Consolidated Guidance 

about Materials Licenses

Program-Specific Guidance about

Well Logging, Tracer, and Field

Flood Study Licenses

Draft Report for Comment

Office of Federal and State Materials and

Environmental Management Programs

NUREG-1556

Volume 14, Rev. 1
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Consolidated Guidance 

about Materials Licenses

Program-Specific Guidance about

Well Logging, Tracer, and Field

Flood Study Licenses

Draft Report for Comment

Manuscript Completed: May 2014

Date Published: May 2014

Prepared by

K. Lambert

S. Mack

R. Torres

S. Wilson

Office of Federal and State Materials and

 Environmental Management Programs

 

NUREG-1556

Volume 14, Rev. 1
 

COMMENTS ON DRAFT REPORT

Any interested party may submit comments on this report for consideration by the NRC staff. 

Comments may be accompanied by additional relevant information or supporting data. Please 

specify the report number NUREG-1556, Volume 14, Revision 1, in your comments, and send 

them by the end of the comment period specified in the Federal Register notice announcing the 

availability of this report. 

Addresses: You may submit comments by any one of the following methods. Please include 

Docket ID NRC-2014-0119 in the subject line of your comments. Comments submitted in 

writing or in electronic form will be posted on the NRC website and on the Federal rulemaking 

website http://www.regulations.gov. 

Federal Rulemaking Website: Go to http://www.regulations.gov and search for documents 

filed under Docket ID NRC-2014-0119. Address questions about NRC dockets to Carol 

Gallagher at 301-287-3422 or by e-mail at Carol.Gallagher@nrc.gov. 

Mail comments to: Cindy Bladey, Chief, Rules, Announcements, and Directives Branch 

(RADB), Division of Administrative Services, Office of Administration, Mail Stop: 

TWB-05-B01M, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001. 

For any questions about the material in this report, please contact: Tomas Herrera, Team 

Leader at 301-415-7138 or by e-mail at Tomas.Herrera@nrc.gov. 

Please be aware that any comments that you submit to the NRC will be considered a public 

record and entered into the Agencywide Documents Access and Management System 

(ADAMS). Do not provide information you would not want to be publicly available. 
iii 

ABSTRACT 

This technical report contains information intended to provide program-specific guidance and 

assist applicants and licensees in preparing applications for materials licenses for well logging, 

tracer, and field flood studies. In particular, it describes the types of information needed to 

complete U.S. Nuclear Regulatory Commission (NRC) Form 313, “Application for Materials 

License.” This document describes both the methods acceptable to the NRC license reviewers 

in implementing the regulations and the techniques used by the reviewers in evaluating the 

application to determine if the proposed activities are acceptable for licensing purposes. 

Paperwork Reduction Act Statement

This NUREG contains information collection requirements that are subject to the Paperwork 

Reduction Act of 1995 (44 U.S.C. 3501 et seq.). These information collection requirements 

were approved by the Office of Management and Budget, approval number 3150-0120. 

Public Protection Notification

The NRC may not conduct or sponsor, and a person is not required to respond to, a request for 

information or an information collection requirement unless the requesting document displays a 

currently valid OMB control number. 

v 

FOREWORD 

The U.S. Nuclear Regulatory Commission’s (NRC’s) NUREG-1556 technical report series 

provides a comprehensive source of reference information about various aspects of materials 

licensing and materials program implementation. These reports, where applicable, describe a 

risk-informed, performance-based approach to licensing consistent with the current regulations. 

The reports are intended for use by applicants, licensees, license reviewers, and other NRC 

personnel. The NUREG-1556 series currently includes the following volumes: 

Volume No. Volume Title 

1 Program-Specific Guidance about Portable Gauge Licenses 

2 Program-Specific Guidance about Industrial Radiography Licenses 

3 Applications for Sealed Source and Device Evaluation and Registration 

4 Program-Specific Guidance about Fixed Gauge Licenses 

5 Program-Specific Guidance about Self-Shielded Irradiator Licenses 

6 Program-Specific Guidance about 10 CFR Part 36 Irradiator Licenses 

7 Program-Specific Guidance about Academic, Research and Development, and 

Other Licenses of Limited Scope 

8 Program-Specific Guidance about Exempt Distribution Licenses 

9 Program-Specific Guidance about Medical Use Licenses 

10 Program-Specific Guidance about Master Materials Licenses 

11 Program-Specific Guidance about Licenses of Broad Scope 

12 Program-Specific Guidance about Possession Licenses for Manufacturing and 

Distribution 

13 Program-Specific Guidance about Commercial Radiopharmacy Licenses 

14 Program-Specific Guidance about Well Logging, Tracer, and Field Flood Study 

Licenses 

15 Guidance about Changes of Control and about Bankruptcy Involving Byproduct, 

Source, or Special Nuclear Materials Licenses 

16 Program-Specific Guidance about Licenses Authorizing Distribution to General 

Licensees 
vi 

Volume No. Volume Title 

17 Program-Specific Guidance about Special Nuclear Material of Less Than 

Critical Mass Licenses 

18 Program-Specific Guidance about Service Provider Licenses 

19 Guidance for Agreement State Licensees about NRC Form 241 “Report of 

Proposed Activities in Non-Agreement States, Areas of Exclusive Federal 

Jurisdiction, or Offshore Waters” and Guidance for NRC Licensees Proposing to 

Work in Agreement State Jurisdiction (Reciprocity) 

20 Program-Specific Guidance about Administrative Licensing Procedures 

21 Program-Specific Guidance about Possession Licenses for Production of 

Radioactive Materials Using an Accelerator 

22 Reserved 

The current document, NUREG--1556, Volume 14, Revision 1, “Consolidated Guidance about 

Materials Licenses: Program-Specific Guidance about Well Logging, Tracer, and Field Flood 

Study Licenses,” is intended for use by applicants, licensees, and NRC staff. This revision 

provides a general update to the previous information contained in NUREG-1556, Volume 14, 

dated June 2000. 

This report takes a risk-informed, performance-based approach to licensing the use of sources 

in well logging, tracer, and field flood study applications. A team composed of staff from NRC 

headquarters, NRC regional offices, and Agreement States prepared this document, drawing on 

their collective experience in radiation safety in general and as specifically applied to well 

logging, tracer, and field flood study operations. 

NUREG1556, Volume 14, Revision 1, is not a substitute for NRC regulations. The approaches 

and methods described in this report are provided for information only. Methods and solutions 

different from those described in this report may be acceptable if they include a basis for the 

staff to make the determinations needed to issue or continue a license. 

________________________________________ 

Laura A. Dudes, Director 

Division of Materials Safety and State Agreements 

Office of Federal and State Materials and Environmental Management Programs 
vii 

CONTENTS 

ABSTRACT ................................................................................................................................. iii 

FOREWORD ................................................................................................................................. v

FIGURES AND TABLES ............................................................................................................. xi 

ACKNOWLEDGMENTS ............................................................................................................ xiii

ABBREVIATIONS ...................................................................................................................... xv

1. PURPOSE OF REPORT ...................................................................................................... 1

2. AGREEMENT STATES ........................................................................................................ 3

3. MANAGEMENT RESPONSIBILITY ..................................................................................... 7

 3.1 Commitments and Responsibilities ............................................................................... 7 

 3.2 Safety Culture ............................................................................................................... 8

4. APPLICABLE REGULATIONS .......................................................................................... 11

5. HOW TO FILE .................................................................................................................... 13

 5.1 Paper Application ........................................................................................................ 13 

 5.2 Where to file ................................................................................................................ 13 

 5.3 Transfer to Electronic Format ...................................................................................... 14 

6. IDENTIFYING AND PROTECTING SENSITIVE INFORMATION ...................................... 15

7. APPLICATION AND LICENSE FEES ................................................................................ 17 

8. CONTENTS OF AN APPLICATION ................................................................................... 19 

 8.1 Item 1: License Action Type ...................................................................................... 20 

 8.2 Item 2: Name and Mailing Address of Applicant ....................................................... 20 

 8.2.1 Notification of Bankruptcy Proceedings ........................................................ 20 

 8.3 Item 3: Address(es) Where Licensed Material Will Be Used or Possessed .............. 21 

 8.4 Item 4: Person to Be Contacted about This Application ............................................ 22 

 8.5 Item 5: Radioactive Material ...................................................................................... 22 

 8.5.1 Sealed Sources and Devices ...................................................................... 25 

 8.5.2 Unsealed (Tracer) Radioactive Material ...................................................... 26 

 8.5.3 Financial Assurance and Record Keeping for Decommissioning ................ 28 

 8.6 Item 6: Purpose(s) for Which Licensed Material Will be Used .................................. 32 

 8.7 Item 7: Individual(s) Responsible for the Radiation Safety Program 

 and Their Training and Experience ............................................................... 34 

 8.7.1 Radiation Safety Officer (RSO) .................................................................... 34 

 8.8 Item 8: Training for Logging Supervisors and Logging Assistants ............................ 37 

 8.9 Item 9: Facilities and Equipment .............................................................................. 39 

 8.10 Item 10: Radiation Safety Program ............................................................................ 42 

 8.10.1 Well Owner or Operator Agreements ......................................................... 43 

 8.10.2 Radiation Safety Program Audit ................................................................. 47 

 8.10.3 Radiation Monitoring Instruments ............................................................... 48 

 8.10.4 Material Receipt and Accountability ........................................................... 50 

 8.10.5 Occupational Dosimetry ............................................................................. 52 

 8.10.6 Public Dose ................................................................................................ 54 

 8.10.7 Operating and Emergency Procedures ...................................................... 55 

 8.10.8 Leak Tests .................................................................................................. 58 

 8.10.9 Maintenance ............................................................................................... 59 

 8.10.9.1 Maintenance Prior To Use ........................................................... 59 

 8.10.9.2 Semi-Annual Visual Inspection and Routine Maintenance .......... 60 

 8.10.9.3 Maintenance Requiring Special Authorization ............................. 61
viii 

 8.10.10 Transportation ............................................................................................ 63 

 8.10.11 Minimization of Contamination ................................................................... 64 

 8.10.12 Sealed Sources .......................................................................................... 66 

 8.10.12.1 Use of Sealed Sources in Drill-To-top (Wireline) Operations ..... 66 

 8.10.12.2 Use of Sealed Sources in Measurement While Drilling or 

 Logging While Drilling Well Logging Operations ......................... 68 

 8.10.12.3 Energy Compensation Sources .................................................. 68 

 8.10.12.4 Use of Sealed Sources and/or Neutron Generators in 

 Freshwater Aquifers .................................................................... 70 

 8.10.13 Subsurface Tracer Studies ......................................................................... 71 

 8.10.13.1 Tracer Studies in Single Well Applications ................................. 71 

 8.10.13.2 Field flood and secondary recovery applications 

 (Tracer Studies in Multiple Wells) ............................................... 72 

 8.10.13.3 Tracer Studies in Freshwater Aquifers ....................................... 74 

 8.10.14 Radioactive Collar and Subsidence or Depth Control Markers .................. 75 

 8.10.15 Neutron Accelerators Using Licensed Material .......................................... 75 

 8.10.16 Depleted Uranium Sinker Bars ................................................................... 77 

 8.10.17 Security Program for Category 1 and Category 2 Materials ....................... 79 

 8.11 Item 11: Waste Management ................................................................................... 80 

 8.12 Item 12: License Fees .............................................................................................. 84

 8.13 Item 13: Certification ................................................................................................ 85 

9. AMENDMENTS AND RENEWALS TO A LICENSE .......................................................... 87 

 9.1 Timely Notification of Transfer of Control ................................................................... 87

10. APPLICATIONS FOR EXEMPTIONS ................................................................................ 89 

11. TERMINATION OF ACTIVITIES ........................................................................................ 91 

APPENDICES 

APPENDIX A LIST OF DOCUMENTS CONSIDERED IN DEVELOPMENT OF 

 THIS NUREG ................................................................................................ A-1 

APPENDIX B U.S. NUCLEAR REGULATORY COMMISSION FORM 313 ........................ B-1 

APPENDIX C SUGGESTED FORMAT FOR PROVIDING INFORMATION 

 REQUESTED IN ITEMS 5 THROUGH 11 OF NRC FORM 313 ................... C-1 

APPENDIX D CHECKLIST FOR LICENSE APPLICATION ................................................ D-1 

APPENDIX E FIELD FLOOD STUDIES/ENHANCED RECOVERY OF OIL AND 

 GAS WELLS ................................................................................................. E-1 

APPENDIX F SUGGESTED WELL LOGGING AND FIELD FLOOD AUDIT 

 CHECKLIST ................................................................................................... F-1 

APPENDIX G WELL LOGGING SUPERVISOR AND LOGGING ASSISTANT 

 TRAINING REQUIREMENTS ....................................................................... G-1 

APPENDIX H ANNUAL INTERNAL JOB PERFORMANCE INSPECTION 

 CHECKLIST FOR WELL LOGGING SUPERVISORS AND WELL 

 LOGGING ASSISTANTS .............................................................................. H-1 

APPENDIX I RADIATION MONITORING INSTRUMENT SPECIFICATIONS 

 AND MODEL SURVEY INSTRUMENT CALIBRATION PROGRAM .............. I-1 

APPENDIX J GUIDANCE FOR DEMONSTRATING THAT UNMONITORED 

 INDIVIDUALS ARE NOT LIKELY TO EXCEED 10 PERCENT OF THE 

 ALLOWABLE LIMITS ..................................................................................... J-1 

APPENDIX K GUIDANCE FOR DEMONSTRATING THAT INDIVIDUAL MEMBERS 

 OF THE PUBLIC WILL NOT RECEIVE DOSES EXCEEDING THE 

 ALLOWABLE LIMITS .................................................................................... K-1
ix 

APPENDIX L NOTIFICATION OF PROPER PERSONS IN THE EVENT OF 

 AN ACCIDENT ............................................................................................... L-1 

APPENDIX M MODEL LEAK TEST PROGRAM ................................................................. M-1 

APPENDIX N TRANSPORTATION-MAJOR DOT REGULATIONS; SAMPLE 

 SHIPPING DOCUMENTS, PLACARDS AND LABELS ................................ N-1 

APPENDIX O MODEL WASTE MANAGEMENT PROCEDURES ...................................... O-1 

APPENDIX P ACTIONS TO BE TAKEN IF A SEALED SOURCE IS RUPTURED OR 

 IF LICENSED MATERIALS HAVE CAUSED CONTAMINATION ................. P-1 

APPENDIX Q MODEL DELEGATION OF AUTHORITY .................................................. Q-1 

APPENDIX R INTERIM STAFF GUIDANCE ON CONSTRUCTION ................................... R-1 

APPENDIX S SAFETY CULTURE STATEMENT OF POLICY ........................................... S-1 

xi 

FIGURES 

Figure 2.1 U.S. Map: Location of NRC Offices and Agreement States .................................... 3 

Figure 8.1 Types of records that must be maintained for decommissioning ........................... 31 

Figure 8.2 RSO responsibilities—Typical duties and responsibilities of the RSO ................... 36 

Figure 8.3 Features of a Typical Source Abandonment .......................................................... 45 

Figure 8.4 Permanent Identification Plaque ............................................................................ 46 

Figure 8.5 Types of surveys .................................................................................................... 49 

Figure 8.6 Material receipt and accountability ......................................................................... 51 

Figure 8.7 Annual dose limits for occupationally exposed adults ............................................ 52 

Figure 8.8 Steps used to calculate public dose ....................................................................... 55 

Figure 8.9 Maintenance, cleaning, and O-ring replacement .................................................... 62 

Figure 8.10 Transportation ........................................................................................................ 63 

Figure 8.11 Transport container ................................................................................................ 64 

Figure 8.12 Personnel surveys .................................................................................................. 66 

Figure 8.13 Drill to stop well logging operations ........................................................................ 67 

Figure 8.14 Singly encapsulated ECS sealed source ............................................................... 70 

Figure K.1 Bird’s eye view of office ....................................................................................... K-2 

Figure K.2 Down-hole storage array ..................................................................................... K-3 

TABLES 

Table 2.1 Who Regulates the Activity? .................................................................................... 4 

Table 3.1 Traits of a Positive Safety Culture ............................................................................ 9 

Table 8.1 Types of Radioactive Material ................................................................................ 23 

Table 8.2 Types of Radioactive Materials Used in Field Flood Studies and 

 Single Well Tracer Operations ............................................................................... 27 

Table 8.3 Commonly Used Licensed Materials Requiring Financial 

Assurance/Decommissioning Funding Plan ........................................................... 30 

Table 8.4 Sample Format for Providing Information about Requested Radionuclides ........... 33 

Table A.1 List of Regulatory Guides, NUREG Reports, and Policy and Guidance 

Directives ............................................................................................................. A-1 

Table I.1 Typical Survey ........................................................................................................ I-1 

Table K.1 Information Known about Dose at the Shield of the Cs-137 Source ................... K-4 

Table K.2 Calculational Method, Part 1 ................................................................................ K-4 

Table K.3 Calculational Method, Part 2 ................................................................................ K-5 

xiii 

ACKNOWLEDGMENTS 

The working group thanks the individuals listed below for assisting in the review and update of 

the report. All participants provided valuable insights, observations, and recommendations. 

The working group would like to thank the staff in the regional offices of the NRC and all of the 

States who provided comments and technical information that assisted in the development of 

this report. 

The working group also thanks Lisa Dimmick, John O’Donnell, Monica Orendi, Tara Weidner, 

and Duane White for developing the formatting and language used in many parts of the report. 

The Participants for this Revision: 

Bielecki, Jessica 

Gilman, Joseph 

Lambert, Kenneth 

Mack, Steve 

Park, James 

Price, Sarah 

Torres, Roberto J. 

Wilson, Scott 

 xv 

ABBREVIATIONS 

ADAMS Agencywide Documents Access and Management System 

ALARA as low as is reasonably achievable 

ALI annual limit on intake 

ANSI American National Standards Institute 

bkg background 

Bq becquerel 

CDE committed dose equivalent 

CEDE committed effective dose equivalent 

CFR Code of Federal Regulations

Ci curie 

cpm counts per minute 

DFP decommissioning funding plan 

DIS decay-in-storage 

DOT U.S. Department of Transportation 

dpm disintegrations per minute 

DTS drill-to-stop 

EA environmental assessment 

ECS energy compensation source 

EPA U.S. Environmental Protection Agency 

F/A financial assurance 

FR Federal Register

FSME Office of Federal and State Materials and Environmental Management Programs 

G-M Geiger-Mueller 

GBq gigabecquerel 

GPO Government Printing Office 

IN information notice 

LLW low level waste 

LSA low specific activity 

LWD logging while drilling 

MBq megabecquerel 

MC manual chapter 

mCi millicurie 

mR milliroentgen 

mrem millirem 

μSv microsievert 

mSv millisievert 

MWD measurement while drilling 

NCRP National Council on Radiation Protection and Measurements 

NIST National Institute of Standards and Technology 

NMSS Office of Nuclear Material Safety and Safeguards
 xvi 

NRC U.S. Nuclear Regulatory Commission 

NVLAP National Voluntary Laboratory Accreditation Program 

OGC Office of the General Counsel 

OMB Office of Management and Budget 

OSL optically stimulated luminescence 

Q quality factor 

rad radiation absorbed dose 

rem radiation dose equivalent (man) 

RG regulatory guide 

RIS regulatory information summary 

RQ reportable quantities 

RSO radiation safety officer 

SI International System of Units 

SSD sealed source and device 

std standard 

Sv sievert 

T1/2 radioactive material half-life 

TAR technical assistance request 

TEDE total effective dose equivalent 

TI transportation index 

TLD thermoluminescent dosimeters 

USASI United States of America Standards Institute
1 

1. PURPOSE OF REPORT 

Byproduct material, as defined in Title 10 of the Code of Federal Regulations (10 CFR) 30.4, 

“Definitions,” depleted uranium, as defined in 10 CFR 40.4, “Definitions,” and special nuclear 

material, as defined in 10 CFR 70.4, “Definitions,” are used for a variety of purposes to include: 

well logging and tracer applications involving both single or multiple well bores; conventional 

well logging and tracer operations; and, in some cases, research and development. Examples 

include the following applications: 

 Sealed sources are used in cased and uncased boreholes. 

 Tracer materials are used in single well applications. 

 Tracer materials are used in multiple well applications (field flood study) for enhanced 

recovery of oil and gas wells. 

 Sealed sources are used for calibration of applicant’s survey instruments and well 

logging tools. 

 Sealed sources and tracer materials are used in the research and development of new 

techniques and equipment. 

This report provides guidance to an applicant in preparing a well logging, tracer, and field flood 

study license application as well as U.S. Nuclear Regulatory Commission (NRC) criteria for 

evaluating the corresponding license application. Chapter 8 of this report, “Contents of an 

Application,” identifies the information needed to complete NRC Form 313, “Application for 

Materials License,” (see Appendix B) for the use of sealed byproduct materials in well logging 

and unsealed byproduct materials in tracer and field flood study applications. The information 

collection requirements in 10 CFR Parts 19, 20, 21, 30, 32, 39, 40, 51, 70, and NRC Form 313 

have been approved under the Office of Management and Budget (OMB) Control Numbers 

3150-0044, 3150-0014, 3150-0035, 3150-0130, 3150-0017, 3150-0001, 3150-0020, 3150-0021, 

3150-0009, and 3150-0120. 

The format within this document for each item of technical information is as follows: 

 Regulations—references the regulations applicable to the item 

 Criteria—outlines the criteria used to evaluate the applicant’s response 

 Discussion—provides additional information about the topic 

 Response from Applicant—provides suggested response or responses, offers the option 

of an alternative reply, or indicates that no response is needed on that topic during the 

licensing process 

Notes and references are self-explanatory and may not be found for each item on NRC 

Form 313. 
2 

NRC Form 313 does not have sufficient space for applicants to provide full responses to 

Items 5 through 11, as indicated on the form. Applicants should address those items on 

separate sheets of paper and submit them along with the completed NRC Form 313. For the 

convenience and streamlined handling of well logging, tracer, or field flood study applications, 

Appendix C, “Suggested Format for Providing Information Requested in Items 5 through 11 of 

NRC Form 313,” may be used to provide supporting information. Appendices D through V 

contain additional information on various radiation safety topics. 

In this document, dose or radiation dose means absorbed dose, dose equivalent, effective dose 

equivalent, committed dose equivalent, committed effective dose equivalent, or total effective 

dose equivalent (TEDE), as defined in 10 CFR Part 20, “Standards for Protection against 

Radiation.” Rem and its International System of Units (SI) equivalent, sievert (Sv) 

(1 rem = 0.01 Sv), are used to describe units of radiation exposure or dose. This is done 

because 10 CFR Part 20 sets dose limits in terms of rem, rather than rad or roentgen. When 

the radioactive material emits beta and gamma rays, 1 roentgen is assumed to equal 1 rad, 

which is assumed to equal 1 rem. For alpha and neutron-emitting radioactive material, 1 rad is 

not equal to 1 rem. Determination of dose equivalent (rem) from absorbed dose (rad) from 

alpha particles and neutrons requires the use of an appropriate quality factor (Q) value. These 

Q values are used to convert absorbed dose (rad) to dose equivalent (rem); Tables 1004(b)(1) 

and (2) in 10 CFR 20.1004, “Units of radiation dose,” address the Q values for alpha and 

neutron particles. 

Appendix E provides specific guidance for licensing field flood activities 
3 

2. AGREEMENT STATES 

Certain States, called Agreement States (see Figure 2.1), have entered into agreements with 

the NRC that give them the authority to license and inspect byproduct, source, and special 

nuclear materials, in quantities not sufficient to form a critical mass, which are used or 

possessed within their borders. Any applicant, other than a Federal entity, who wishes to 

possess or use licensed material in one of these Agreement States should contact the 

responsible officials in that State for guidance on preparing an application. These applications 

should be filed with State officials, not with the NRC. In areas under exclusive federal 

jurisdiction within an Agreement State, NRC continues to be the regulatory authority. 

Figure 2.1 U.S. map: Locations of NRC Offices and Agreement States

In the special situation of work at Federally controlled sites in Agreement States, it is necessary 

to ascertain the jurisdictional status of the land to determine whether the NRC or the Agreement 

State has regulatory authority. These areas can also include tribal lands of federally recognized 

Indian tribes.1

 

 

1

 For the purposes of this guidance, an “Indian tribe” is defined as an Indian or Alaska Native tribe, band, nation, 

 pueblo, village, or community that the Secretary of the Interior acknowledges to exist as an Indian tribe pursuant 

 to the Federally Recognized Indian Tribe List Act of 1994. A list of federally recognized tribes is available at 

 www.bia.gov. 
4 

The NRC has regulatory authority over land determined to be “exclusive Federal jurisdiction,” 

while the Agreement State has jurisdiction over nonexclusive Federal jurisdiction land. 

Applicants are responsible for determining in advance the jurisdictional status of the specific 

areas where they plan to conduct licensed operations. The NRC recommends that applicants 

contact their local office of the Federal agency controlling the site (e.g., contract officer, base 

environmental health officer, district office staff) for assistance in determining the jurisdictional 

status of the land and to provide the information in writing to ensure compliance with NRC or 

Agreement State regulatory requirements, as appropriate. Additional guidance on determining 

jurisdictional status is found in the Office of Federal and State Materials and Environmental 

Management Program’s (FSME) procedures in the State Agreement (SA) series, SA-500, 

“Jurisdiction Determination,” which is available at http://nrc-stp.ornl.gov/. Once on the Web site, 

use the link for “FSME Procedures” in the left hand column under “Resources & Tools.” The link 

will take you to another Web page where you can search for FSME Procedures. 

Table 2.1 provides a quick way to evaluate whether the NRC or an Agreement State has 

regulatory authority. 

Table 2.1 Who Regulates the Activity? 

Applicant and Proposed Location of Work Regulatory 

Agency 

Federal agency regardless of location (except the U.S. Department of 

Energy and, under most circumstances, its prime contractors are exempt 

from licensing, in accordance with 10 CFR 30.12, “Persons using byproduct 

material under certain Department of Energy and Nuclear Regulatory 

Commission contracts”) 

NRC 

Non-Federal entity in non-Agreement State, District of Columbia, 

U.S. territory or possession, or in offshore Federal waters NRC 

Federally recognized Indian Tribe or tribal member on Indian Tribal land NRC 

Non-federal entity on Federally recognized Indian Tribal land NRC2

Federally recognized Indian Tribe or tribal member outside of Indian Tribal 

land in Agreement State. Agreement State

 

2

 The NRC can exercise jurisdiction as the regulatory authority on tribal land of a Federally recognized Indian 

 Tribe. Section 274b. Agreements do not give States the authority to regulate nuclear material in these areas. 

 However, there are a few States that exercise regulatory authority over these areas based on treaties or 

 agreements with specific tribes. Companies owned or operated by Federally recognized Indian Tribe members or 

 non-Indians that wish to possess or use licensed material on tribal lands should contact the appropriate NRC 

 regional office to determine the jurisdictional status of the tribal lands and identify the appropriate regulatory 

 agency for licensing and reciprocity. 
5 

Applicant and Proposed Location of Work Regulatory 

Agency 

Non-Federal entity in Agreement State Agreement 

State3

Non-Federal entity in Agreement State at Federally controlled site not

subject to exclusive Federal jurisdiction 

Agreement 

State3

Non-Federal entity in Agreement State at Federally controlled site subject to 

exclusive Federal jurisdiction NRC 

Non-Federal entity in Agreement State using radioactive materials (except 

industrial radiography) directly connected with Part 50 or 52 reactor 

operations or needed during the construction and preoperational phases of a 

reactor. 

NRC 

Non-Federal entity in Agreement State using radioactive materials not

directly connected with Part 50 or 52 reactor operations or needed during the 

construction and preoperational phases of a reactor. 

Agreement 

State3

Reference: A current list of Agreement States (including names, addresses, and telephone 

numbers of responsible officials) is available at the Office of Federal and State Materials and 

Environmental Management Programs’ public Web site, http://nrc-stp.ornl.gov. As an 

alternative, a request for the list can be made to an NRC regional office. 

 

3

 Section 274m. of the AEA gives the NRC regulatory authority over radioactive materials covered under the 

 Section 274b. Agreement when the activity can affect the Commission’s authority to protect the common 

 defense and security, to protect restricted data, or guard against the loss or diversion of special nuclear material 

 at a site. (This is an uncommon situation which NRC usually evaluates on a case-by-case basis.) Companies 

 that wish to possess or use licensed material at these sites should contact the licensee to determine the 

 jurisdictional status for specific AEA radioactive materials they intend to possess or use at the site. 

7 

3. MANAGEMENT RESPONSIBILITY 

The NRC recognizes that effective radiation safety program management is vital to achieving 

safe, secure, and compliant operations. Consistent compliance with NRC regulations provides 

reasonable assurance that licensed activities will be conducted safely and that effective 

management will result in increased safety, security, and compliance. 

“Management,” as used in this volume, refers to the processes for conduct and control of a 

radiation safety program and to the individuals who are responsible for those processes and 

who have authority to provide necessary resources to achieve regulatory compliance. 

3.1 Commitments and Responsibilities 

Pursuant to 10 CFR 30.32(c), each application shall be signed by the applicant or licensee or a 

person duly authorized to act for and on the behalf of the applicant or licensee. If it is not clear 

whether the application was signed by someone duly authorized to act for and on the behalf of 

the applicant or licensee, NRC license reviewers may ask for additional assurances that the 

individual who signed the application is duly authorized to act for and on the behalf of the 

applicant or licensee. The signature on an application acknowledges the licensee’s 

commitments and responsibilities for the following: 

 Radiation safety, security, and control of radioactive materials and compliance with 

regulations; 

 Completeness and accuracy of the radiation safety records and all information provided 

to the NRC (10 CFR 30.9, “Completeness and accuracy of information”); 

 Knowledge about the contents of the license and application; 

 Compliance with current NRC and U.S. Department of Transportation (DOT) regulations 

and the licensee’s operating, emergency, and security procedures; 

 Commitment to provide adequate resources (including space, equipment, personnel, 

time, and, if needed, contractors) to the radiation protection program to ensure that the 

public and workers are protected from radiation hazards and compliance with regulations 

is maintained; 

 Selection and assignment of a qualified individual to serve as the radiation safety officer 

(RSO) for licensed activities and confirmation that the RSO has independent authority to 

stop unsafe operations and will be given sufficient time to fulfill radiation safety duties 

and responsibilities; 

 Commitment to ensure that radiation workers have adequate training; 

 Prevention of discrimination of employees engaged in protected activities (10 CFR 30.7, 

“Employee protection”) 
8 

 Commitment to provide information to employees about the employee protection and 

deliberate misconduct provisions in 10 CFR 30.7 and 10 CFR 30.10, “Deliberate 

misconduct,” respectively; 

 Commitment to obtain the NRC’s prior written consent before transferring control of the 

license (see Section 9.1, “Timely Notification of Transfer of Control,” of this report); 

 Notification of the appropriate NRC regional administrator in writing, immediately 

following the filing of a petition for voluntary or involuntary bankruptcy (10 CFR 30.34(h)), 

as discussed further in Section 8.2.1, “Notification of Bankruptcy Proceedings,” of this 

report. 

For information on NRC inspection, investigation, enforcement, and other compliance programs, 

see the current version of the NRC’s Enforcement Policy and Inspection Procedures available in 

the NRC’s online library at http://www.nrc.gov/reading-rm.html. 

3.2 Safety Culture 

Individuals and organizations performing regulated activities are expected to establish and 

maintain a positive safety culture commensurate with the safety and security significance of 

their activities and the nature and complexity of their organizations and functions. This applies 

to all licensees, certificate holders, permit holders, authorization holders, holders of quality 

assurance program approvals, vendors and suppliers of safety-related components, and 

applicants for a license, certificate, permit, authorization, or quality assurance program approval, 

subject to NRC authority. 

“Nuclear safety culture” is defined in the NRC’s safety culture policy statement (76 FR 34773), 

June 14, 2011) as the core values and behaviors resulting from a collective commitment by 

leaders and individuals to emphasize safety over competing goals to ensure protection of 

people and the environment. Individuals and organizations performing regulated activities bear 

the primary responsibility for safely handling and securing these materials. Experience has 

shown that certain personal and organizational traits are present in a positive safety culture. A 

trait, in this case, is a pattern of thinking, feeling, and behaving that emphasizes safety, 

particularly in goal conflict situations (e.g., production versus safety, schedule versus safety, 

and cost of the effort versus safety). Refer to Table 3.1 for the traits of a positive safety culture 

from the NRC’s safety culture policy statement. 

Organizations should ensure that personnel in the safety and security sectors have an 

appreciation for the importance of each, emphasizing the need for integration and balance to 

achieve both safety and security in their activities. Safety and security activities are closely 

intertwined. While many safety and security activities complement each other, there may be 

instances in which safety and security interests create competing goals. It is important that 

consideration of these activities be integrated so as not to diminish or adversely affect either; 

thus, mechanisms should be established to identify and resolve these differences. A safety 

culture that accomplishes this would include all nuclear safety and security issues associated 

with NRC-regulated activities. 

The NRC, as the regulatory agency with an independent oversight role, reviews the 

performance of individuals and organizations to determine compliance with requirements and 

commitments through its existing inspection and assessment processes. However, the NRC’s 
9 

safety culture policy statement and traits are not incorporated into the regulations. Safety 

culture traits may be inherent to an organization’s existing radiation safety practices and 

programs. For instance, during the daily visual inspection of logging equipment, a well logging 

supervisor identifies damaged threads on a well logging tool, removes the defective tool from 

service, and notifies management so the tool can be repaired or replaced. The requirement for 

daily visual inspections of logging equipment may correspond with the safety culture trait 

specified in Table 3.1 as “Personal Accountability” (all individuals take personal responsibility for 

safety). However, licensees should be aware that this is just an example, and should consider 

reviewing their radiation safety programs in order to develop and implement a safety culture 

commensurate with the nature and complexity of their organizations and functions. 

Refer to Appendix S for the NRC’s safety culture policy statement. More information on NRC 

activities relating to safety culture can be found at: 

http://www.nrc.gov/about-nrc/safety-culture.html. 

Table 3.1 Traits of a Positive Safety Culture

Leadership Safety Values 

and Actions 

Problem Identification and 

Resolution 

Personal Accountability 

Leaders demonstrate a 

commitment to safety in their 

decisions and behaviors 

Issues potentially impacting 

safety are promptly 

identified, fully evaluated, 

and promptly addressed and 

corrected commensurate 

with their significance 

All individuals take personal 

responsibility for safety 

Work Processes Continuous Learning Environment for Raising 

Concerns 

The process of planning and 

controlling work activities is 

implemented so that safety 

is maintained 

Opportunities to learn about 

ways to ensure safety are 

sought out and implemented 

A safety conscious work 

environment is maintained 

where personnel feel free to 

raise safety concerns without 

fear of retaliation, 

intimidation, harassment, or 

discrimination 

Effective Safety 

Communications 

Respectful Work 

Environment 

Questioning Attitude 

Communications maintain a 

focus on safety 

Trust and respect permeate 

the organization 

Individuals avoid 

complacency and 

continuously challenge 

existing conditions and 

activities in order to identify 

discrepancies that might 

result in error or 

inappropriate action 

11 

4. APPLICABLE REGULATIONS 

It is the applicant’s or licensee’s responsibility to obtain and have available up-to-date copies of 

applicable regulations, to read and understand the requirements of each of these regulations, 

and to comply with each applicable regulation. The following parts of Title 10 of the Code of 

Federal Regulations (10 CFR) contain regulations applicable to well logging, tracer, and field 

flood studies. Some of these parts are specific to one type of license, while others are general 

and will apply to many if not all licensees. 

The current versions of these parts can be found under the “Basic References” link at the NRC’s 

online library at http://www.nrc.gov/reading-rm.html; if viewing in a browser, the following list 

includes direct links to the rules: 

 10 CFR Part 2, “Agency Rules of Practice and Procedure” 

 10 CFR Part 19, “Notices, Instructions and Reports to Workers: Inspection and 

Investigations” 

 10 CFR Part 20, “Standards for Protection Against Radiation” 

 10 CFR Part 21, “Reporting of Defects and Noncompliance” 

 10 CFR Part 30, “Rules of General Applicability to Domestic Licensing of Byproduct 

Material” 

 10 CFR Part 32, “Specific Domestic Licenses to Manufacture or Transfer Certain Items 

Containing Byproduct Material” 

 10 CFR Part 33, “Specific Domestic Licenses of Broad Scope for Byproduct Material” 

 10 CFR Part 37, “Physical Protection of Category 1 and Category 2 Quantities of 

Radioactive Material” 

 10 CFR Part 39, “Licenses and Radiation Safety Requirements for Well Logging” 

 10 CFR Part 40, “Domestic Licensing of Source Material” 

 10 CFR Part 70, “Domestic Licensing of Special Nuclear Material” 

 10 CFR Part 71, “Packaging and Transportation of Radioactive Material” 

 10 CFR Part 110, “Export and Import of Nuclear Equipment and Material” 

 10 CFR Part 150, “Exemptions and Continued Regulatory Authority in Agreement States 

and in Offshore Waters under Section 274” 

 10 CFR Part 170, “Fees for Facilities, Materials, Import and Export Licenses, and Other 

Regulatory Services Under the Atomic Energy Act of 1954, as Amended”
12 

 10 CFR Part 171, “Annual Fees for Reactor Licenses and Fuel Cycle Licenses and 

Materials Licenses, Including Holders of Certificates of Compliance, Registrations, and 

Quality Assurance Program Approvals and Government Agencies Licensed by the NRC” 

Copies of the above documents may be obtained by calling the Government Printing Office 

order desk toll-free at 866–512–8600, in Washington, DC, at 202–512–1800 or online at 

http://bookstore.gpo.gov. 

In addition, 10 CFR Parts 1 through 199 can be found on the NRC’s Web site at 

http://www.nrc.gov/reading-rm/doc-collections/ under “Regulations (10 CFR).” 

NRC regulations and amendments also can be accessed from the “NRC Library” link on the 

NRC’s public Web site at http://www.nrc.gov. The NRC and all other Federal agencies publish 

amendments to their regulations in the Federal Register.
13 

5. HOW TO FILE 

5.1 Paper Application 

Applicants for a materials license should do the following: 

 Use the most recent guidance in preparing an application. 

 Complete NRC Form 313 (Appendix B) Items 1 through 4, 12, and 13 on the form itself. 

 Complete NRC Form 313 Items 5 through 11 on supplementary pages or use 

Appendix C. 

 Provide sufficient detail for the NRC to determine that equipment, facilities, training, 

experience, and the radiation safety program are adequate to protect health and safety 

and minimize danger to life and property. 

 For each separate sheet other than NRC Form 313 and Appendix C submitted with the 

application, identify and cross-reference submitted information to the item number on the 

application or the topic to which it refers. 

 Submit all documents, typed, on 81⁄2 x 11-inch paper. 

 Avoid submitting proprietary information and personally identifiable information. 

 If submitted, proprietary information and other sensitive information (e.g., personal 

privacy and security related) should be clearly identified according to 10 CFR 2.390, 

“Public inspections, exemptions, requests for withholding” (see Chapter 6, “Identifying 

and Protecting Sensitive Information”). 

 Submit an original, signed application. 

 Retain one copy of the license application for future reference. 

Applications must be signed by the applicant, licensee, or a person duly authorized as 

required by 10 CFR 30.32(c) (see Section 8.13, “Certification”). 

5.2 Where to File 

Applicants wishing to possess or use licensed material in any State, U.S. territory, or 

U.S. possession subject to NRC jurisdiction must file an application with the NRC regional office 

for the locale in which the material will be possessed or used. Figure 2.1 identifies the NRC’s 

four regional offices and their respective areas for licensing purposes and the Agreement 

States. Note that all materials applications are submitted to Regions I, III, or IV. All applicants 

for materials licenses located in the Region II geographical area should send their applications 

to Region I. 

In general, applicants wishing to possess or use licensed material in Agreement States must file 

an application with the Agreement State and not with the NRC. However, if work will be 
14 

conducted at federally controlled sites, or federally recognized Indian Tribal lands, in Agreement 

States, applicants must first determine the jurisdictional status of the land in order to determine 

whether the NRC or the Agreement State has regulatory authority. See Chapter 2, “Agreement 

States,” for additional information. 

5.3 Transfer to Electronic Format 

Paper applications received by the NRC are scanned through an optical character reader and 

converted to an electronic format. To ensure a smooth transfer to an electronic format, 

applicants should do the following: 

 Submit printed or typewritten—not handwritten—text on smooth, crisp paper that will 

feed easily into the scanner. 

 Choose typeface designs that are sans serif, such as Arial, Helvetica, or Futura (the text 

of this document is in the Arial font). 

 Use 12-point or larger font. 

 Avoid stylized characters, such as script or italics. 

 Ensure that the print is clear and sharp. 

 Ensure that there is high contrast between the ink and paper (black ink on white paper is 

best). 

The NRC will provide additional instructions as the agency implements new mechanisms for 

 electronic license application filing.
15 

6. IDENTIFYING AND PROTECTING SENSITIVE INFORMATION 

All licensing applications, except for portions containing sensitive information, will be made 

available for review in the NRC’s Public Document Room and electronically at the NRC Library. 

For more information on the NRC Library, visit http://www.nrc.gov. 

The licensee should identify, mark, and protect sensitive information against unauthorized 

disclosure to the public. Licensing applications that contain sensitive information should be 

marked as indicated below in accordance with 10 CFR 2.390 before the information is submitted 

to the NRC. Key examples are as follows: 

 Proprietary Information and Trade Secrets: If it is necessary to submit proprietary 

information or trade secrets, follow the procedure in 10 CFR 2.390(b). Failure to follow 

this procedure could result in disclosure of the proprietary information to the public or 

substantial delays in processing the application. 

 Personally Identifiable Information: Personally identifiable information (PII) about 

employees or other individuals should not be submitted unless specifically requested by 

the NRC. Examples of PII are social security number, home address, home telephone 

number, date of birth, and radiation dose information. If PII is submitted, a cover letter 

should clearly state that the attached documents contain PII and the top of every page of 

a document that contains PII should be clearly marked as follows: “Privacy Act 

Information—Withhold Under 10 CFR 2.390.” For further information, see Regulatory 

Issue Summary (RIS) 2007-04, “Personally Identifiable Information Submitted to the 

U.S. Nuclear Regulatory Commission,” dated March 9, 2007, which can be found on the 

NRC’s Generic Communications webpage under “Regulatory Issue Summaries”: 

http://www.nrc.gov/reading-rm/doc-collections/gen-comm/. 

 Security-Related Information: Following the events of September 11, 2001, the NRC 

changed its procedures to avoid release of information that terrorists could use to plan or 

execute an attack against facilities or citizens in the United States. As a result, certain 

types of information are no longer routinely released and are treated as sensitive 

unclassified information. For example, certain information about the quantities and 

locations of radioactive material at licensed facilities, and associated security measures, 

are no longer released to the public. Therefore, a cover letter should clearly state that 

the attached documents contain sensitive security-related information and the top of 

every page of a document that contains such information should be clearly marked: 

“Security Related Information—Withhold under 10 CFR 2.390.” For the pages having 

security-related sensitive information, an additional marking should be included (e.g. an 

editorial note box) adjacent to that material. For further information, see RIS 2005-31, 

“Control of Security-Related Sensitive Unclassified Non-Safeguards Information Handled 

by Individuals, Firms, and Entities Subject to NRC Regulation of the Use of Source, 

Byproduct, and Special Nuclear Material,” dated December 22, 2005, which can be 

found on the NRC’s Generic Communications webpage under “Regulatory Issue 

Summaries”: http://www.nrc.gov/reading-rm/doc-collections/gen-comm/. Additional 

information on procedures and any updates is available at http://www.nrc.gov/readingrm/sensitive-info.html.

17 

 

7. APPLICATION AND LICENSE FEES 

Each application for which a fee is specified must be accompanied by the appropriate fee. 

Refer to 10 CFR 170.31, “Schedule of fees for materials licenses and other regulatory services, 

including Inspections, and import and export licenses,” to determine the amount of the fee. The 

NRC will not issue a license until the fee is received. Consult 10 CFR 170.11, “Exemptions,” for 

information on exemptions from these fees. Once the technical review has begun, no fees will 

be refunded; application fees will be charged regardless of the NRC’s disposition of an 

application or the withdrawal of an application. 

Most NRC licensees are also subject to annual fees; refer to 10 CFR 171.16, “Annual fees: 

Materials licensees, holders of certificates of compliance, holders of sealed source and device 

registrations, holders of quality assurance program approvals, and government agencies 

licensed by the NRC.” Consult 10 CFR 171.11 for information on exemptions from annual fees 

and 10 CFR 171.16(c) on reduced annual fees for licensees that qualify as “small entities.” 

Direct all questions about the NRC’s fees or completion of Item 12 of NRC Form 313 to the 

Office of the Chief Financial Officer at NRC Headquarters in Rockville, MD, (301) 415-7554. 

Information about fees may also be obtained by calling NRC’s toll-free number, (800) 368-5642, 

extension 415-7554. The e-mail address is Fees.Resource@nrc.gov.

19 

8. CONTENTS OF AN APPLICATION 

The following information applies to the indicated items on NRC Form 313 (Appendix B). 

All items in the application should be completed in enough detail for the NRC to determine that if 

the proposed equipment, facilities, training and experience, and radiation safety program satisfy 

regulatory requirements and are adequate to protect public health and safety and minimize 

danger to life and property. Consideration must be given, when developing the application, to 

the concepts of keeping exposure as low as is reasonably achievable (ALARA), minimizing 

contamination, and maintaining control of radioactive materials. 

10 CFR 20.1101(b) states: “The licensee shall use, to the extent practical, procedures and 

engineering controls based upon sound radiation protection principles to achieve occupational 

doses and doses to members of the public that are as low as is reasonably achievable 

(ALARA).” Regulatory Guide 8.10, “Operating Philosophy for Maintaining Occupational 

Radiation Exposures as Low as Is Reasonably Achievable,” discusses the ALARA concept and 

philosophy. The application should document ALARA considerations, including establishing 

administrative action levels and monitoring programs. 

10 CFR 20.1406, “Minimization of Contamination,” requires applicants for licenses to describe 

how facility design and procedures for operation will minimize, to the extent practicable, 

contamination of the facility and the environment; facilitate eventual decommissioning; and 

minimize, to the extent practicable, the generation of radioactive waste. As with ALARA 

considerations, applicants should address these concerns for all aspects of their programs. 

10 CFR 20.1801, “Security of stored material,” states that licensees shall secure from 

unauthorized removal or access licensed materials that are stored in controlled or unrestricted 

areas. 

10 CFR 20.1802, “Control of material not in storage,” states that licensees shall control and 

maintain constant surveillance of licensed material that is in a controlled or unrestricted area 

and that is not in storage. 

Refer to Appendix R of this report for guidance regarding the definition of construction and the 

consideration of activities that can be performed by materials license applicants and potential 

applicants, and licensees before the NRC has concluded its environmental review of the 

proposed licensing action. The majority of materials licensing actions will meet the criteria in 10 

CFR 51.22(c)(14)(xi) for a categorical exclusion. This means that the licensing action will not 

require an environmental assessment or environmental impact statement in accordance with 10 

CFR 51.22(b), since the NRC has already determined that this type of licensing action does not 

have a significant impact on the environment. It is the applicant’s responsibility to review the 

guidance in Appendix R to determine whether the categorical exclusion applies to the licensing 

action. 

All information submitted to the NRC during the licensing process may be incorporated as part 

of the license and will be subject to review during inspection. 
20 

8.1 Item 1: License Action Type

Item 1 of NRC Form 313 states the following: 

This is an application for (check appropriate item): 

Type of Action License No.

[ ] A. New License Not Applicable 

[ ] B. Amendment XX-XXXXX-XX 

[ ] C. Renewal XX-XXXXX-XX 

Check Box A for a new license request. Note that a pre-licensing visit may be required before 

issuance of the license. Also, note that an initial security inspection may be conducted in 

accordance with NRC Inspection Manual Chapter 2800, “Materials Inspection Program,” before 

issuance of the license. 

Check Box B for an amendment to an existing license and provide the license number. 

Check Box C for a renewal of an existing license and provide the license number.

See “Amendments and Renewals to a License” in Chapter 9 of this report. 

8.2 Item 2: Name and Mailing Address of Applicant 

List the legal name of the applicant’s corporation or other legal entity with direct control over use 

of the radioactive material; a division or department within a legal entity may not be a licensee. 

An individual may be designated as the applicant only if the individual is acting in a private 

capacity and the use of the radioactive material is not connected with employment in a 

corporation or other legal entity. Provide the mailing address where correspondence should be 

sent. A post office box number is an acceptable mailing address. 

Notify the NRC of changes in mailing address; these changes do not require a fee.

Note: The NRC must be notified before control of the license is transferred (see Section 9.1, 

“Timely Notification of Transfer of Control”) or when bankruptcy proceedings have been initiated 

(see Section 8.2.1, “Notification of Bankruptcy Proceedings”). 

 

8.2.1 Notification of Bankruptcy Proceedings 

Regulation: 10 CFR 30.34(h) 

Criteria: Immediately following the filing of a voluntary or involuntary petition for bankruptcy for 

or against a licensee, the licensee must notify the appropriate NRC regional administrator in 

writing, identifying the bankruptcy court in which the petition was filed and the date of filing. 

Discussion: Even though a licensee may have filed for bankruptcy, the licensee remains 

responsible for all regulatory requirements. The NRC must be notified when licensees are in 

bankruptcy proceedings in order to determine whether all licensed material is accounted for and 

adequately controlled and whether there are any public health and safety concerns 
21 

(e.g., contaminated facility). The NRC shares the results of its determinations with other 

involved entities (e.g. trustee), so that health and safety issues can be resolved before 

bankruptcy actions are completed and may request that the United States Department of 

Justice (DOJ) represent the NRC’s interests in the bankruptcy proceeding. 

Response from Applicant: None is required at the time of application for a new license. 

Licensees must immediately notify the NRC in writing follow the filing of a voluntary or 

involuntary petition for bankruptcy by or against the licensee. 

Reference: See NUREG-1556, Volume 15, “Consolidated Guidance about Materials 

Licenses: Guidance about Changes of Control and about Bankruptcy Involving Byproduct, 

Source, or Special Nuclear Materials Licenses.” 

8.3 Item 3: Address(es) Where Licensed Material Will Be Used or Possessed 

Specify the street address, city, and State or other descriptive address (e.g., Highway 10, 

8 kilometers (5 miles) east of the intersection of Highway 10 and State Route 234, Anytown, 

State) for each facility at which licensed material will be used or stored. The descriptive address 

should be sufficient to allow an NRC inspector to find the facility location. A post office box 

address is not acceptable. In addition, applicants are encouraged to provide global positioning 

system coordinates, as appropriate. 

A license amendment is required before receiving, using, and storing licensed material at an 

address or location not included with the application or already listed on the license. 

To conduct operations at temporary job sites (i.e., locations where work is conducted for limited 

periods of time), specify “temporary job sites anywhere in the United States where the NRC 

maintains jurisdiction.” 

If an applicant submits documents that give the exact location of use and storage the applicant 

should mark these documents as “Security-Related Information—Withhold under 

10 CFR 2.390.” See Chapter 6, “Identifying and Protecting Sensitive Information,” for more 

details. 

Note: As discussed later in Section 8.5.3, “Financial Assurance and Recordkeeping for 

Decommissioning,” licensees must maintain permanent records describing where licensed 

material was used or stored while the license was in effect. This is important for making future 

determinations about the release of these locations for unrestricted use (e.g., before the license 

is terminated). Acceptable records are leak test records, sketches, and written descriptions of 

specific locations where licensed material was used or stored and any information relevant to 

damaged devices or leaking radioactive sources. 

An NRC license does not relieve a licensee from complying with other applicable Federal, 

State, or local regulations (e.g., local zoning requirements). 
22 

8.4 Item 4: Person to Be Contacted about This Application 

Identify the individual who can answer questions about the application and include a telephone 

number where the individual may be contacted. Also include business cell phone numbers and 

e-mail addresses. This individual, usually the RSO, will serve as the point of contact during the 

review of the application. If this individual is not a full-time employee of the licensed entity, his 

or her position and relationship to the licensee should be specified. The NRC should be notified 

if the person assigned to this function changes or if his or her telephone number, cell phone 

number, or e-mail address changes. Notification of a contact change is only in order to provide 

information and would not be considered an application for license amendment, unless the 

notification involves a change in the contact person who is also the RSO. 

As indicated on NRC Form 313 (see Appendix B), Items 5 through 11 should be submitted on 

separate sheets of paper. Applicants may use Appendix C for this purpose and should note 

that using the suggested wording of responses and committing to use the model procedures 

in this report will facilitate the NRC’s review. 

8.5 Item 5: Radioactive Material 

Regulations: 10 CFR 30.18, 10 CFR 30.32(g), 10 CFR 30.32(i), 10 CFR 30.33(a)(2), 

10 CFR 32.210, 10 CFR 39.13. 

Criteria: An application for a license will be approved if the requirements of 10 CFR 30.33, 

“General requirements for issuance of specific licenses,” and 10 CFR 39.13, “Specific licenses 

for well logging,” are met. In addition, licensees will be authorized to possess and use only 

those sealed sources and devices that are specifically approved or registered by the NRC or an 

Agreement State.

Discussion: The applicant should list each requested radionuclide by its element name and 

mass number (e.g., cesium-137), specify whether the material will be acquired and used in 

unsealed or sealed form, and list the maximum activity requested (include units 

millicuries/curies (mCi/Ci)). Table 8.1, “Types of Radioactive Materials,” below provides 

examples of the different types of radioactive materials. Some, not all, are addressed in this 

report.

Note: Additional safety equipment and precautions are required when handling and using 

unsealed free-form volatile radioactive materials. (Volatile means that a liquid becomes a gas at 

a relatively low temperature when the sealed container within which the liquid is stored is left 

open to the environment.) 
23 

Table 8.1 Types of Radioactive Materials 

Type of Material Covered by this 

Report

Examples

Byproduct material Yes H-3, C-14, Na-22, S-35, Sc-46, Ca-45, 

Fe-55, Co-57, Co-58, Co-60, Ni-63, 

Zn-65, Br-82, Sr-85, Sr-90, Ag-110m, 

I-125, Sb-124, I-131, Xe-133, Cs-137, 

La-140, Ir-192, Au-198, Am-241, 

discrete sources of Ra-226 

Source material Yes uranium, depleted uranium 

Special nuclear material Yes Pu-238:Be sealed source 

Naturally occurring 

radionuclides 

No Ra-226 (nondiscrete sources), Th-232, 

Th-natural 

Maximum activity should be specified in megabecquerels (MBq) [millicuries (mCi)] or 

gigabecquerels (GBq) [curies (Ci)] for each radionuclide. Applicants should include in the 

maximum activity requested, the total estimated inventory planned for use in NRC jurisdictions, 

including licensed material in storage and maintained as radioactive waste. The requested 

maximum activity for any radionuclide should be commensurate with the applicant’s needs and 

facilities for safe handling. Applicants, when establishing the maximum activity being requested 

for radioactive materials with half lives greater than 120 days, should review the requirements 

for submitting a certification for financial assurance for decommissioning. These requirements 

are discussed in Section 8.5.3, “Financial Assurance and Record Keeping for 

Decommissioning.” NUREG-1757, Volume 3, Revision 1, “Consolidated Decommissioning 

Guidance: Financial Assurance, Recordkeeping, and Timeliness” provides additional guidance 

on the requirements for financial assurance for decommissioning and the recordkeeping 

requirements related to decommissioning. 

Applicants requesting an authorization to use volatile radioactive material must provide 

appropriate facilities, handling equipment, and radiation safety procedures for using such 

material. 

If a dose evaluation indicates, because of a release of radioactive materials, that the potential 

dose to a person off-site would exceed 0.01 sieverts (Sv)[1 rem] effective dose equivalent or 

0.05 Sv [5 rems] to the thyroid, an emergency plan for responding to a release shall be included 

with the application (10 CFR 30.32(i)). For example: 370 GBq (10 curies) of iodine-131 is a 

quantity requiring an emergency plan. 

Consult with the proposed supplier, manufacturer, or distributor to ensure that requested 

sources and devices, where applicable, are compatible with and conform to the sealed source 

and device designations registered with the NRC or an Agreement State. Licensees may not 

make any changes to the sealed source, device, or source/device combination that would alter 

the description or specifications from those indicated in the respective registration certificates, 

before obtaining the NRC’s permission in a license amendment. To ensure that applicants use 

sources and devices according to the registration certificates, they may want to get a copy of 

the certificate and review it or discuss it with the manufacturer. 
24 

Response from Applicant: 

 For sealed materials: 

− Identify each radionuclide (element name and mass number) that will be used in 

each sealed source within the NRC’s jurisdiction. 

− Identify, for each source model, the maximum activity per source and total 

possession. 

− Provide the manufacturer’s (distributor’s) name and model number for each 

sealed source and, if applicable, device requested. 

− Confirm that the activity per source and maximum activity in each device will not 

exceed the maximum activity listed on the approved certificate of registration 

issued by the NRC or by an Agreement State. 

− Confirm that each sealed source, device, and source/device combination is 

registered as an approved sealed source or device by the NRC or an Agreement 

State. 

A safety evaluation of sealed sources and devices is performed by the NRC or an Agreement 

State before authorizing a manufacturer (or distributor) to distribute them to specific licensees. 

The safety evaluation is documented in a sealed source and device (SSD) registration 

certificate. SSD registration certificates may be obtained through the device manufacturer or 

vendor. Applicants must provide the manufacturer’s name and model number for each 

requested SSD (e.g., instrument calibrator) so that the NRC can verify that each, when 

applicable, has been evaluated in an SSD registration certificate. 

 For unsealed tracer materials, including both volatile and nonvolatile materials (e.g., 

iodine-131, iodine-125, hydrogen-3): 

− Provide element name with mass number, chemical and/or physical form, and 

maximum requested possession limit. 

− Provide information for volatile materials, if known, on the anticipated rate of 

volatility or dispersion. This information may be obtained from the tracer material 

vendor, supplier, or manufacturer. 

After the NRC license is issued, the licensee needs to create an account in the National 

Source Tracking System (NSTS) to track, from cradle to grave, sealed sources with activities 

exceeding the activities listed in Appendix E of 10 CFR Part 20, “Nationally Tracked Source 

Thresholds.” The receipt, transfer, and disposal transactions of NSTS sources must be 

reported in accordance with 10 CFR 20.2207, “Reports of Transactions Involving Nationally 

Tracked Sources.” 
25 

8.5.1 Sealed Sources and Devices 

Regulation: 10 CFR 30.32(g), 10 CFR 39.41, 10 CFR 39.53. 

Criteria: Any sealed source used for well logging that contains more than 3.7 MBq 

(100 microcuries) of byproduct or special nuclear material and is used downhole in well bores of 

gas wells, oil wells, or in mineral deposits, must satisfy the requirements of 10 CFR 39.41, 

“Design and performance criteria for sources.” 

Sealed sources used for well logging should have an SSD registration certificate designating the 

use of the sealed source for “well logging.” 

Discussion: The NRC or an Agreement State performs a safety evaluation of sealed sources 

before authorizing a manufacturer or distributor to distribute sources to specific licensees. The 

safety evaluation is documented in an SSD registration certificate. 

Applicants must provide the manufacturer’s name and model number for each requested sealed 

source. This information is necessary to ensure that each sealed source requested in the 

application is evaluated and approved by the NRC or an Agreement State, included in an SSD 

registration certificate, approved under the provisions granted by the NRC in 10 CFR 39.41, or 

is identified on an NRC or Agreement State license and authorized for well logging. Applicants 

should consult with the proposed suppliers or vendors to ensure that sealed sources, and if 

applicable, devices, conform to information contained in SSD registration certificates. 

Licensees should ensure that their uses of sealed sources, and, if applicable, associated 

equipment, are in accordance with registration certificates. Applicants may elect to obtain 

copies of applicable SSD registration certificates for future reference. 

For sealed sources used for well logging applications, NRC licenses only authorize possession 

of individual sealed sources approved for well logging. To allow flexibility, licenses do not 

authorize specific sealed source/well logging tool combinations. Applicants should consult with 

the manufacturer of the sealed sources before using associated equipment (e.g., well logging 

tools, transport containers, handling tools). Conferring with the vendor or manufacturer before 

use helps ensure that the associated equipment selected is compatible with sealed sources 

requested in the application. 

Applicants must provide the manufacturer’s name and model number for each requested energy 

compensation source. Energy compensation sources are small sealed sources, with an activity 

not exceeding 3.7 MBq (100 microcuries), used within a logging tool to provide a reference 

standard to maintain the tool’s calibration when in use. These sources are not required to meet 

the design and performance criteria in 10 CFR 39.41. 

Response from Applicant: 

 Complete the table in Appendix C to support the request for byproduct, source, or 

special nuclear material used in well logging operations and radioactive materials used 

for purposes other than well logging, e.g., radiation survey instrument calibrators. 

OR
26 

 On a separate page, include the following information to support the request for each 

sealed source: 

 Identify each sealed source or energy compensation source by the manufacturer’s 

name, model number, radionuclide (element name and mass number), maximum activity 

per source, and total activity requested. 

 Confirm that the activity per source and maximum activity in each device will not exceed 

the maximum activity listed on the approved certificate of registration issued by the NRC 

or by an Agreement State. 

 Identify any sealed sources or corresponding devices not used in well logging that 

contain byproduct, special nuclear, or source material and specify the manufacturer’s 

name, model number, and radionuclide (element name and mass number). Examples of 

such devices are calibration devices used for survey instruments and pocket dosimeters, 

and sources used above ground for calibrating well logging tools. 

 Identify the manufacturer’s name and model number of depleted uranium sinker bars. 

 Confirm that each sealed source is registered as an approved sealed source by the NRC 

or an Agreement State and will be possessed and used in accordance with the 

conditions specified in the registration certificate. 

Note: An applicant should contact the device or source manufacturer or vendor for information 

on SSD registration certificates.

 

8.5.2 Unsealed (Tracer) Radioactive Material 

Regulation: 10 CFR 30.32(i), 10 CFR 30.33, 10 CFR 30.72, 10 CFR 39.2, 10 CFR 39.13.

Criteria: An application for a license will be approved if the requirements of 10 CFR 30.33, 

“General requirements for issuance of specific licenses,” and 10 CFR 39.13, “Specific licenses 

for well logging,” are satisfied. 

Discussion: Each authorized radionuclide tracer is listed on the NRC license by its element 

name, chemical and/or physical form, maximum amount authorized (possession limit), and the 

maximum amount of each radionuclide (identified by physical or chemical form) used in each 

type of tracer study requested. The following definitions are provided to clarify single and 

multiple well tracer operations addressed in this report: 

 Tracer Materials: Radionuclides in liquid, solid, or gas form that are injected into single 

well bores or underground reservoirs to monitor the movement of fluids or gases. Tracer 

studies involve a single well and require the use of an electronic well logging tool to 

detect the radionuclides injected into the well.

 Field Flood Studies or Enhanced Oil and Gas Recovery Studies: Tracer studies 

involving multiple wells where one or more radionuclides are injected and multiple oil or 

gas samples containing radioactive material are collected from each of the wells to 

determine the direction and rate of flow through the formation. Field flood tracer 
27 

operations would not normally involve the use of an electronic well logging tool to detect 

the radionuclides in the well.

 Labeled Frac Sands: Radionuclide(s) in liquid or solid forms that is (are) chemically 

bonded to glass or resin beads and injected into a single well in a density-controlled 

solution. Frac sand operations require the use of an electronic well logging tool to 

assess the amount of radionuclide(s) remaining in the underground reservoir formation.

Table 8.2 Types of Radioactive Materials Used in Field Flood Studies and Single Well 

 Tracer Operations 

Field Flood Or Enhanced Oil And Gas Recovery Study Applications Tracers 

Used In Multiple Wells 

Gas H-3, Kr-85, C-14, I-131, Br-82 

Liquid H-3, C-14, Na-22, S-35, Ca-45, Co-60, Ni63, Zn-65, Sr-85, Sc-46, Sr-90, Ag-110m, 

I-125, I-131, La-140, Ir-192 

Well Logging Tracer Applications Tracers Used In A Single Well

Gas Br-82, I-131, I-125 

Liquid Fe-59, I-125, I-131, Sb-124, Au-198, 

Ag-110m 

Labeled Frac Sand Sc-46, Br-82, Ag-110m, Sb-124, Ir-192 

Response from Applicant: 

 For unsealed nonvolatile and volatile (e.g., iodine-125, iodine-131, hydrogen-3, 

bromine-82) tracer materials: 

– Provide the element name and mass number. 

– Identify each chemical and/or physical form (e.g., liquid, gas, or labeled frac 

sands) requested for each type of tracer study. 

– Specify the maximum amount of each radionuclide tracer that you will use in 

each type of tracer study by its physical or chemical form. Identifying the forms 

as “any” is unacceptable. 

– Specify the maximum amount of each radionuclide tracer material that will be 

possessed at any one time. Possession limits should also include any materials 

that may be stored as waste. 

 Specify the purpose for which each radionuclide will be used.
28 

 Provide an Emergency Plan (if required) 

− Emergency plans are not routinely required for tracer materials with half-lives of 

less than 120 days and for quantities authorized in well logging and tracer 

licenses. 

Applicants should refer to 10 CFR 30.32(i) and 30.72, Schedule C, “Quantities of 

radioactive materials requiring consideration of the need for an emergency plan for 

responding to a release,” to determine the quantities of radioactive material requiring an 

emergency plan for responding to a release of radioactive materials. In addition 30.32(i) 

provides the information required to develop an Emergency Plan. 

8.5.3 Financial Assurance and Record Keeping for Decommissioning 

Regulations: 10 CFR 30.34(b), 10 CFR 30.35, 10 CFR 70.25 

Criteria: Well logging licensees authorized to possess sealed sources and/or unsealed 

byproduct material with a half-life greater than 120 days and in excess of the limits specified in 

10 CFR 30.35, “Financial assurance and recordkeeping for decommissioning,” must provide 

evidence of financial assurance for decommissioning. 

Well logging licensees authorized to possess sealed sources containing special nuclear material 

with a half-life greater than 120 days and in excess of the limits specified in 10 CFR 70.25, 

“Financial assurance and recordkeeping for decommissioning,” must provide evidence of 

financial assurance for decommissioning. 

In addition, each decommissioning funding plan must contain a cost estimate for 

decommissioning and a means for adjusting the decommissioning cost estimate periodically 

over the life of the facility. Cost estimates must be adjusted at intervals not to exceed 3 years in 

accordance with 10 CFR 30.35(e) and 10 CFR 70.25(e). 

Each licensee is obligated to maintain, in an identified location, decommissioning records 

related to facilities where licensed material is used, stored, or dispatched, regardless of the 

material half-life. Decommissioning records described above are not required at temporary 

jobsites. Under 10 CFR 30.35(g) and/or 10 CFR 70.25(d) when terminating the license, 

licensees must transfer records important to decommissioning to either of the following: 

 the new licensee before licensed activities are transferred or assigned according to 

10 CFR 30.34(b) 

 the appropriate NRC regional office before the license is terminated 

Discussion: The NRC’s primary objective is to ensure that decommissioning will be carried out 

with minimum impact on the health and safety of the public, occupationally exposed individuals, 

and the environment. NRC regulations, when applicable, require the applicant to provide 

Certification of Financial Assurance (F/A) or a Decommissioning Funding Plan (DFP). This is to 

provide reasonable assurance that, after the technical and environmental components of 

decommissioning are carried out, unrestricted use of the facilities is possible at the termination 

of licensed activities. These regulatory requirements specify that a licensee either set aside 

funds for decommissioning activities or provide a guarantee through a third party that funds will 
29 

be available. Methods of certification of financial assurance for decommissioning may include 

the following: 

 security bond 

 trust agreement 

 statement of intent 

 certificate of deposit 

 parent company guaranty 

Before a license is issued, applicants are required to submit the Certification of Financial 

Assurance or a DFP when requesting authorization to possess any sealed or unsealed 

radioactive material with a half-life greater than 120 days and exceeding the limits in 

10 CFR 30.35 and/or 10 CFR 70.25. Criteria for determining whether an applicant must submit 

a DFP or has an option of submitting either a DFP or F/A are described in 10 CFR 30.35 and/or 

10 CFR 70.25(d). 

There are two parts to this rule: financial assurance that applies to some licensees and 

record keeping that applies to all licensees. 

Licensing guidance for demonstrating compliance with financial assurance, recordkeeping, and 

timeliness criteria is described in NUREG-1757, Volume 3, Revision 1, “Consolidated 

Decommissioning Guidance: Financial Assurance, Recordkeeping, and Timeliness.” 

The applicant should refer to this document and provide the requested information if financial 

assurance is required based on the proposed maximum possession limits that will be listed in 

the license. 

Table 8.3 provides a partial list of sealed and unsealed radionuclides with a half-life greater than 

120 days with the corresponding limits in excess of which an F/A or a DFP is required. 

However, it is the NRC’s experience that most well logging, tracer, and field flood study 

licensees use only a few of these radionuclides. The most frequently used radionuclides with a 

half-life greater than 120 days that require financial assurance in unsealed form are hydrogen-3, 

carbon-14, and silver-110 metastable, and for sealed sources, americium-241. Radionuclides 

with a half-life greater than 120 days are listed in Column 1. Column 2 lists the corresponding 

possession limits of radionuclides requiring F/A. Column 3 lists the corresponding possession 

limits of unsealed radionuclides requiring the submittal of a DFP. These limits apply when only 

one of these radionuclides is possessed. 

Applicants can use the data from Table 8.3, to determine if F/A is required and the amount that 

is required when more than one of these radionuclides is requested. 

The following unsealed radionuclides with a half-life less than or equal to 120 days used in well 

logging, tracer, and field flood studies, need not be considered for financial assurance purposes. 

Examples of these radionuclides include: iodine-131, scandium-46, bromine-82, zirconium-95, 

antimony-124, iridium-192, and gold-198.
30 

Table 8.3 Commonly Used Licensed Materials Requiring Financial 

 Assurance/Decommissioning Funding Plan 

Column 1: Radionuclide Column 2: Limit for F/A 

(millicuries*)

Column 3: Limit for DFP 

(millicuries*)

Unsealed Materials 

H-3 1,000 100,000 

C-14 100 10,000 

Ag-110m 1 100 

Sealed Materials 

Am-241 100,000 10,000,000 

Pu-239 100,000 10,000,000 

Cf-252 100,000 10,000,000 

Ra-226 100,000 10,000,000 

Cs-137 100,000,000 10,000,000,000 

*1 millicurie = 37 MBq 

NUREG-1757, Volume 3, contains approved wording for each mechanism authorized by the 

regulation to guarantee or secure funds. The requirements for maintaining records important to 

decommissioning, including the type of information required, are stated in 10 CFR 30.35(g) 

and/or 10 CFR 70.25(g). All licensees are required to maintain these records in an identified 

location until the site is released for unrestricted use (see Figure 8.14). In the event that the 

licensed activities are transferred to another person or entity, these records shall be transferred 

to the new licensee before transferring the licensed activities. The new licensee is responsible 

for maintaining these records until the license is terminated. When the license is terminated, 

these records shall be transferred to the NRC. 
31 

1556-005.ppt

041300

Structural

Modifications As-built

Drawings

Surveys

Reference:

Blueprints stored

at Location XYZ

Spills

Deco

R

m

e

missioning

cords

1556-005.ppt

041300

Structural

Modifications As-built

Drawings

As-built

Drawings

Surveys

Reference:

Blueprints stored

at Location XYZ

SpillsSpills

Deco

R

m

e

missioning

cords

Figure 8.1 Types of records that must be maintained for decommissioning. 

Regulations in 10 CFR 30.35(g) and 10 CFR 70.25(g) require that records important to 

decommissioning are: 

 transferred to the new licensee before licensed activities are transferred or assigned 

according to 10 CFR 30.34(b) 

OR 

 transferred to the appropriate NRC Regional office before the license is terminated 

Response from Applicants: 

• Under 10 CFR 30.35(g) and/or 10 CFR 70.25(g), we shall maintain drawings and 

records important to decommissioning and transfer these records to a new licensee 

before licensed activities are transferred, or assign the records to the appropriate NRC 

regional office before the license is terminated.

 AND 

 If F/A or a DFP is required, submit the required documents described in NUREG-1757, 

Volume 3.
32 

Note: Licensees must maintain permanent records on locations where licensed materials are 

used or stored while the license is in force. These permanent records are important for making 

future determinations about the release of these locations for unrestricted use (e.g., before the 

license is terminated). Acceptable permanent records include sketches, written descriptions of 

specific locations where radioactive material is used or stored, and records of any leaking 

sealed sources, tracer material spills, contaminated waste storage areas, or other unusual 

occurrences involving the spread of contamination in or around the licensee’s facilities or field 

stations. Permanent decommissioning records described above are not required for temporary 

job site locations. 

8.6 Item 6: Purpose(s) for Which Licensed Material Will be Used 

Regulations: 10 CFR 30.33(a)(1), 10 CFR 39.41, 10 CFR 39.45, 10 CFR 39.47, 

10 CFR 39.49, 10 CFR 39.51, 10 CFR 39.63, 10 CFR 51.21, 10 CFR 51.22. 

Criteria: Radionuclides and sealed sources requested in the application must be used for 

purposes authorized by the Atomic Energy Act of 1954, as amended. The licensee must 

specify the purpose for which each radionuclide or sealed source listed in Item 5 is to be used, 

as well as specifying the type of wells in which each type of material will be used (e.g., oil, gas, 

mineral, geophysical). In addition, the licensee should describe the type of mineral or 

geophysical logging to be conducted (e.g., coal, salt domes). Sealed sources used in well 

logging devices should be used only for the purposes for which they were designed, in 

accordance with the manufacturer’s written recommendations and instructions, as specified in 

an approved SSD registration certificate, and as authorized on an NRC or Agreement State 

license. The licensee shall specify the manufacturer and model number of each device.

Discussion: The applicant’s request to use sealed sources and radionuclides in well logging, 

tracer, and field flood studies should clearly specify the purpose for which each type of material 

will be used. Applicants should include a description that is sufficiently detailed to allow the 

NRC to determine the potential for exposure to occupationally exposed individuals or members 

of the public. 

Note: Traditionally, only Federal or State authorities have been authorized to conduct logging 

in potable water wells in freshwater aquifers. Approval to conduct these operations requires 

that applicants justify the need and to provide assurance that sealed sources, in case of 

accidental loss in a potable water zone, could be recovered.

Applicants requesting authorization to perform any of the hazardous operations listed below 

should clearly indicate their intent and provide specific instructions for conducting such activities 

in their operating and emergency procedures: 

 Removing a sealed source from a source holder of a logging tool and maintenance on 

sealed sources or holders 

 Using destructive techniques to remove a stuck sealed source from a source holder 

 Opening, repairing, or modifying any sealed source 

 Knowingly injecting licensed radioactive tracer material into a fresh water aquifer 

 Using a sealed source in a well without a surface casing to protect fresh water aquifers. 
33 

Applicants may use the format given in Table 8.4 or Appendix C to provide the requested 

information. 

Table 8.4 Sample Format for Providing Information about Requested Radionuclides 

Radionuclide Chemical/Physical 

Form

Maximum Possession 

Limit

Proposed Use

Americium-241 Sealed neutron source 

(XYZ Inc., Model 10) 

Provide the maximum 

activity per individual 

source, and total 

possession limit for 

each source model. 

Oil, gas, and 

mineral logging. 

Cesium-137 Sealed source 

(Okko Inc., Model 36) 

Provide the maximum 

activity per individual 

source, and total 

possession limit for 

each source model 

Oil, gas, and 

mineral logging. 

Hydrogen-3 Gas, titanium tritide 

neutron generator tube 

(Cols Inc., Model 3) 

Provide the maximum 

activity per individual 

tube, and total 

possession limit for 

each tube model. 

Neutron activation 

logging in oil and 

gas wells in 

downhole 

accelerator 

Iodine-131 Gas Include the maximum 

activity per injection 

and the total activity to 

be possessed. 1

Subsurface tracer 

operations 

Iodine-131 Liquid Include the maximum 

activity per injection 

and the total activity to 

be possessed. 1

Subsurface tracer 

operations 

Iridium-192 “Labeled” frac sand Include the maximum 

activity per injection 

and the total activity to 

be possessed. 1

Subsurface tracer 

operations 

Cobalt-60 Metal wire Include the maximum 

activity per individual 

unit and the total 

activity to be 

possessed. 

Pipe joint collar 

markers, 

subsidence 

markers,dDepth 

determination 
34 

Radionuclide Chemical/Physical 

Form

Maximum Possession 

Limit

Proposed Use

Silver-110m Liquid Include the maximum 

activity per injection 

and the total activity to 

be possessed.*

Field flood tracer 

studies 

Depleted Uranium Sinker Bars 225 kilograms Sinker weights 

(concentrated 

mass) 

*

When providing the information above, the maximum amounts of radioactive material possessed as unsealed 

radioactive material should include the radioactive materials to be used for the licensed purpose as well as any 

material possessed as waste or for decay-in-storage. 

Applicants should note that authorization granted by the NRC to use licensed material in tracer 

or field flood studies does not relieve them of their responsibilities to comply with any other 

applicable Federal, State or local regulatory requirements. 

Response from Applicant: List in Appendix C the specific use or purpose of each sealed 

source and radionuclide requested in the application. 

8.7 Item 7: Individual(s) Responsible for the Radiation Safety Program and Their 

Training and Experience 

8.7.1 Radiation Safety Officer (RSO) 

Regulations: 10 CFR 30.33(a)(3) 

Criteria: Though there are no specific training requirements, RSOs must have adequate 

training and experience to implement the radiation safety program. In the past, the NRC has 

found successful completion of one of the following to be evidence of adequate training and 

experience:

 well logging course for users and RSOs, with hands-on experience with equipment and 

sources 

 equivalent course that meets the logging supervisor criteria specified in Appendix G of 

this document 

Discussion: The person responsible for the radiation protection program is identified on the 

license as the RSO. The NRC believes the RSO is the key to overseeing and ensuring safe 

operation of the licensee’s well logging, tracer, or field flood study program. The RSO must 

have adequate training to understand the hazards associated with radioactive material and be 

familiar with all applicable regulatory requirements. The RSO needs independent authority to 

stop operations that he or she considers unsafe. He or she must have sufficient time and 

commitment from management to fulfill certain duties and responsibilities to ensure that 

radioactive materials are used in a safe manner, approved radiation safety procedures are 

being implemented, and the required records of licensed activities are maintained. 
35 

The RSO may delegate certain day-to-day tasks of the radiation protection program to other 

responsible individuals without delegating his or her responsibilities of the radiation safety 

program. For example, a large well logging firm with multiple field stations or temporary job 

sites may appoint individuals designated as “site RSOs” who assist the RSO and are 

responsible for the day-to-day activities at the field stations or temporary job sites. The RSO is 

typically listed as the point of contact for NRC/Licensee communications in Item 4 of the NRC 

Form 313 (see Section 8.4). 

Typical RSO duties are illustrated in Figure 8.2. The NRC requires the name of the RSO on the 

license to ensure that licensee management has always identified a responsible, qualified 

person and that the named individual knows of his or her designation as RSO. The NRC will 

request a copy of an organizational chart showing the RSO (and other designated responsible 

individuals) to demonstrate that he or she has sufficient independence and direct 

communication with responsible management officials. Also, show in the organizational chart 

the position of the individual who signs the application in Item 13 of the NRC Form 313. Note: 

This individual should be an officer of the company that can make legal and financial 

commitments for the company.
36 

Figure 8.2 RSO responsibilities—Typical duties and responsibilities of the RSO 

To be considered eligible for the RSO position, the applicant must submit for NRC review the 

specific training and experience of the proposed RSO and detail his or her duties and 

responsibilities. The proposed RSO should have had a minimum of 1 year of actual experience 

as a logging supervisor. The RSO is expected to coordinate the safe use of licensed materials 

and to ensure compliance with the applicable requirements of the CFR (e.g., Parts 19, 20, 21, 

30, 39). The RSO should possess a thorough knowledge of management policies, company 

administrative and operating procedures, and safety procedures related to protection against 

radiation exposures. 

Receipt, transfer, disposal

Transportation

Audits

Personnel Monitoring

Stop unsafe licensed activities

Proper use and maintenance of

approved sources and devices

Personnel training

Monitor emergency events

Device security

Material disposal

Device security

Interaction with NRC, other authorities

Records maintenance

Six-month worker audits

Survey meter calibration and

maintenance
37 

Response from Applicant: Provide the following: 

 Provide the name of the proposed RSO who will be responsible for ensuring that the 

licensee’s radiation safety program is implemented in accordance with approved 

procedures. 

AND 

 Demonstrate that the RSO has sufficient independence and direct communication with 

responsible management officials by providing a copy of an organization chart with 

positions demonstrating day-to-day oversight of the radiation safety activities 

AND EITHER 

 Provide documentation demonstrating that the proposed RSO is qualified by training and 

experience (i.e., certificate of completion of a well logging RSO or authorized user’s 

course) 

OR 

 Provide alternative information demonstrating that the proposed RSO is qualified by 

training and experience (e.g., Board Certification by the American Board of Health 

Physicists; completion of a bachelor’s or master’s degree in the sciences with at least 

one year of experience in the conduct of a radiation safety program of comparable size 

and scope; or formal training in the establishment and maintenance of a radiation 

protection program) 

OR 

 Provide alternative information demonstrating that the proposed RSO is qualified by 

training and experience, e.g., listed by name as an authorized user or the RSO on an 

NRC or Agreement State license that requires a radiation safety program of comparable 

size and scope. 

Note: It is important to notify the NRC and obtain a license amendment prior to making 

changes in the designation of the RSO responsible for the radiation safety program. 

8.8 Item 8: Training for Logging Supervisors and Logging Assistants 

Regulations: 10 CFR 19.11, 10 CFR 19.12, 10 CFR 19.13, 10 CFR 30.7, 10 CFR 30.9, 

10 CFR 30.10, 10 CFR 30.33, 10 CFR 39.2, 10 CFR 39.13, 10 CFR 39.61. 

Criteria: Well logging supervisors and well logging assistants must have adequate training and 

experience as outlined in 10 CFR 19.12, “Instruction to workers,” 10 CFR 30.33(a)(3), and 

10 CFR 39.61, “Training.” Although persons engaged in field flood studies operations are not 

specifically addressed in 10 CFR Part 39, “Licenses and Radiation Safety Requirements for 

Well Logging,” NRC staff has historically accepted classroom training for tracer studies to be an 

appropriate guide for individuals engaged in field flood studies.
38 

Discussion: 

 Logging supervisor means an individual who uses licensed material or provides personal 

supervision in the use of licensed material at a temporary jobsite and who is responsible to 

the licensee for assuring compliance with the requirements of the Commission's regulations 

and the conditions of the license. 

 Logging assistant means any individual who, under the personal supervision of a logging 

supervisor, handles sealed sources or tracers that are not in logging tools or shipping 

containers or who performs surveys required by § 39.67. 

Formal training and testing requirements, performance requirements, annual refresher training, 

and annual audit requirements for logging supervisors and logging assistants are outlined in 

10 CFR 39.61. 

Refer to Appendix G of this NUREG as an aid in determining the specific training requirements 

for logging supervisors, logging assistants, and individuals authorized to conduct field flood 

study/tracer applications. The applicant must submit a description of its training program for 

logging supervisors, logging assistants, and individuals authorized to conduct field flood study 

applications. 

Because 10 CFR Part 39 contains different requirements for logging supervisors and logging 

assistants, applicants must include training programs for each category. When describing the 

training programs for these positions, include the sequence of events from the time of hiring 

through the designation of individuals as logging supervisors or logging assistants. Experienced 

logging supervisors who have worked for another well logging, tracer, or field flood study 

licensee should receive formal instruction similar to that given to prospective logging assistants. 

Instructors who provide classroom training to individuals in the principles of radiation and 

radiation safety should have knowledge and understanding of these principles beyond those 

obtainable in a course similar to the one given to prospective logging supervisors. Individuals 

who provide instruction in the hands-on use of well logging and handling equipment should be 

qualified logging supervisors with at least 1 year of experience in performing well logging 

operations, or should possess a thorough understanding of the operation of well logging and 

handling equipment (e.g., a manufacturer’s service representative). 

A safety review (audit) of the job performance of each logging supervisor and logging assistant 

ensures that the Commission’s regulations, license requirements, and the licensee’s operating 

and emergency procedures are followed. The audit must include observation of the 

performance of each logging supervisor annually (10 CFR 39.13(d)). The audit may include 

observation of each logging assistant as part of the annual safety review (10 CFR 39.13, 

“Specific licenses for well logging”). Audits should be conducted during an actual well logging 

operation. If a logging supervisor or logging assistant has not participated in a well logging 

operation for more than 12 months since the last safety review., an audit should be conducted 

the first time the individual engages in well logging operations. 
39 

Response from Applicant: 

 Submit the training program to be given to new logging supervisors and logging 

assistants. 

 

 Provide a copy of a typical examination and the correct answers to the examination 

questions. Indicate the passing grade. 

 Specify the qualifications of your instructors in radiation safety principles and describe 

their experience with well logging activities. If training will be conducted by someone 

outside the applicant’s organization, identify the course by title, provide the name, 

address, and telephone number of the company providing the training, and provide a 

course outline (if available). 

 Describe the field (practical) examination that will be given to prospective logging 

supervisors and logging assistants. The NRC suggests using the checklist in 

Appendix H as a source of potential areas to review during the field examination. 

 Describe the annual refresher training program, including topics to be covered and how 

the training will be conducted. 

 Submit a description of your program for annual safety reviews of the job performance 

of each well logging supervisor as described in 10 CFR 39.13(d).

8.9 Item 9: Facilities and Equipment 

Regulations: 10 CFR 20.1406, 10 CFR 20.1101(b), 10 CFR 20.1703, 10 CFR 30.33(a)(2), 

10 CFR 30.35(g), 10 CFR 39.31(b)(1), 10 CFR 39.45(a), 10 CFR 39.71, 10 CFR 40.32(c), 

10 CFR 70.23(a)(3).

Criteria: Facilities and equipment must be adequate to protect health, minimize danger to life 

or property, minimize the possibility of contamination, and keep exposure to occupationally 

exposed workers and the public ALARA. 

Discussion: Applicants must demonstrate that proposed facilities and equipment provide 

adequate storage capabilities, ensure that appropriate shielding is available to protect the health 

and safety of the public and employees, keep exposures to radiation and radioactive materials 

ALARA, and minimize the possibility of contamination from the uses, types, and quantities of 

radioactive materials requested. 

According to 10 CFR 20.1801, “Security of stored material,” and 10 CFR 20.1802, “Control of 

material not in storage,” licensed materials located in an unrestricted area and not in storage 

must be under the constant surveillance and control of the licensee. Areas where material is 

used or stored, including below ground bunker storage areas, should be (1) accessible only by 

authorized persons; and (2) secured or locked when an authorized person is not physically 

present. Use or storage areas cannot be considered restricted areas for purposes of radiation 

safety if accessible by unauthorized persons. 

In addition to the 10 CFR 20.1801 and 1802 requirements above, areas where radioactive 

material greater than category 1 and 2 quantities is possessed requires implementation of 
40 

10 CFR Part 37, “Physical Protection of Category 1 and Category 2 Quantities of Radioactive 

Material.” Appendix A to 10 CFR Part 37, “Category 1 and Category 2 Radioactive Materials,” 

provides a table of category 1 and 2 quantities of radioactive materials of concern. Part 37 

requires that where category 1 or 2 quantities of radioactive materials are used or stored, the 

licensee should: (1) ensure the radioactive materials are accessible only by individuals who 

have been deemed trustworthy and reliable, and who have been granted unescorted access; (2) 

have a security program to monitor and, without delay, detect, assess, and respond to any 

actual or attempted unauthorized access to radioactive material; (3coordinate, to the extent 

practicable, with the LLEA for responding to threats; (4) for portable and mobile devices, have 

two independent physical controls that form tangible barriers to secure the material from 

unauthorized removal when the device is not under direct control and constant surveillance by 

the licensee; and (5) provide for physical protection and tracking of radioactive materials in 

transit. 

Applicants may delay completing facilities and acquiring equipment until after the application 

review is completed. Delaying the completion of facilities or the acquisition of equipment will 

allow for changes, if any, needed as a result of the application review. This delay will also 

ensure the adequacy of proposed facilities and equipment before the applicant makes a 

significant financial commitment. In all cases, the applicant cannot possess or use licensed 

material until after the facilities are approved, equipment is procured, a pre-licensing site visit 

has occurred by the NRC, and the license is issued. 

Diagrams, drawings or sketches that provide exact locations of materials or depict specific 

locations of safety or security equipment should be marked as “Security-Related 

Information - Withhold Under 10 CFR 2.390.” 

Response from Applicant: 

 Submit a diagram, drawing, or sketch of the proposed facility, identifying areas where 

radioactive materials, including radioactive wastes, will be used or stored. Diagrams, 

drawings, or sketches should include indication of the scale, or include dimensions on 

each drawing or sketch and be marked: “Security-Related Information – Withhold Under 

10 CFR 2.390” as appropriate. 

 Drawings should show, where applicable, adjacent buildings, boundary lines, security 

fences, and lockable storage areas. 

 Illustrate area(s) where explosive, flammable, or other hazardous materials may be 

stored. 

 Drawings should also show the relationship and distance between restricted areas and 

adjacent unrestricted areas.

10 CFR 20.2003, “Disposal by release into sanitary sewerage,” authorizes the disposal of 

readily soluble radioactive materials via the sanitary sewage. Sanitary sewage does not 

include sewage treatment facilities, septic tanks, and leach fields owned or operated by a 

licensee. If you have any of these systems, please describe the controls used to prevent 

disposal in the prohibited systems. 
41 

 Drawings should specify shielding materials (concrete, lead, etc.) and means for 

securing radioactive materials from unauthorized removal. 

 Submit a drawing or sketch of the proposed tracer material storage facilities, including 

rooms, buildings, below ground bunker storage areas, or containers used for storage of 

both tracer and tracer waste materials, if appropriate. Specify the types and amount of 

shielding materials (concrete, lead, etc.) and means for securing tracer materials from 

unauthorized removal. 

 Describe protective clothing (such as rubber gloves, coveralls, respirators, and face 

shields), auxiliary shielding, absorbent materials, injection equipment, secondary 

containers for waste water storage for decontamination purposes, plastic bags for 

storing contaminated items, etc., that will be available at well sites when using tracer 

materials. 

 Describe proposed laundry facilities, if applicable, used for contaminated protective 

clothing. Specify how the contaminated waste water from the laundry machines or sinks 

is disposed. Operating and emergency procedures should address decontamination of 

the laundry area and equipment. 

 Describe proposed decontamination facilities for trucks, tracer injection tools, or other 

equipment contaminated by tracer materials, if applicable. Specify how the 

contaminated waste water for these decontamination facilities is disposed. Operating 

and emergency procedures should address decontamination of these types of 

equipment and facilities. 

 Submit a diagram, drawing or sketch of the proposed facility identifying areas where 

radioactive materials, including radioactive wastes, will be used or stored. Mark 

diagram, drawing, or sketch: “Security-Related Information – Withhold Under 10 CFR 

2.390” as appropriate. 

 Show in drawings, where applicable, adjacent buildings, boundary lines, security 

fences, and lockable storage areas. 

 Illustrate area(s) where explosive, flammable, or other hazardous materials may be 

stored. 

 Show in the drawings the relationship and distance between restricted areas and 

adjacent unrestricted areas. 

 Specify in the drawings shielding materials (concrete, lead, etc.) and means for 

securing radioactive materials from unauthorized removal. 

 Draw to an indicated scale, or include dimensions on each drawing or sketch. 

 Submit a drawing or sketch of the proposed tracer material storage facilities including 

rooms, buildings, below ground bunker storage areas, or containers used for storage of 

both tracer and tracer waste materials, if appropriate. Specify the types and amount of 

shielding materials (concrete, lead, etc.) and means for securing tracer materials from 

unauthorized removal.
42 

 Describe protective clothing (such as rubber gloves, coveralls, respirators, and face 

shields), auxiliary shielding, absorbent materials, injection equipment, secondary 

containers for waste water storage for decontamination purposes, plastic bags for 

storing contaminated items, etc., that will be available at well sites when using tracer 

materials. 

 Describe proposed laundry facilities, if applicable, used for contaminated protective 

clothing, and specify how the contaminated waste water from the laundry machines or 

sinks is disposed. Operating and emergency procedures should address 

decontamination of the laundry area and equipment. 

 Describe proposed decontamination facilities for trucks, tracer injection tools, or other 

equipment contaminated by tracer materials, if applicable. Specify how the 

contaminated waste water for these decontamination facilities is disposed. Operating 

and emergency procedures should address decontamination of these types of 

equipment and facilities. 

 Describe, if applicable, equipment for “repackaging” gaseous, volatile, or finely divided 

tracer material. Most tracer users do not repackage materials and acquire their 

injections in precalibrated amounts or “ready to use” forms. However, should an 

applicant request the ability to repackage tracer, volatile, or finely divided material, 

consider the following equipment when repackaging tracer materials: sinks, trays with 

absorbent material, glove boxes, fume hoods with charcoal filtration, filtered exhaust, 

special handling equipment including special tools, rubber gloves, etc. For license 

applications with multiple use locations, please state the physical location(s) where NRC 

regulatory required records will be stored and available for review during NRC 

inspections. 

 If applicable, the applicant will have in place a security program in accordance with 

10 CFR Part 37 prior to possessing category 1 or category 2 quantities of radioactive 

materials. 

 State the physical location where the NRC regulatory required records will be stored and 

available for review during NRC inspections 

8.10 Item 10: Radiation Safety Program 

Regulations: 10 CFR 20.1101, 10 CFR 30.33, 10 CFR 39.13 

Criteria: A radiation safety program must be established and submitted to the NRC as part of 

the application. The program must be commensurate with the scope and extent of activities for 

the use of licensed materials in well logging, tracer, and field flood study operations. Each 

applicant must develop, document, and implement a radiation protection program containing the 

following elements: 

 steps to keep radiation exposures ALARA 

 description of equipment and facilities adequate to protect personnel, the public, and the 

environment 
43 

 conduct of licensed activities by individuals qualified by training and experience 

 written operating and emergency procedures 

 program for the annual inspection of the job performance of well logging personnel 

 description of organization structure and individuals responsible for ensuring 

implementation of radiation safety program 

 records management

Discussion: The specific components of an applicant’s radiation safety program are detailed in 

the subsections found under this section. Some of these subsections will not require the 

applicant to submit information as part of an application, but simply provide the applicant with 

guidance to comply with a specific NRC requirement.

For Field Flood Studies 

Applicants who plan to conduct well logging operations using sealed sources, tracer materials, 

or tracer materials in field flood study operations are required to submit for NRC approval their 

Operating and Emergency procedures or, optionally, to provide either an outline or summary of 

each procedure that includes the important radiation safety aspects of each individual 

procedure. Radiation safety programs including tracer materials must assure that they address 

these additional concerns: 

 methods or procedures for preventing the release of contaminated material, equipment 

or vehicles to unrestricted use from tracer or field flood study operations 

 radiation safety procedures and the well logging supervisors’ responsibilities unique to 

tracer and field flood study operations 

 tracer and field flood study equipment, techniques, and corresponding radiation safety 

procedures associated with use of tracer materials. 

Note: Appendix E includes a description of procedures for using tracer materials in field flood 

study operations. 

Response from Applicant: The applicant is required to establish and submit its radiation 

protection program. Each bulleted item listed above should be addressed, as applicable to the 

licensed activities requested. 

8.10.1 Well Owner or Operator Agreements 

Regulations: 10 CFR 39.15(a), 10 CFR 39.15(d), 10 CFR 39.55(b), 10 CFR 39.69(c), 

10 CFR 39.77(c), 10 CFR 39.77(d). 

Criteria: Well logging conducted with a sealed source shall only be performed if a written 

agreement with the employing well owner or operator is executed prior to the start of well 

logging operations. 
44 

Discussion: Well logging operations conducted using sealed sources are performed only after 

a written agreement is executed with the employing well owner or operator. Written agreements 

must identify a responsible party for ensuring that the following steps will be taken if a source 

becomes lodged in a hole: 

 A reasonable effort will be made to recover the source. 

 A person will not attempt to recover a lodged sealed source in a manner that, in the 

licensee’s opinion, could result in its rupture. 

 During efforts to recover a sealed source, a licensee must continuously monitor the 

circulating fluids in the well bore, as required in 10 CFR 39.69(c). 

 Contaminated equipment, personnel, or environment must be decontaminated prior to 

release. 

 If a sealed source is classified by the licensee as irretrievable after reasonable efforts at 

recovery have been expended, the following must be implemented within 30 days, as 

shown in Figure 8.3: 

 The source must be immobilized and sealed in place with a cement plug. 

 The licensee must provide a means to prevent inadvertent intrusion on the 

source, unless the source is not accessible to any subsequent drilling operations. 

 The licensee must install a permanent identification plaque at the surface of the 

well, unless mounting of a plaque is not practical. Figure 8.4 provides an 

example diagram of a permanent identification plaque. The information that 

should be included are the following: 

(1) the word “CAUTION” 

(2) the radiation symbol 

(3) the date the source was abandoned 

(4) the name of the well owner or well operator, as appropriate 

(5) the well name and well identification number(s) or other designation 

such as global positioning system 

(6) the sealed source’s radionuclide and activity (in standard and 

International System of Units (SI) units) 

(7) the depth the source was abandoned and depth to the top of the plug 

(8) an appropriate warning, such as “DO NOT RE-ENTER THIS WELL” 

(9) a statement of the Federal or State authorities to contact if additional 

well entrance is required 
45 

Figure 8.3 Features of a Typical Source Abandonment 

The NRC is aware that in some circumstances, such as high well pressures that could lead to 

fires or explosions, the delay required to obtain NRC approval to abandon the well may 

introduce an immediate threat. Under such circumstances, immediate abandonment, 

without prior NRC approval, is authorized if a delay could cause an immediate threat to 

public health and safety. The NRC would then be notified as soon as possible after the 

abandonment. See 10 CFR 39.77(c)(1) and (d). 

1556-007.pp

041300

Top of Tool and Bottom of 

Cement Plug 15214’ MD

Tool

1.5 CiCs-137 Source 

15219’ MD

Top of Cement 

15000’ MD

Kickoff Device Consisting of Heavy 

Weight Drill Pipe Over Well Depth 

From 15000’ to 14256’ MD

Bottom of 2nd Cement Plug 12996’ MD

Base of 9 5/8” Liner 133316’ MD Bottom of 7” Liner 

14185’ MD

Top of 7” Liner 

12746’ MD

Bridge Plug 12696’ MD Also 

Top of 2nd Cement Plug

SIDETRACKED HOLE

OR GI NI AL HOLE

ABANDONED

Plugback and Kickoff 

14925’ MD

Cement

Sidetrack

Top of Fish and 

Bottom of Cement

15125’ MD

Cesium -137 Source 

15121’ MD

Tool

Casing

1556-007.pp

041300

Top of Tool and Bottom of 

Cement Plug 15214’ MD

Tool

1.5 CiCs-137 Source 

15219’ MD

Top of Cement 

15000’ MD

Kickoff Device Consisting of Heavy 

Weight Drill Pipe Over Well Depth 

From 15000’ to 14256’ MD

Bottom of 2nd Cement Plug 12996’ MD

Base of 9 5/8” Liner 133316’ MD Bottom of 7” Liner 

14185’ MD

Top of 7” Liner 

12746’ MD

Bridge Plug 12696’ MD Also 

Top of 2nd Cement Plug

SIDETRACKED HOLE

OR GI NI AL HOLE

ABANDONED

Plugback and Kickoff 

14925’ MD

Cement

Sidetrack

Top of Fish and 

Bottom of Cement

15125’ MD

Cesium -137 Source 

15121’ MD

Tool

Casing

Top of Tool and Bottom of 

Cement Plug 15214’ MD

Tool

1.5 CiCs-137 Source 

15219’ MD

Top of Cement 

15000’ MD

Kickoff Device Consisting of Heavy 

Weight Drill Pipe Over Well Depth 

From 15000’ to 14256’ MD

Bottom of 2nd Cement Plug 12996’ MD

Base of 9 5/8” Liner 133316’ MD Bottom of 7” Liner 

14185’ MD

Top of 7” Liner 

12746’ MD

Bridge Plug 12696’ MD Also 

Top of 2nd Cement Plug

Top of Tool and Bottom of 

Cement Plug 15214’ MD

Tool

1.5 CiCs-137 Source 

15219’ MD

Top of Cement 

15000’ MD

Kickoff Device Consisting of Heavy 

Weight Drill Pipe Over Well Depth 

From 15000’ to 14256’ MD

Bottom of 2nd Cement Plug 12996’ MD

Base of 9 5/8” Liner 133316’ MD Bottom of 7” Liner 

14185’ MD

Top of 7” Liner 

12746’ MD

Bridge Plug 12696’ MD Also 

Top of 2nd Cement Plug

SIDETRACKED HOLE

OR GI NI AL HOLE

ABANDONED

Plugback and Kickoff 

14925’ MD

Cement

Sidetrack

Top of Fish and 

Bottom of Cement

15125’ MD

Cesium -137 Source 

15121’ MD

Tool

Casing

SIDETRACKED HOLE

OR GI NI AL HOLE

ABANDONED

Plugback and Kickoff 

14925’ MD

Cement

Sidetrack

Top of Fish and 

Bottom of Cement

15125’ MD

Cesium -137 Source 

15121’ MD

Tool

Casing
46 

Figure 8.4 Permanent Identification Plaque 

Note: A written agreement is not required if the licensee and well owner or operator are part of 

the same corporate structure or otherwise similarly affiliated. However, all other requirements 

must still be met.

 If the requirement for a written agreement does not apply to you, then you should include 

a statement in your application that you will only log holes where the well owner or 

operator is part of your corporate structure or otherwise similarly affiliated, and you 

should describe the corporate affiliation. 

Response from Applicant: Provide the following:

A statement that: “We will obtain a written agreement that meets the requirements specified in 

10 CFR 39.15 prior to well logging: (1) with a sealed source; (2) with a neutron generator 

exceeding 30 curies; or (3) with a neutron generator in a well without a surface casing.”

CAUTION

ONE 20 CURIE AM -241/BE RADIOACTIVE SOURCE

ABANDONED 10 APRIL 96 AT 4901 FT

PLUGBACK DEPTH 3870 FT

DO NOT RE-ENTER THIS WELL BEFORE CONTACTING

MICHIGAN DEPARTMENT OF ENVIRONMENTAL QUALITY

& U.S. NUCLEAR REGULATORY COMMISSION

HILDEN OIL COMPANY

BROOKLYN, MICHIGAN

DANN NO. 1-1A

API NO. 21-075-50569

JACKSON COUNTY, MICHIGAN

SECT 1 TWP 4S RGE 3W

COMPANY:

WELL:

LOCATION:

1556-008.pp

041300

CAUTION

ONE 20 CURIE AM -241/BE RADIOACTIVE SOURCE

ABANDONED 10 APRIL 96 AT 4901 FT

PLUGBACK DEPTH 3870 FT

DO NOT RE-ENTER THIS WELL BEFORE CONTACTING

MICHIGAN DEPARTMENT OF ENVIRONMENTAL QUALITY

& U.S. NUCLEAR REGULATORY COMMISSION

CAUTION

ONE 20 CURIE AM -241/BE RADIOACTIVE SOURCE

ABANDONED 10 APRIL 96 AT 4901 FT

PLUGBACK DEPTH 3870 FT

DO NOT RE-ENTER THIS WELL BEFORE CONTACTING

MICHIGAN DEPARTMENT OF ENVIRONMENTAL QUALITY

& U.S. NUCLEAR REGULATORY COMMISSION

HILDEN OIL COMPANY

BROOKLYN, MICHIGAN

DANN NO. 1-1A

API NO. 21-075-50569

JACKSON COUNTY, MICHIGAN

SECT 1 TWP 4S RGE 3W

COMPANY:

WELL:

LOCATION:

HILDEN OIL COMPANY

BROOKLYN, MICHIGAN

DANN NO. 1-1A

API NO. 21-075-50569

JACKSON COUNTY, MICHIGAN

SECT 1 TWP 4S RGE 3W

COMPANY:

WELL:

LOCATION:

1556-008.pp

041300
47 

8.10.2 Radiation Safety Program Audit 

Regulations: 10 CFR 20.1101, 10 CFR 20.2102.

Criteria: Licensees must review the content and implementation of their radiation protection 

programs annually to ensure the following: 

 compliance with NRC and DOT regulations (as applicable), and the terms and conditions 

of the license 

 occupational doses and doses to members of the public are as low as is reasonably 

achievable (ALARA) (10 CFR 20.1101, “Radiation protection programs”) 

 records of audits and other reviews of program content and implementation are 

maintained for 3 years 

Discussion: Appendix F contains a suggested annual audit program that is specific to well 

logging and tracer operations and is acceptable to the NRC. Since all areas indicated in 

Appendix F may not be applicable to every licensee and all items may not need to be addressed 

during each audit, licensees may wish to develop a program-specific audit checklist. 

The NRC encourages licensee management to conduct performance-based reviews by 

observing work in progress, interviewing staff, and spot-checking required records. As a part of 

the audit program, applicants should consider performing unannounced audits of well logging 

and tracer operations to observe whether radiation safety procedures are being followed. 

It is essential that, once identified, problems are corrected comprehensively and in a timely 

manner. Information Notice (IN) 96-28, “Suggested Guidance Relating to Development and 

Implementation of Corrective Action,” provides guidance on this subject. Licensees are 

encouraged to contact the NRC for guidance if there is any uncertainty about a reporting 

requirement. The NRC routinely reviews licensee’s records to verify if appropriate corrective 

actions were implemented in a timely manner to address recurrence. It is in the best interest of 

the licensee to identify potential violations of regulatory requirements and take necessary steps 

to correct them. The NRC can opt to exercise discretion and may elect not to cite the licensee 

for these violations if prompt and effective corrective actions are implemented. For information 

on the NRC’s use of discretion in issuing a notice of violation, refer to the most recent version of 

NRC’s enforcement documents at http://www.nrc.gov/reading-rm/doccollections/enforcement/. The NRC’s Enforcement Policy may be found online at 

http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html and the Enforcement 

Manual may be found online at http://www.nrc.gov/aboutnrc/regulatory/enforcement/guidance.html. 

 

Licensees must maintain records of audits and other reviews of program content and 

implementation for 3 years from the date of the record. The NRC has found audit records that 

contain the following information acceptable: 

 date of audit. 

 name of person or persons who conducted the audit 

 names of persons contacted by the auditor or auditors 

 areas audited
48 

 audit findings and corrective actions 

 follow-up 

Response from Applicant: No response required. The licensee’s program for auditing its 

radiation safety program will be reviewed during inspections. 

References: The current version of the NRC’s Enforcement Policy is included on the NRC’s 

Web site at http://www.nrc.gov/about-nrc/regulatory/enforcement.html. IN 96-28, dated 

May 1, 1996, can be found on the NRC’s Generic Communications Web page under Information 

Notices: http://www.nrc.gov/reading-rm/doc-collections/gen-comm/. 

8.10.3 Radiation Monitoring Instruments 

Regulations: 10 CFR 20.1501, 10 CFR 20.2103(a), 10 CFR 30.33(a)(2), 10 CFR 39.33 

Criteria: Licensees must possess radiation monitoring instruments that are necessary to 

protect health and minimize danger to life or property. Instruments used for quantitative 

radiation measurements must be calibrated for the radiation that is measured at least every 6 

months. For the purposes of this document, survey instruments are defined as any device used 

to measure the radiological conditions at a licensed facility, field station, or temporary job site. 

Discussion: For well logging and tracer operations, instruments must be capable of measuring 

beta and gamma radiation at intensities ranging from 1 microsievert (μSv) (0.1 millirem (mrem)) 

per hour through at least 500 μSv (50 mrem) per hour. Licensees shall also have available 

calibrated and operable radiation detection instruments sensitive enough to detect the low 

radiation and contamination levels that could be encountered if a sealed source ruptured. 

Licensees shall possess operable and calibrated radiation detection/measurement instruments 

to perform the following, as necessary: 

 package surveys 

 vehicle surveys 

 tracer material contamination surveys of equipment, vehicles, personnel and sites 

 prescreening of sealed source leak tests 

 unrestricted area dose rate measurements 
49 

Figure 8.5 Types of surveys. There are many different types of surveys performed by well 

logging, tracer, and field flood studies licensees. 

The choice of instrument should be appropriate for the type of radiation to be measured, and for 

the type of measurement to be taken (count rate, dose rate, etc.). 

Applications should include descriptions of the instrumentation available for use and 

instrumentation that applicants intend to purchase prior to starting licensed activities. The 

description should include type of instrument and probe, and the instrument’s intended purpose. 

The NRC requires that calibrations be performed by the instrument manufacturer or a person 

specifically authorized by the NRC or an Agreement State, unless the applicant specifically 

requests this authorization. Applicants seeking authorization to perform survey instrument 

calibrations shall submit procedures for review. Appendix I provides information about 

instrument specifications and model calibration procedures.

Response from Applicant: Provide one of the following: 

 A description of the instrumentation (as described above) that will be used to perform 

required surveys and a statement that: “We will use instruments that meet the radiation 

monitoring instrument specifications published in Appendix I of NUREG-1556, Volume 

14, Revision 1, ‘Program-Specific Guidance About Well Logging, Tracer and Field Flood 

Study Licenses.’ We reserve the right to upgrade our survey instruments as necessary.” 

OR 

 A description of the instrumentation (as described above) that will be used to perform 

required surveys and a statement that: “We will use instruments that meet the radiation 

monitoring instrument specifications published in Appendix I of NUREG-1556, 

Volume 14, Revision 1 “Program-Specific Guidance About Well Logging, Tracer and 

Field Flood Study Licenses.” Additionally, we will implement the model survey meter 

calibration program published in Appendix I of NUREG-1556, Volume 14, Revision 1 

"Program-Specific Guidance about Well Logging, Tracer and Field Flood Study 

Licenses." We reserve the right to upgrade our survey instruments as necessary.” 

OR 

1556-009.pp

041300

Radioactive Materials

1556-009.pp

041300

Radioactive Materials
50 

 A description of alternative equipment and procedures for ensuring that appropriate 

radiation monitoring equipment will be used during licensed activities and that proper 

calibration and calibration frequency of survey equipment will be performed. Further, the 

statement “We reserve the right to upgrade our survey instruments as necessary” should be 

added to the response.

Note: Alternative responses will be reviewed using the criteria listed above.

8.10.4 Material Receipt and Accountability 

Regulations: 10 CFR 20.1801, 10 CFR 20.1802, 10 CFR 20.1906, 10 CFR 20.2207, 

10 CFR 30.34(e), 10 CFR 30.35(g), 10 CFR 30.41, 10 CFR 30.51, 10 CFR 39.37.

Criteria: Licensees with licensed material must do the following: 

 Retain records of receipt of licensed material as long as the material is possessed, and 

for three years following transfer or disposal of the material. 

 Retain records of each transfer of licensed material for 3 years after each transfer. 

 Retain records of each disposal of licensed material until the NRC terminates the license 

that authorizes disposal of the material. 

 Update transactions in the National Source Tracking System (NSTS), including an 

annual inventory reconciliation, if applicable. 

 Conduct physical inventories of licensed materials semiannually to account for all sealed 

sources, tracer materials, and depleted uranium. 

 Retain inventory records for 3 years from the date of the inventory. 

Discussion: As illustrated in Figure 8.6, licensed materials must be tracked from the time of 

receipt to disposal in order to ensure accountability, identify when licensed material is lost, 

stolen, or misplaced, and to ensure that possession limits listed on the license are not 

exceeded. Physical inventories, which should be conducted semiannually, should account for 

all licensed material (i.e., location where the material is stored, physical verification of the 

presence of the material, and accountability of the material by the use of material receipt and 

transfer records). 

Inventory records must be retained for 3 years and contain the following types of information: 

 quantity and kind of licensed material including sealed sources, tracer material on hand 

(including waste), and depleted uranium in sinker bars 

 location of licensed material 

 date the inventory occurred 

 name of individual performing the inventory 
51 

Note: Physical inventory records may be combined with leak test records.

Licensees who receive, transfer, and dispose of nationally tracked sources (i.e., sealed sources 

containing a quantity equal or greater than Category 1 or Category 2 levels of any radioactive 

material listed in Appendix E of 10 CFR Part 20, “Standards for Protection Against Radiation”) 

must complete and submit to the National Source Tracking System (NSTS) a National Source 

Tracking Transaction Report by the close of the next business day after the transaction has 

occurred. In addition, licensees must reconcile the inventory of nationally tracked sources 

possessed by the licensee against that licensee’s data in NSTS. This reconciliation must be 

conducted during the month of January in each year. Licensees must submit to the NSTS 

confirmation that the data in NSTS is correct by January 31 of each year. Additional information 

regarding the NSTS may be found on the NRC public web site at 

http://www.nrc.gov/security/byproduct/ismp/nsts.html. 

Figure 8.6 Material receipt and accountability. Licensees must retain records of receipt, 

transfer, and disposal in accordance with the retention period described in 10 CFR 30.51, 

“Records.” Licensees must conduct semi-annual physical inventories and must retain inventory 

records for 3 years from the date of the inventory in accordance with 10 CFR 39.37, “Physical 

inventory.” 

Response from Applicant: Provide the following statements: 

 “Physical inventories will be conducted and documented semiannually to account for all 

licensed material, including byproduct, tracer, and depleted uranium received and 

possessed under the license.” 

AND 

 “We will develop, implement, and maintain procedures for ensuring accountability of 

licensed materials at all times.” 

AND 

 If applicable, “We will comply with the National Source Tracking System (NSTS) 

reporting requirement as described in 10 CFR 22.2207.”

1556-010.ppt

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Material Receipt and Transfer

Disposal or Transfer

Transfer

or

D

R

isposal ecord

Receipt

Receipt

Record

Semi-Annual 

Inventory:

Jan 

7 Jul

7

1556-010.ppt

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Material Receipt and Transfer

Disposal or Transfer

Transfer

or

D

R

isposal ecord

Receipt

Receipt

Record

Receipt

Record

Semi-Annual 

Inventory:

Jan 

7 Jul

7
52 

8.10.5 Occupational Dosimetry 

Regulations: 10 CFR 20.1201, 10 CFR 20.1202, 10 CFR 20.1203, 10 CFR 20.1207, 

10 CFR 20.1208, 10 CFR 20.1501, 10 CFR 20.1502, 10 CFR 39.65.

Criteria: According to 10 CFR 39.65, “Personnel monitoring,” logging supervisors and logging 

assistants must wear personnel dosimeters (processed and evaluated by an accredited National 

Voluntary Laboratory Accreditation Program (NVLAP) processor) during the handling or use of 

licensed radioactive material. This requirement applies to personnel using dosimeters for whole 

body measurements. Appendix J provides guidance for determining if individuals other than the 

RSO, logging supervisors, or logging assistants require dosimetry. 

Bioassay services required in a license must be provided to individuals using tracer materials in 

subsurface studies if required by the license. 

Figure 8.7 Annual dose limits for occupationally exposed adults 

Discussion: The licensee may not permit any individual to act as a logging supervisor or 

logging assistant unless, at all times during the handling of licensed radioactive material, each 

individual wears on the trunk of the body an NVLAP-approved personnel dosimeter that is 

sensitive to the type of radiation(s) to which the individual is exposed. If neutron sources or 

neutron producing equipment are to be used, a commitment to provide neutron-sensitive 

dosimetry devices is required. If film badges are used, they must be replaced at least monthly, 

and other personnel dosimeters (thermoluminescent dosimeters (TLDs) or optically stimulated 

luminescence dosimeters (OSLs)) must be replaced at least quarterly . A list of NVLAP 

approved dosimetry processors can be found at http://www.nist.gov/nvlap.
53 

For purposes of internal dosimetry, the licensee may be required to provide bioassay services 

when individuals work with unsealed radioactive material. Bioassays are required if working 

with quantities, chemical and physical forms, and activities that make it likely that the 

radionuclide will be ingested, inhaled, or absorbed resulting in an intake in excess of 10 percent 

of the applicable annual limit on intakes (ALIs) in table 1, Columns 1 and 2, of Appendix B to 

10 CFR Part 20. One ALI results in a committed effective dose equivalent (CEDE) of 5 rems or 

a committed dose equivalent (CDE) of 50 rems. 

When using individually packaged “ready to use” quantities of iodine-131 tracer materials in 

well logging operations, bioassays are required for individuals using more than 50 millicuries at 

any one time, or using a total of 50 millicuries within any 5-day period. Guidance on bioassay 

programs for iodine-131, including the levels and types of handling for which bioassays are 

indicated, is provided in Regulatory Guide 8.20, “Applications of Bioassay for iodine-125 and 

iodine-131.” When handling tritium (H-3) exceeding 3.7 Gbq (0.1 curie) or gaseous H-3 

exceeding 3700 Gbq (100 curies), bioassays are required. Guidance on bioassay programs 

for tritium is provided in Regulatory Guide 8.32, “Criteria for Establishing a Tritium Bioassay 

Program.” Copies of Regulatory Guides may be obtained from the NRC’s Web site at 

http://www.nrc.gov/reading-rm/doc-collections/reg-guides/occupational-health/rg. 

Bioassay services are available and provided by local hospitals, universities, or other vendors 

specifically approved by an NRC or Agreement State license to provide such services. 

Response from Applicant: 

Provide the following: 

 Provide a statement that the required personnel dosimeters (e.g., film badge, TLD, OSL) 

will be processed and evaluated by an NVLAP-accredited entity, will be exchanged at 

the required frequency, and will be assigned to and worn by well logging supervisors and 

logging assistants. 

AND 

 Provide a bioassay program when using unsealed radioactive tracer materials. If an 

applicant elects to provide a bioassay program that is less conservative than 

recommended in Regulatory Guide 8.20, 8.32, or other appropriate Regulatory Guide, its 

rationale should be stated. Bioassay programs should include what the applicant 

considers an acceptable interval or schedule for conducting bioassays, identify action 

levels or guidelines, and describe specific actions to be taken when action levels are 

exceeded. Because of the complex nature of bioassay and corresponding data analysis, 

it is acceptable for applicants to make reference to the procedures in NRC guidance 

documents. 

OR 

 In lieu of providing a bioassay program, provide a commitment that the applicant will 

contract with a vendor for bioassay services, and confirm that the vendor is licensed or 

otherwise authorized by the NRC or an Agreement State to provide required bioassay 

services. 
54 

OR 

 In lieu of providing a bioassay program, provide a commitment that the applicant will not 

allow any individual to use more than: (1) 50 millicuries of iodine-131 at any one time or 

in any 5-day period at field stations or at temporary job sites; (2) or more than 3.7 Gbq 

(0.1 curie) of H-3 or more than 3700 Gbq (100curies) of gaseous H-3. 

8.10.6 Public Dose 

Regulations: 10 CFR 20.1003, 10 CFR 20.1301, 10 CFR 20.1302, 10 CFR 20.1801, 

10 CFR 20.1802, 10 CFR 20.2107. 

Criteria: Licensees must do the following: 

 Ensure that licensed materials will be used, transported, stored, and disposed of in such 

a way that members of the public will not receive more than 1 millisievert (mSv) 

(100 mrem) in 1 year, and the dose in any unrestricted area will not exceed 0.02 mSv 

(2 mrem) in any 1 hour, from licensed operations. 

 Control and maintain constant surveillance of licensed materials when in use and not in 

storage. 

 Secure stored licensed materials from access, removal, or use by unauthorized 

personnel. 

Discussion: Members of the public include persons who work in or may occupy locations 

where licensed material is used or stored. Employees whose assigned duties do not include the 

use of licensed material and work in the vicinity where it is used or stored are also included as 

members of the public. Public dose is controlled, in part, by ensuring that licensed material is 

secured (e.g., located in a locked area) to prevent unauthorized access or use. Well logging 

sealed sources and tracer materials are usually restricted by controlling access to the keys 

needed to gain access to storage locations, including downhole storage bunkers. 

Public dose is also affected by the choice of storage and use locations at the field stations and 

at temporary job sites. Licensed material must be located so that the resulting public dose in an 

unrestricted area (e.g., an office or the exterior surface of an outside wall) does not exceed 

1 mSv (100 mrem) in a year or 0.02 mSv (2 mrem) in any 1 hour. Applicants should use the 

concepts of controlling time, distance, and shielding when choosing storage and use locations. 

Decreasing the time that an individual is exposed, increasing the distance from the radioactive 

material, and adding shielding that is appropriate for the specific type of radiation (e.g., brick, 

concrete, lead, hydrogenous materials.) will reduce the radiation exposure. 

Information provided by the manufacturer or vendor on anticipated radiation levels of sealed 

sources and tracer materials, both inside their respective transport containers and outside the 

transport container at given distances, is the type of information needed to make public dose 

calculations. Licensees may assess radiation levels located in adjacent areas to radioactive 

material either by making calculations or by using a combination of direct measurements and 

calculations. After obtaining anticipated radiation levels or by making direct radiation 

measurements using an appropriate survey instrument, an applicant can use the “inverse 

square” law, occupancy factors, and shielding design to evaluate the effect on the public and 
55 

use this information to determine operating and emergency procedures for using radioactive 

materials. See Appendix K for an example demonstrating that individual members of the public 

will not receive doses exceeding the allowable public limits. 

If, after making an initial public dose evaluation, a licensee changes the conditions used for the 

evaluation (e.g., relocates radioactive material within a designated storage area, increases the 

amount of radioactive materials in storage, changes the frequency radioactive material is in use, 

or changes the occupancy of adjacent areas), the licensee must perform a new evaluation to 

ensure that the public dose limits are not exceeded and take corrective action, if required. 

Calculating the Annual Dose to an 

Individual Member of the Public

1556-012.ppt

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Identify all potential sources of external and internal 1 exposure to members of the public

Another facility? Perform the above steps for all 8 facilities

Multiply the maximum annual dose by the 7 occupancy factors to get the annual dose

Multiply the dose rates by the number of hours in a 6 year to produce the maximum annual dose

Calculate predicted occupancy factors at points of 5 maximum dose rates

Identify from survey data, at each location, maximum 4 levels of dose rates

Perform surveys of all locations of use, transport, or 3 storage of radioactive material

Identify all locations of use, transport, or storage 2 of radioactive material

Calculating the Annual Dose to an 

Individual Member of the Public

1556-012.ppt

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Identify all potential sources of external and internal 1 exposure to members of the public

Another facility? Perform the above steps for all 8 facilities

Multiply the maximum annual dose by the 7 occupancy factors to get the annual dose

Multiply the dose rates by the number of hours in a 6 year to produce the maximum annual dose

Calculate predicted occupancy factors at points of 5 maximum dose rates

Identify from survey data, at each location, maximum 4 levels of dose rates

Perform surveys of all locations of use, transport, or 3 storage of radioactive material

Identify all locations of use, transport, or storage 2 of radioactive material

Figure 8.8 Steps used to calculate public dose. 

Response from Applicant: No response is required from the applicant in a license application, 

but compliance will be examined during inspection. During NRC inspections, licensees must be 

able to provide documentation demonstrating by measurement or calculation that the total 

effective dose equivalent to the individual member of the public likely to receive the highest 

dose from licensed operations is less than 1 mSv (100 mrem) in 1 year, and any unrestricted 

area does not exceed 0.02 mSv (2 mrem) in any 1 hour. See Appendix K for examples of 

methods to demonstrate compliance. 

8.10.7 Operating and Emergency Procedures 

Regulations: 10 CFR 20.1406, 10 CFR 20.1906, 10 CFR 20.2201, 10 CFR 20.2202, 

10 CFR 20.2203, 10 CFR 21.21(a), 10 CFR 30.50, 10 CFR 39.13, 10 CFR 39.33(b), 

10 CFR 39.43, 10 CFR 39.63, 10 CFR 39.67, 10 CFR 39.69, 10 CFR 39.77.
56 

Criteria: The licensee must develop, implement, and maintain operating and emergency 

procedures or submit a summary of the procedures that addresses the important radiation 

safety aspects of each procedure to the NRC as part of the application package. Additionally, if 

well logging and tracer personnel perform specific operations such as leak-testing, semi-annual 

inspection and maintenance of equipment, and removal and replacement of a sealed source “O” 

ring, appropriate procedures and instructions for these operations should be included in the 

applicant’s operating and emergency procedures.

Each licensee must develop, implement, and maintain operating and emergency procedures 

that address scenarios likely to be encountered. Operating and emergency procedures’ 

elements must include the items outlined in 10 CFR 39.63, “Operating and emergency 

procedures.” The following is provided as a checklist of important items: 

 instructions for handling and using licensed materials, including sealed sources in wells, 

without surface casing for protecting freshwater aquifers 

 instructions for maintaining security during storage and transportation 

 instructions to keep licensed material under control and under immediate surveillance 

during use 

 steps to take to keep radiation exposures ALARA 

 steps to maintain accountability during use (including during emergency situations) 

 steps to control access to work sites 

 steps to take and whom to contact when an emergency occurs 

 instructions for using remote handling tools when handling sealed sources, except lowactivity calibration sources and radioactive tracer materials 

 methods and occasions for conducting radiation surveys, including surveys for detecting 

contamination, as required by 10 CFR 39.67(c) through (e) 

 procedures to minimize personnel exposure during routine use and in the event of an 

incident, including exposures from inhalation and ingestion of licensed tracer materials 

 methods and occasions for locking and securing stored licensed materials 

 personnel monitoring, including bioassays, and the use of personnel monitoring 

equipment 

 transportation of licensed materials to field stations or temporary job sites, packaging of 

licensed materials for transport in vehicles, placarding of vehicles when needed, and 

physically securing licensed materials in transport vehicles during transportation to 

prevent accidental loss, tampering, or unauthorized removal
57 

 procedures for picking up, receiving, and opening packages containing licensed 

materials, in accordance with 10 CFR 20.1906, “Procedures for receiving and opening 

packages” 

 instructions for the use of tracer materials, including how to decontaminate the 

environment, equipment, and personnel 

 instructions for maintaining records in accordance with the regulations and the license 

conditions 

 steps for the use, inspection, and maintenance of sealed sources, source holders, 

logging tools, injection tools, source handling tools, storage containers, transport 

containers, and uranium sinker bars, as required by 10 CFR 39.43, “Inspection, 

maintenance, and opening of a source or source holder” 

 procedures for identifying and reporting to NRC defects and noncompliance, as required 

by 10 CFR 21.21(a) 

 actions to be taken if a sealed source is lodged in a well, as required by 10 CFR 39.15 

and 39.77. Refer to Appendix L for guidance on reporting requirements. 

 procedures and actions to be taken if a sealed source is ruptured, including actions to 

prevent the spread of contamination and minimize inhalation and ingestion of licensed 

materials and actions to obtain suitable radiation survey instruments, as required by 

10 CFR 39.33(b). Refer to Appendix P for some key elements that should be addressed 

in the procedures. 

 instructions for the proper storage and disposal of radioactive waste 

 procedures for laundering contaminated clothing and for decontaminating equipment 

and vehicles 

 procedures to be followed in the event of uncontrolled release of radioactive tracer 

material to the environment, including notification of the RSO, the NRC, and other 

Federal and State agencies. 

Discussion: The purpose of operating and emergency procedures is to provide well logging 

and tracer personnel, including field flood study personnel, with specific guidance for all 

operations they will perform. Each topic of importance should be included in the operating and 

emergency procedures and need not be presented in order. Instructions for non-routine 

operations, for example, inspection and maintenance of well logging and tracer equipment or 

conducting calibration of survey instruments, should be included as separate appendices in the 

application.

Operating and emergency procedures need not specify a particular make and model of survey 

instrument. Procedures should provide sufficient guidance and instruction for each specific type 

of well logging or associated equipment. For example, you may submit a single operating 

procedure for using sealed sources, tracer materials, and radionuclides used in field flood 

operations, provided the unique variances in each operation are addressed in the application.
58 

Operating and emergency procedures or a summary of the procedures that addresses the 

important radiation safety aspects of each must be submitted to the NRC for review as a part of 

the application. 

Response from Applicant: 

We will develop, implement, and maintain operating and emergency procedures that address 

the important radiation safety aspects, as described in 10 CFR 39.63. 

8.10.8 Leak Tests 

Regulations: 10 CFR 30.53, 10 CFR 39.13(f), 10 CFR 39.35.

Criteria: The NRC requires testing of sealed sources containing greater than 3.7 MBq (100 

microcuries) of beta/gamma or 0.37 MBq (10 microcuries) of alpha radioactive material in order 

to determine whether there is any radioactive leakage from sealed sources. Requirements for 

leak tests are based on the type of radiation (beta/gamma/alpha) escaping from the inner 

capsule. Records of test results must be maintained. 

Discussion: The NRC or an Agreement State may authorize manufacturers, consultants, and 

other organizations to either perform the entire leak-test sequence for other licensees or provide 

leak-test kits to licensees. In the latter case, the licensee is expected to take the leak-test 

sample according to the device manufacturer’s and the kit supplier’s instructions and return it to 

the kit supplier for evaluation and reporting results. Licensees may also be authorized to 

conduct the entire leak-test sequence themselves. Measurement of the leak-test sample is a 

quantitative analysis requiring that instrumentation used to analyze the sample be capable of 

detecting 185 Bq (0.005 microcurie (μCi)) of radioactivity. 

Sealed sources will be leak tested at intervals not to exceed 6 months. Energy Compensation 

Sources will be leak tested at intervals not to exceed 3 years, unless exempted under 

10 CFR 39.35(e). 

Response from Applicant: 

State either of the following: 

 “Leak tests sample collection and analysis will be performed by an organization 

authorized by NRC or an Agreement State to provide leak testing services to other 

licensees; or by using a leak test sample collection kit supplied by an organization 

licensed by NRC or an Agreement State to provide leak test kits and/or sample analysis 

services to other licensees and according to the instructions provided in the leak test 

sample collection kit.” 

OR 

 “Leak test sample collection and analysis will be done by the applicant.” Provide the 

information in Appendix M supporting a request to perform leak test sample collection 

and sample analysis and either state that you will follow the model procedures in the 

appendix or submit a description of alternative procedures. 
59 

Note: Requests for authorization to perform leak testing and sample analysis will be reviewed 

on a case-by-case basis and, if approved, NRC staff will authorize via a license condition. 

Alternative procedures will be evaluated against Appendix M criteria. 

8.10.9 Maintenance 

Regulations: 10 CFR 39.31, 10 CFR 39.43, 10 CFR 39.49 

Criteria: The licensee shall have written procedures for visually inspecting and for maintaining 

source holders, logging tools, injection tools, source handling tools, storage and transport 

containers, and uranium sinker bars in an operable condition, including labeling. If equipment 

problems are found, the equipment must be withdrawn from service until repaired. Records of 

this inspection program are required. 

Discussion: Each licensee shall have a program to visually check source holders, tools, 

containers, and sinker bars for defects prior to each use to ensure that the equipment is in good 

working order and that required labeling is present. If defects are found, the equipment must be 

removed from service until repaired and a record made of the defect and the repairs made prior 

to returning the equipment for use. Licensees shall conduct a visual inspection semiannually to 

ensure that no physical damage to equipment is visible and the required labeling is present. 

Licensees must establish a program for the routine maintenance of source holders, logging 

tools, inspection tools, source handling tools, storage containers, transport container, injection 

tools, and uranium sinker bars. If defects are found during the visible inspection or during the 

routine maintenance, the equipment must be removed from service until repaired and a record 

made of the defect and any repairs made prior to returning the equipment for use. These 

records must be retained for 3 years after the defect is found. 

Non-routine and special maintenance, e.g., change of O-rings on sealed sources or removal of 

a stuck sealed source, in a manner that could potentially damage or rupture the source, can 

only be performed by those licensees that have specifically received authorization from the NRC 

or an Agreement State. 

Response from Applicant: No response required in the section. Applicants must include in 

subsequent sections its program for inspection and maintenance of logging equipment and 

include the program with the Operating and Emergency Procedures. 

8.10.9.1 Maintenance Prior To Use 

Regulations: 10 CFR 39.31, 10 CF R 39.43(a), 10 CFR 39.49.

Criteria: The licensee must have written procedures for visually inspecting and maintaining 

source holders, logging tools, injection tools, source handling tools, storage and transport 

containers, and uranium sinker bars for defects prior to use. This visual inspection is necessary 

to ensure that the equipment remains in good working condition and is labeled as required.

Discussion: Regulations in 10 CFR 39.43(a) require that source holders, tools, containers, and 

sinker bars be checked visually for defects prior to each use to ensure that the equipment is in 
60 

good working condition and is labeled as required. Labeling requirements are specified in 

10 CFR 39.31, “Labels, security, and transportation precautions,” and 10 CFR 39.49, “Uranium 

sinker bars.” Instructions in the operating procedures provided to personnel must clearly reflect 

the regulatory requirement—visual inspections are performed prior to each use. After the 

inspection, record the date, inspector, equipment involved, any defects found, and repairs 

made. Equipment that fails the inspection must be removed from service and returned only 

after it is successfully repaired. 

The licensee must develop, implement, and maintain procedures for visually inspecting and 

maintaining source holders, tools, and containers. 

Response from Applicant:

Provide the following: 

 State that “Before each use, visual inspections will be conducted and records maintained 

in accordance with 10 CFR 39.43(a), to ensure that well logging equipment is in good 

working condition and is labeled as required.” 

AND 

 Submit the procedure(s) for conducting visual inspections before each use. 

8.10.9.2 Semi-Annual Visual Inspection and Routine Maintenance 

Regulations: 10 CFR 21.21, 10 CFR 39.31, 10 CFR 39.43(a), 10 CFR 39.43(b), 

10 CFR 39.49.

Criteria: Licensees must have written procedures for semiannual visual and routine 

maintenance of source holders, logging tools, injection tools, source handling tools, storage and 

transport containers, and uranium sinker bars to ensure that the labeling required by 

10 CFR Part 39 is legible and that no physical damage to the equipment is visible. 

Requirements in 10 CFR 21.21, “Notification of failure to,” comply or existence of a defect and 

its evaluation,” require, in part, that licensees adopt appropriate procedures to notify the NRC of 

any equipment that is defective or could result in a substantial safety hazard.

Discussion: The licensee shall conduct visual inspections and perform routine maintenance 

activities on source holders, tools, containers, and sinker bars to ensure that the labeling 

required by 10 CFR Part 39.31, “Labels, security, and transportation precautions,” for sealed 

sources and 10 CFR 39.49 for uranium sinker bars is legible, and that no physical damage is 

visible. If defects are found, the equipment must be removed from service, and a record must 

be made, listing: the defects; inspection and maintenance operations performed; and the 

actions taken to correct the defects. As noted in 10 CFR Part 39, instructions for conducting 

these activities must be included as part of the operating and emergency procedures. 

Instructions should be tailored to the licensee’s specific program and to the equipment 

possessed and used.

Licensee staff should report all defects to the appropriate and designated licensee management 

official. The licensee management official shall report defects to the NRC, in accordance with 

10 CFR 21.21. All personnel involved in the identification of defects should be trained in the 
61 

proper communication of such findings within the licensee’s organizational structure and 

reporting to the NRC commensurate with their position. 

Response from Applicant: 

 State that “Semiannual visual inspections and routine maintenance will be conducted 

and records maintained in accordance with 10 CFR 39.43(b), to ensure that required 

labeling is legible and that no physical damage is visible.” 

AND 

 Submit the procedure(s) for conducting semiannual visual inspections and routine 

maintenance. 

8.10.9.3 Maintenance Requiring Special Authorization 

Regulations: 10 CFR 39.43(c), 10 CFR 39.43(d), 10 CFR 39.43(e) 

Criteria: Certain maintenance procedures on sealed sources or holders that contain sealed 

sources are prohibited, unless a written procedure has been approved and the licensee is 

specifically authorized by the NRC or an Agreement State to perform these operations.

Discussion: Activities that are prohibited, unless a written procedure has been reviewed and 

approved by the NRC or an Agreement State, include: 

 removing a sealed source from a source holder or logging tool 

 preventive maintenance activities on sealed sources or holders that may be necessary 

when using certain types of logging tools, including removing and replacing O-rings (see 

Figure 8.12 below) 

 removing a sealed source that is stuck in a source holder or logging tool by drilling, 

cutting, or chiseling (e.g., any situation where tools are required to remove the stuck 

source). 

 opening, repairing, or modifying any sealed source 
62 

Figure 8.9 Maintenance, cleaning, and O-ring replacement. 

Response from Applicant: 

 Statethat “Activities described in 10 CFR 39.43(c) and (d) shall not be conducted unless 

detailed written procedures have been approved by the NRC.” 

OR 

 Submit detailed procedures for any activities described in 10 CFR 39.43(c) and (d), 

including radiation safety precautions that individuals will be expected to follow when 

performing these tasks and the minimum qualifications of these individuals. Each 

different task must be described. Should a procedure require the removal of the sealed 

source from the holder before performing any maintenance on the holder, applicants 

should describe the removal procedures. 

Note: Equipment manufacturers can provide information concerning maintenance and source 

removal procedures. In some cases, certain maintenance operations should only be performed 

by the manufacturer or individuals who are licensed by the NRC or an Agreement State to 

provide these services. 

1556-013.pp

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Safety Checklist

Survey Meter

Dosimetry

Procedures for 

removing “O” rings

Jigs, remote tools

Remote Tool

Sealed Source

Dosimeter

Survey Meter

Jig or Support

“O” ring

1556-013.pp

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Safety Checklist

Survey Meter

Dosimetry

Procedures for 

removing “O” rings

Jigs, remote tools

Remote Tool

Sealed Source

Dosimeter

Survey Meter

Jig or Support

“O” ring

Safety Checklist

Survey Meter

Dosimetry

Procedures for 

removing “O” rings

Jigs, remote tools

Safety Checklist

Survey Meter

Dosimetry

Procedures for 

removing “O” rings

Jigs, remote tools

Remote Tool

Sealed Source

Dosimeter

Survey Meter

Jig or Support

“O” ring
63 

8.10.10 Transportation 

Regulations: 10 CFR 20.1101, 10 CFR 30.41, 10 CFR 30.51, 10 CFR 39.31, 10 CFR 71.5, 

10 CFR 71.12, 10 CFR 71.14, 10 CFR 71.37, 10 CFR 71.38, 10 CFR 71.47, Subpart H of 

10 CFR Part 71, 49 CFR Parts 171-178.

Criteria: Applicants must develop, implement, and maintain safety programs for transport of 

radioactive material to ensure compliance with NRC and DOT regulations. 

Discussion: Licensees should consider the safety of all individuals who may either handle or 

come into contact with transport containers or packages containing licensed material. The 

primary consideration in packaging licensed material should be to ensure that the package 

integrity is not compromised during transport and that the radiation levels or removable 

contamination levels at the package surfaces meet the regulatory requirements of 

10 CFR 71.47, “External radiation standards for all packages,” and 49 CFR 173.443, 

“Contamination control.” In all cases, ALARA concerns are addressed prior to, during, and after 

transporting any radioactive material.

Note: Licensees shipping radioactive waste for disposal must prepare appropriate 

documentation as specified in 10 CFR Part 20 and Appendix N. 

Figure 8.10 Transportation. Licensees often transport their equipment and radioactive 

materials, including sealed sources and tracer materials, to and from job sites and must ensure 

compliance with DOT regulations.

Discussion: Figure 8.10 illustrates some DOT requirements often overlooked by well logging, 

tracer, and field flood study licensees. During an inspection, the NRC uses the provisions of 10 

CFR 71.5, “Transportation of licensed material,” and a Memorandum of Understanding with 

DOT to examine and enforce transportation requirements applicable to well logging, tracer, and 

field flood study licensees. Appendix N lists major DOT regulations and provides sample 

shipping documents, placards, and labels.
64 

 

Figure 8.11 Transport container 

Response from Applicant: No response is needed from applicants during the licensing phase. 

Transportation issues are reviewed during inspections. 

References: The most recent version of “A Review of Department of Transportation 

Regulations for Transportation of Radioactive Materials” can be obtained at 

http://www.phmsa.dot.gov/staticfiles/PHMSA/DownloadableFiles/Files/RAM_Regulations_Revie

w_12-2008.pdf .

8.10.11 Minimization of Contamination 

Regulations: 10 CFR 20.1406, 10 CFR 39.33(a), 10 CFR 39.35(d), 10 CFR 39.67(c)-(e), 

10 CFR 39.69.

Criteria: Applicants for new licenses must describe how facility design and procedures for 

operation will minimize, to the extent practicable, contamination of the facility and the 

environment, facilitate eventual decommissioning, and minimize, to the extent practicable, the 

generation of radioactive waste.

Discussion: All applicants for new licenses need to consider the importance of designing and 

operating their facilities so as to minimize the amount of radioactive contamination generated at 

the site during its operating lifetime and the generation of radioactive waste during 

decontamination. When submitting new applications, applicants should consider the following 

with regards to minimization of contamination by tracer material or sealed sources: 

1556-015.ppt

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1556-015.ppt

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65 

 implementation of and adherence to good health physics practices while performing 

operations 

 minimization of distance to areas, to the extent practicable, where licensed materials are 

used and stored 

 maximization of survey frequency, within reason, to enhance detection of contamination 

 segregation of radioactive material in waste storage areas 

 segregation of sealed sources and tracer materials to prevent cross-contamination 

 separation of radioactive material from explosives 

 separation of potentially contaminated areas from clean areas by barriers or other 

controls 

Sealed sources and devices that are approved by the NRC or an Agreement State and located 

and used according to their respective SSD registration certificates usually pose minimal risk of 

contamination. Well logging applicants usually do not need to address these issues as a 

separate item since they are included in responses to other items of the application. 

Leak tests performed as specified in 10 CFR 39.35, “Leak testing of sealed sources,” should 

identify defective sources. Sealed sources found to be leaking in excess of 185 becquerels 

(0.005 microcuries) of removable contamination must be withdrawn from use and 

decontaminated, repaired, or disposed of according to NRC requirements. These steps 

minimize the spread of contamination and reduce radioactive waste associated with 

decontamination efforts. Other efforts to minimize radioactive waste do not apply to well logging 

programs using only sealed sources and devices that have not leaked. 

Special authorization must be granted by the NRC to applicants to decontaminate a facility 

contaminated by a leaking sealed source or contaminated by unsealed material with a half-life 

greater than 120 days. Approval granted in a license by the NRC or an Agreement State to 

provide these specialized services minimizes the spread of contamination and reduces 

radioactive waste associated with decontamination efforts. 
66 

Figure 8.12 Personnel surveys 

Response from Applicant: 

 The applicant does not need to provide a response to this item if the applicant has met 

the criteria in the following sections: 8.5.1,“Radioactive Material—Sealed Sources and 

Devices;” 8.5.2, “Radioactive Material—Unsealed (Tracer) Radioactive Material;” 

8.9, “Facilities and Equipment;” 8.10.8, “Radiation Safety Program—Leak Tests;” 

8.10.7, “Radiation Safety Program—Operating and Emergency Procedures;” 

8.10.13, “Radiation Safety Program—Tracer Studies;” and 8.11, “Waste Management.” 

OR 

 The applicant should submit its procedures to conduct decontamination of a facility 

contaminated by a leaking sealed source or contaminated by unsealed material with a halflife greater than 120 days.

8.10.12 Sealed Sources 

8.10.12.1 Use of Sealed Sources in Drill-To-Stop (Wireline) Operations 

Regulations: 10 CFR 39.13, 10 CFR 39.63. 

Criteria: Applicants must develop and follow instructions to be used by logging personnel when 

using licensed sealed radioactive sources in drill-to-stop (DTS) well logging operations. 

Surveying arm and hand using survey 

meter and gamma probe.

1556-016.pp

041300

Surveying feet and legs using survey 

meter and gamma probe

Surveying arm and hand using survey 

meter and gamma probe.

1556-016.pp

041300

Surveying feet and legs using survey 

meter and gamma probe
67 

Unlike measurement while drilling (MWD) or logging while drilling (LWD) operations where well 

logging operations occur concurrent with the drilling operations, drill-to-stop (DTS) well logging 

operations require that all drilling operations cease and that parts of the drilling apparatus, 

including all of the drill stem, be removed to provide access to the well bore. The well logging 

tool containing one or more sealed sources is then lowered into the well bore to obtain 

information about the well or adjacent oil, gas, mineral, groundwater, or geological formations. 

1556-017.ppt

041300

Figure 8.13 Drill to stop well logging operations 

Discussion: Operating and Emergency procedures that cover the use of sealed sources in 

DTS well logging operations must be developed and implemented. 

Applicants who request authorization to use sealed sources in DTS well logging operations in 

well bores without a surface casing should describe the procedures to be followed necessary to 

ensure that a sealed source does not become lodged in the well bore. Examples of pre-logging 

actions that should be included in the procedures are: 

 obtain specific knowledge of the borehole conditions from the drilling team or company 

 run a caliper log to show the hole is open or to find problem areas 

 run a tool without a radioactive source to show it can be freely removed 

 place a temporary casing in sections of the hole giving problems
68 

Drill-to-stop well logging activities should include procedures for using appropriate remote 

handling tools for handling sealed sources. The applicant must ensure that a handling tool is 

compatible with a particular sealed source in accordance with manufacturers/distributors 

instructions, and that operating and emergency procedures reflect the correct tool/source 

configuration. 

Response from Applicant: 

 Submit step-by-step operating and emergency procedures for conducting DTS well 

logging operations. Procedures must address radiation safety aspects when conducting 

DTS well logging operations.

8.10.12.2 Use of Sealed Sources in Measurement While Drilling or Logging While Drilling 

Well Logging Operations

Regulations: 10 CFR 39.13, 10 CFR 39.63. 

Criteria: Applicants must develop and follow procedures to be used by logging personnel when 

using licensed sealed radioactive sources in MWD or LWD well logging operations.

MWD or LWD well logging operations occur during the drilling of the well bore and do not 

require that the drill stem or other equipment be removed from the well. MWD or LWD 

requires that the well logging tool containing one or more sealed sources be located above the 

drilling stem to obtain information about the well or adjacent oil, gas, mineral, groundwater, or 

geological formations while the well drilling operation continues uninterrupted. Both MWD and 

LWD activities can be conducted at the same time drilling operations are occurring. Downhole 

recorded data from MWD or LWD sensors is transmitted to the surface through the use of mud 

telemetry. 

Discussion: Operating and Emergency procedures that cover the use of sealed sources in 

MWD or LWD well logging operations must be developed and implemented. 

Instructions in MWD and LWD well logging activities should include procedures for using 

appropriate remote handling tools for handling sealed sources. The applicant must ensure that 

a handling tool is compatible with a particular sealed source in accordance with 

manufacturers/distributors instructions, and that operating and emergency procedures reflect 

the correct tool/source configuration. 

Response from Applicant: 

 Submit step-by-step operating and emergency procedures for conducting MWD and 

LWD well logging activities. Procedures must address radiation safety aspects when 

conducting MWD and LWD well logging operations. 

8.10.12.3 Energy Compensation Sources 

Regulations: 10 CFR 39.13, 10 CFR 39.15, 10 CFR 39.35, 10 CFR 39.37, 10 CFR 39.39, 

10 CFR 39.41, 10 CFR 39.51, 10 CFR 39.53, 10 CFR 39.63, 10 CFR 39.77 
69 

Criteria: Energy compensation sources (ECSs) used in well logging operations are small 

sealed sources each containing less than or equal to 3.7 MBq (100 microcuries) of byproduct 

material. ECSs are used as reference or calibration standards for stabilizing and calibrating 

conventional, LWD, or MWD well logging tools.

Discussion: ECSs are not considered well logging sealed sources and are not required to 

satisfy the requirement for well logging sealed sources. As a result, ECSs are: 

 exempt from leak testing requirements if the ECS contains less than or equal to 3.7 MBq 

(100 microcuries) each; however, sealed sources greater than 3.7 MBq (100 

microcuries) that are used for calibration of well logging tools are not exempt from leak 

testing requirements and must be tested at intervals not to exceed 3 years. 

 exempt from abandonment requirements described in 10 CFR 39.77, “Notification of 

incidents and lost sources; abandonment procedures for irretrievable sources,” when 

only ECSs less than or equal to 3.7 MBq (100 microcuries) remain in the abandoned tool 

in a well with surface casing for protecting freshwater aquifers; however, for wells 

without surface casings, the abandonment requirements of 10 CFR 39.77 and 

10 CFR 39.53, “Energy compensation source,” apply to ECSs less than or equal to 3.7 

MBq (100 microcuries). Abandonment requirements are also discussed in Section 

8.10.1 of this NUREG. 

 exempt from the design and performance criteria for well logging sources as described 

in 10 CFR 39.41. 

 exempt from the monitoring requirements during source recovery operations when only 

ECSs less than or equal to 3.7 MBq (100 microcuries) remain in a well logging tool that 

is lodged in a well with a surface casing; however, in wells without a surface casing to 

protect freshwater aquifers, see 10 CFR 39.53 for applicable requirements. 

 not exempt from the requirements to conduct a physical inventory and to maintain 

records of use. Requirements established in other parts of NRC regulations (e.g., 

10 CFR Part 20, 10 CFR Part 30) are still applicable to possession and use of byproduct 

material contained in ECSs. 
70 

.005” TI Window x .348” DIA.

1556-018.ppt

041300

Outer Capsule

Outer Plug

Inner Plug

Inner Capsule

.288” DIA.

Active Element

.005” TI Window x .403” DIA.

.403” O.D.

E.B. Weld

.253”

ANSI

43333

Special Form 

Material

.005” TI Window x .348” DIA.

1556-018.ppt

041300

Outer Capsule

Outer Plug

Inner Plug

Inner Capsule

.288” DIA.

Active Element

.005” TI Window x .403” DIA.

.403” O.D.

E.B. Weld

.253”

ANSI

43333

Special Form 

Material

Outer Capsule

Outer Plug

Inner Plug

Inner Capsule

.288” DIA.

Active Element

.005” TI Window x .403” DIA.

.403” O.D.

E.B. Weld

.253”

ANSI

43333

Special Form 

Material

Figure 8.14 Singly encapsulated ECS sealed source 

Response from Applicant: 

 Submit Step-By-Step Operating and Emergency Procedures for using and handling 

ECSs. Include, among other aspects, instructions for testing ECSs requiring leak tests 

at intervals not to exceed 3 years, instructions for conducting physical inventories of 

ECSs at least every 6 months, a record system for maintaining inventory records 

required by 10 CFR 39.37, “Physical Inventory,” and a record system for maintaining 

records of use for ECSs. 

8.10.12.4 Use of Sealed Sources and/or Neutron Generators in Freshwater Aquifers 

Regulations: 10 CFR 39.55, 10 CFR 39.63 

Criteria: The licensee is prohibited from using sealed sources or neutron generators in 

freshwater aquifers unless the licensee requests and receives written permission from the NRC. 

Discussion: Use of radioactive materials in freshwater aquifers is a prohibited activity unless 

specifically authorized by the NRC. Authorization to use sealed sources or neutron generators 

in freshwater aquifers requires that operating and emergency procedures include the following 

pre-logging instructions, at a minimum:: 

 obtain specific knowledge of the borehole conditions from the drilling team or company 

 run a caliper log to show the hole is open or to find problem area
71 

 run a tool without a radioactive source to show it can be freely removed 

 place a temporary casing in sections of the hole giving problems 

Response from Applicant: 

State that: “We will not use sealed sources and/or neutron generators for conducting well 

logging operations in freshwater aquifers.” 

OR 

Submit step-by-step operating and emergency procedures for conducting well logging activities 

using sealed sources and/or neutron generators in freshwater aquifers that meet the criteria in 

Section 8.10.12.4 of NUREG-1556, Volume 14, Revision 1; 10 CFR 39.55, “Tritium neutron 

generator target source”; and 10 CFR 39.63.

8.10.13 Subsurface Tracer Studies 

Regulations: 10 CFR 39.45, 10 CFR 51.22(c)(14)(xi) 

Discussion: The use of subsurface tracers in well logging activities may include in the injection 

of licensed radioactive tracers in: single wells; field flood studies involving secondary and 

tertiary recovery applications; and fresh water aquifers. The injection of tracers may be an 

activity that requires a licensee to prepare an environmental report, in accordance with 10 CFR 

51.50, in order for the NRC to perform an environmental assessment. Licensees wanting to 

inject licensed tracers into fresh water aquifers will need to be specifically authorized to do so by 

the NRC. 

8.10.13.1 Tracer Studies in Single Well Applications 

Regulations: 10 CFR 39.45, 10 CFR 39.63, 10 CFR 51.22. 

Criteria: Applicants must develop, implement, and maintain safety programs for the use of 

unsealed material for tracer studies in single wells.

Discussion: Applicants’ operating and emergency procedures should address the following 

items: 

 methods and occasions for conducting radiation surveys 

 methods and occasions for locking and securing tracer materials 

 personnel monitoring and the use of personnel monitoring equipment 

 transportation to temporary job sites and field stations, including the packaging and 

placing of tracer materials in vehicles, placarding of vehicles, and securing of tracer 

materials during transportation
72 

 procedures for minimizing exposure to members of the public and occupationally 

exposed individuals in the event of an accident 

 maintenance of records at field stations and temporary job sites 

 use, inspection, and maintenance of equipment (injector tools, remote handling tools, 

transportation containers, etc.) 

 procedures to be used for picking up, receiving, and opening packages containing 

radioactive material 

 decontamination of the environment, equipment, and personnel 

 notifications of proper personnel in the event of an accident 

Response from Applicant: 

State that: “We will not perform tracer studies in single well applications.” 

OR 

“We will perform tracer studies in single well applications and have submitted step-by-step 

operating and emergency procedures for conducting tracer studies in single well applications 

that meet the criteria in Section 8.10.13.1 of NUREG-1556, Volume 14, Revision 1; 

10 CFR 39.45; and 10 CFR 39.63.” 

8.10.13.2 Field Flood and Secondary Recovery Applications (Tracer Studies in Multiple 

Wells) 

Regulations: 10 CFR 39.45, 10 CFR 39.63, 10 CFR 51.21, 10 CFR 51.22, 10 CFR 51.30, 10 

CFR 51.45, 10 CFR 51.60, 10 CFR 51.66 

Criteria: Applicants must develop, implement, and maintain safety programs for the use of 

unsealed material for tracer studies in multiple wells (field flood studies). Refer to Appendix E in 

developing step-by-step instructions for tracer personnel in performing field flood tracer studies 

for multiple wells.

For field flood study activities where licensed material is intentionally released into the 

environment, the applicant must provide an environmental report under the provisions of 10 

CFR 51.60(b)(1)(vi). The environmental report must be prepared in accordance with the 

requirements in 10 CFR 51.45, “Environmental report.” Authorizing an applicant to conduct field 

flood studies for multiple wells would require NRC’s assessment of an environmental report and 

development of an environmental assessment. 
73 

Discussion: Applicants should address the following when requesting field flood and 

secondary recovery applications: 

 agreement with well operator or owner 

 field flood study project design 

 pre-injection phase of the field flood project 

 injection phase 

 post-injection phase 

 emergency procedures 

 reporting and recordkeeping requirements 

 waste management 

 methods and occasions for conducting radiation surveys 

 methods and occasions for locking and securing tracer materials 

 personnel monitoring and the use of personnel monitoring equipment 

 transportation to temporary job sites and field stations, including the packaging and 

placing of tracer materials in vehicles, placarding of vehicles, and securing tracer 

materials during transportation 

 procedures for minimizing exposure to members of the public and occupationally 

exposed individuals in the event of an accident 

 maintenance of records at field stations and temporary job sites 

 use, inspection, and maintenance of equipment (injector tools, remote handling tools, 

transportation containers, etc.) 

 procedures to be used for picking up, receiving, and opening packages containing 

radioactive material 

 decontamination of the environment, equipment, and personnel 

 notifications of proper personnel in the event of an accident. 

See Appendix E for additional information on developing a program for conducting field flood 

studies and enhanced recovery of oil and gas wells. 
74 

Response from Applicant: 

 Statement that “Field flood studies using tracer materials will not be conducted.” 

OR 

 Statement that “Field flood studies using tracer materials will be conducted and we have 

submitted step-by-step procedures and information required in Appendix E, “Field Flood 

Studies/Enhanced Recovery of Oil and Gas Wells.” 

8.10.13.3 Tracer Studies in Freshwater Aquifers 

Regulations: 10 CFR 39.45, 10 CFR 51.21, 10 CFR 51.22, 10 CFR 51.30, 10 CFR 51.32, 10 

CFR 51.45, 10 CFR 51.60, 10 CFR 51.66

Criteria: Applicants must develop, implement, and maintain a safety program for using tracer 

materials in freshwater aquifers. Licensees may not knowingly inject licensed material into a 

freshwater aquifer unless specifically authorized to do so by the NRC.

Discussion: 

The NRC, in accordance with 10 CFR 39.45(b), prohibits the intentional injection of licensed 

tracer material into a freshwater aquifer unless the individual is specifically authorized by the 

Commission to perform this activity. 

Authorizing field flood studies where the applicant intends to intentionally inject licensed tracer 

material into a freshwater aquifer requires that an environmental report be prepared by the 

applicant in accordance with 10 CFR 51.45, “Environmental report,” and an environmental 

assessment be performed by the NRC. Field flood study applicants are charged at full cost fee 

based on the professional staff time expended as described in footnote e.3 to 10 CFR 170.31, 

“Schedule of fees for materials licenses and other regulatory services, including inspections, 

and import and export licenses.” Individuals planning activities of this nature should contact the 

NRC well in advance of scheduled use. 

Note: The NRC’s completion of an environmental assessment, based on the level of 

complexity, can require several months to review, approve, and publish the results of the 

assessment in the Federal Register. 

Response from Applicant: 

 State that: “We will not knowingly inject tracer material into a freshwater aquifer.” 

OR 

 “We request authorization to inject tracer material into a freshwater aquifer and have 

submitted our reasons for performing the study and procedures to safeguard the public, 

licensee personnel, and the environment, and have provided an environmental report 

containing the information outlined in 10 CFR 51.45.” 
75 

8.10.14 Radioactive Collar and Subsidence or Depth Control Markers 

Regulations: 10 CFR 30.71, 10 CFR 39.47, 10 CFR 39.37 

Criteria: Radioactive markers usually used as pipe collar markers include wires, tape, nails, 

etc. Applicants can use radioactive markers only where each individual marker contains 

quantities of licensed material not exceeding the quantities identified in 10 CFR 30.71, 

“Schedule B.” Radioactive markers must be physically inventoried semi-annually as specified in 

10 CFR 39.37. 

Discussion: Operating and emergency procedures must include a commitment that 

radioactive markers can be used only where each individual marker contains quantities of 

licensed material not exceeding the quantities identified in 10 CFR 30.71. However, licensees 

are not restricted to using only one marker, and may use multiple markers in each pipe joint, 

provided each individual marker (wires, tape, nails, etc.) is not greater than the quantities 

identified in 10 CFR 30.71. Additionally, provisions must be included in the operating and 

emergency procedures to ensure that radioactive markers undergo physical inventories semiannually, as specified in 10 CFR 39.37. 

Note: Subsidence or depth control markers that use quantities greater than those authorized by 

10 CFR 39.47, “Radioactive markers,” must be approved or registered by the NRC or an 

Agreement State in an SSD registration certificate. 

Response from Applicant:

State that: “We will only use radioactive markers where each individual marker contains only 

quantities of licensed material not exceeding the quantities identified in 10 CFR 30.71, Schedule 

B.” 

 

8.10.15 Neutron Accelerators Using Licensed Material 

Regulations: 10 CFR 20.1001(b), 10 CFR 20.1301, 10 CFR 20.1302, 10 CFR 20.1601, 

10 CFR 20.1602, 10 CFR 39.55.

Criteria: Applicants authorized to use a neutron generator (particle accelerator) containing a 

tritium source should include operating and emergency procedures for the proper handling and 

use of the accelerator targets or tubes containing radioactive materials. Because the neutron 

radiation produced from particle accelerators containing byproduct materials is categorized as 

machine-produced radiation, the radiation being emitted from a neutron accelerator is subject to 

individual State, not NRC, regulatory authority. However, the dose received by an individual 

from machine-produced radiation is additive to the dose received from NRC-regulated materials 

when assessing total occupational dose to an individual in accordance with 10 CFR 20.1001(b). 

Therefore, the potential dose that an occupational worker can receive from this type of activity is 

regulated by the NRC. Applicants proposing to use neutron generators in Agreement State 

jurisdiction should contact the appropriate State for additional information.
76 

Discussion: Neutron generators (accelerators) are used in the well logging industry as a 

source of neutrons. Most accelerators use tritium gas sealed in a glass tube or plated on a 

target or disc. Neutron generator target sources, in most instances, contain less than 110 GBq 

(30 curies) of tritium.

Neutron generator tubes are not considered well logging sealed sources and are not required to 

satisfy the requirement for well logging sealed sources. As a result, neutron generator tubes 

containing less than 110 GBq (30 curies) of tritium are exempt from: 

 abandonment requirements 

 leak test requirements 

 the performance requirements of sealed sources used in well logging operations 

Neutron generator tubes: (1) containing greater than 1,110 GBq (30 curies) of tritium; or (2) that 

are used in a well without surface casing to protect freshwater aquifers, are subject to the 

requirements of 10 CFR Part 39, except 39.41. 

Neutron accelerators (particle accelerator) generate about 14 MeV neutrons when high voltage 

is applied to the generator. In addition, short-lived activation products are formed when the 

neutrons being produced by the accelerator interact with the metallic components of the 

generator. Applicants using a neutron generator must include operating and emergency 

procedures that address prevention of exposure to radiation emitted from short-lived neutron 

activation products, and procedures that address contamination. Specifically, the procedures 

should: 

 State that the high voltage being applied to the generator must be turned off at a certain 

depth before the generator is brought to the surface, and that the generator must remain 

downhole for a specific amount of time, as specified by the manufacturer, to allow for the 

decay of short-lived activated products. 

 Instruct individuals in the handling of contamination resulting from the routine use, initial 

installation, replacement, or accidental damage of the targets or glass tubes. 

 State the methods and occasions for conducting radiation surveys. 

Applicants requesting to use neutron generators must state if the generators are going to be 

calibrated by an NRC or Agreement State licensee who is specifically authorized to conduct this 

type of activity. If the applicant desires to conduct calibration of neutron generators, procedures 

describing facilities, specialized equipment and tools, and personnel training specific for this 

type of activity must be submitted for the NRC review. 

Applicants should refer to 10 CFR 39.55, “Tritium neutron generator target source,” for 

applicable requirements for using neutron generators.
77 

Response from Applicant: 

 State that: “We will not use neutron generators (accelerators) in our well logging 

operations.” 

OR 

 State that: “We will use neutron generators (accelerators) in accordance with the criteria 

in Section 8.10.15 of NUREG-1556, Volume 14, Revision 1, and will provide step-bystep operating and emergency procedures for NRC review. Calibration of neutron 

generators will be performed by an NRC or Agreement State licensee that is specifically 

authorized to conduct this activity.” 

OR 

 State that: “We will use neutron generators (accelerators) in accordance with the criteria in 

Section 8.10.15 of NUREG-1556, Volume 14, Revision 1, and will provide step-by-step 

operating and emergency procedures for NRC review. We will perform calibration of 

neutron generators and step-by-step procedures for conducting calibration of neutron 

generators that are submitted for NRC review.” 

8.10.16 Depleted Uranium Sinker Bars 

Regulations: 10 CFR 39.37, 10 CFR 39.43(b), 10 CFR 39.49, 10 CFR 39.67, 10 CFR 40.25, 

10 CFR 40.51 

Criteria: Depleted uranium sinker bars may be distributed under either a general license or a 

specific license. Most well logging licensees acquire depleted uranium sinker bars under the 

provisions of 10 CFR 40.25, “General license for use of certain industrial products or devices,” 

and then file Form NRC 244, “Registration Certificate—Use of Depleted Uranium under General 

License.” Specifically licensed material must be physically inventoried and visually inspected for 

labeling and physical damage.

Discussion: Depleted Uranium Sinker Bars Authorized Under General License: 

Certain devices are authorized by the NRC for distribution to persons who are generally 

licensed for the use of certain industrial products or devices containing depleted uranium for the 

purpose of providing a concentrated mass in a small volume. Uranium sinker bar devices can 

be acquired by the users under the provisions of 10 CFR 40.25 without obtaining a specific 

license from the NRC; however, when acquired under the provisions of a general license, 

individuals must file Form NRC 244. Generally licensed sinker bars are exempt from 

10 CFR Parts 19, 20, and 21. Regulatory requirements that apply to such devices possessed 

under a general license are stated in 10 CFR 40.25. While operating under the provision of a 

general license for these types of devices, general licensees must: 

 not introduce uranium sinker bars into a chemical, physical, or metallurgical treatment or 

process, except as a treatment for restoration of any plating or covering 

 not abandon uranium sinker bars 
78 

 transfer only to individuals authorized under the provisions of 10 CFR 40.51, “Transfer of 

source or byproduct material” 

 notify NRC within 30 days of the transfer of depleted uranium sinker bars 

Depleted Uranium Sinker Bars Authorized under a Specific License: 

While operating under the provision of a specific license for these types of devices, specific 

licensees must: 

 Physically inventory the uranium sinker bars at intervals not to exceed 6 months. 

 Visually inspect before use for proper labeling, “CAUTION—RADIOACTIVE DEPLETED 

URANIUM” and “NOTIFY CIVIL AUTHORITIES (or COMPANY NAME) IF FOUND,” and 

at intervals not to exceed 6 months. 

 Visually inspect for physical damage and conduct routine maintenance at intervals not to 

exceed 6 months. 

 Remove bars from use if found defective, until repaired or disposed. 

 If defects are found record date, equipment, inspection and maintenance performed, 

defects found, and actions take to correct the defect. Records must be retained for 

3 years. 

Response from Applicant: 

 State that: “We will not use depleted uranium sinker bars in our well logging operations.” 

OR 

 State that: “Depleted uranium sinker bars will be obtained under the provisions of a 

general license per 10 CFR 40.51, and registration form NRC Form 244 will be filed, as 

required.” 

AND/OR 

 State that: “Depleted uranium sinker bars will be obtained under a specific license, 

specify the number of kilograms of material requested.” 

AND 

 State that: “Uranium sinker bars will be possessed and inspected as specified in Section 

8.10.16 in NUREG-1556, Volume 14, Revision 1.” 
79 

8.10.17 Security Program for Category 1 and Category 2 Materials 

Regulations: 10 CFR 20.2207, 10 CFR Part 37 

Criteria: Licensees must ensure the security and control of licensed material. 

Note: The requirements in 10 CFR 20.2207 are only applicable to those licensees that 

manufacture, transfer, receive, disassemble, or dispose of Category 1 and Category 2 sources., 

as specified in Appendix E to 10 CFR Part 20 . The regulations in 10 CFR Part 37, “Physical 

Protection of Category 1 and Category 2 Quantities of Radioactive Material,” apply to licensees 

that possess an aggregate amount of category 1 or category 2 quantity of radioactive material., 

as specified in Appendix A to 10 CFR Part 37. 

Discussion: The regulations in 10 CFR 20.2207 require that each licensee that manufactures, 

transfers, receives, disassembles, or disposes of a nationally tracked source shall complete and 

submit an NSTS report. The NSTS is a major security initiative of the NRC. The NSTS is a 

secure, accessible and easy-to-use computer system that tracks high-risk radioactive sources 

from the time they are manufactured or imported through the time of their disposal or export, or 

until they decay enough to no longer be of concern. 

In accordance with 10 CFR Part 37, “Physical Protection of Category 1 and Category 2 

Quantities of Radioactive Material,” licensees authorized to possess Category 1 or Category 2 

quantities of radioactive material must establish, implement, and maintain a security program to 

ensure physical protection of the radioactive material. For additional guidance implementing 

10 CFR Part 37 requirements, see NUREG-2155, “Implementation Guidance for 10 CFR Part 

37, “Physical Protection of Category 1 and Category 2 Quantities of Radioactive Material.” 

Table 1 of Appendix A, “Category 1 and Category 2 Radioactive Materials,” to 10 CFR Part 37 

lists Category 1 and 2 threshold quantities of radioactive material. The applicant should refer to 

this table to determine if its program exceeds the Category 1 or Category 2 authorization 

thresholds. 

If licensees possess, ship, or receive quantities of material exceeding Category 1, then they 

must also comply with requirements specific to Category 1 quantities. Refer to 10 CFR Part 37 

for these additional requirements. 

Per 10 CFR Part 37, Subpart B, licensees must establish an access authorization program to 

ensure that individuals who have unescorted access to Category 1 and 2 quantities of 

radioactive material and reviewing officials are trustworthy and reliable. 

Per 10 CFR Part 37, Subpart C, licensees must establish a physical protection program to 

monitor and, without delay, detect, assess, and respond to any actual or attempted 

unauthorized access to Category 1 or Category 2 quantities of radioactive material in use or 

storage. 

Per 10 CFR Part 37, Subpart D, licensees must provide for physical protection of Category 1 or 

Category 2 quantity of radioactive materials in transit. These requirements apply to a person 

delivering material to a carrier for transport, as well as cases in which the person transports 

material. 
80 

Note: Refer to 10 CFR Part 37 and associated guidance in NUREG-2155 for additional details 

on security guidance. 

Response from Applicant: 

No response is required from an applicant or licensee that would become newly subject to 

10 CFR Part 37. 

8.11 Item 11: Waste Management 

Regulations: 10 CFR 20.1904, 10 CFR 20.2001, 10 CFR 20.2002, 10 CFR 20.2003, 

10 CFR 20.2004, 10 CFR 20.2005, 10 CFR 20.2006, 10 CFR 20.2007, 10 CFR 20.2108, 

10 CFR 30.41, 10 CFR 30.51.

Criteria: Radioactive waste must be disposed of in accordance with regulatory requirements 

and license conditions or transferred to an authorized recipient. Authorized recipients are the 

original manufacturer, distributor, a commercial firm licensed by the NRC or an Agreement State 

to accept radioactive waste from other persons, or in the case of sealed sources, transferred to 

another specific licensee authorized to possess the licensed material (i.e., a transferees’ license 

specifically authorizes the same radionuclide, chemical or physical form, and in most instances, 

the same use). Records of transfer and waste disposal must be maintained.

Before transferring any radioactive material, including radioactive waste, a licensee must verify 

that the recipient is properly authorized to receive the specific type of material using one of the 

methods described in 10 CFR 30.41, “Transfer of byproduct material.” In addition, all packages 

containing radioactive waste must be prepared and shipped in accordance with NRC and DOT 

regulations. Records of transfer and disposal must be maintained as required by 10 CFR 30.51, 

“Records.” 

Discussion: Radioactive waste generated when conducting licensed activities may include: 

sealed sources, used or unused radioactive tracer materials, and unusable items contaminated 

with radioactive tracer materials (e.g., absorbent paper, gloves, bottles).

Unsealed radioactive waste must be stored in strong, tight containers (e.g., thick plastic bags, 

boxes, barrels) to prevent the spread of contamination, and sealed sources should be stored in 

their corresponding transport containers or in a downhole storage bunker until their disposal. 

The integrity of the radioactive waste containers must be assured, and the containers, while in 

storage, must have the appropriate warning label specified in 10 CFR Part 20. Radioactive 

waste must be secured against unauthorized access or removal. Depending on the radioactive 

half-life of the material, the NRC requires disposal of well logging sealed sources and tracer 

materials generated at licensees’ facilities by one or more of the following methods: 

Tracer Material with a Half-Life of 120 Days or Less: 

 decay-in-storage (DIS) 

 transfer to an authorized recipient 

 release into sanitary sewerage 

 release in effluents to unrestricted areas, other than into sanitary sewerage 

 incineration 

 any alternate method specifically approved by the NRC 
81 

Tracer Material with a Half-Life Greater Than 120 Days: 

 transfer to an authorized recipient 

 release into sanitary sewerage 

 release in effluents to unrestricted areas, other than into sanitary sewerage 

 incineration. 

 any alternate method specifically approved by the NRC 

Sealed Sources with a Half-Life of 120 Days or Less: 

 transfer to an authorized recipient 

 DIS 

Sealed Sources with a Half-Life Greater Than 120 Days: 

 transfer to an authorized recipient. 

 ensure there is a current leak test prior to transfer to an authorized recipient 

Licensees may choose any one or more of these methods to dispose of their radioactive waste. 

The NRC’s experience indicates that most well logging tracers are stored or disposed of by a 

combination of methods, transfer to an authorized recipient and DIS being the most frequently 

used. Applicants requesting authorization to dispose of radioactive tracer waste by incineration 

should first refer to model waste management procedures in NUREG-1556, Volume 11 and 

contact the appropriate Regional Office of the NRC for guidance. Applicants should note that 

compliance with NRC regulations does not relieve them of their responsibility to comply with any 

other applicable Federal, State, or local regulations. Some types of radioactive waste used in 

tracer operations and in “labeled frac sands” may include additional chemical hazards. This 

type of waste is designated as “mixed waste” and requires special handling and disposal. 

Applicants should describe in detail their program for management and disposal of radioactive 

waste, including mixed waste, if applicable. A waste management program should include 

procedures for handling waste; specify the requirements for safe and secure storage; and 

describe how to characterize, minimize, and dispose of all types of radioactive waste, including, 

where applicable, mixed waste. Appropriate training should be provided to waste handlers. 

Regulation 10 CFR 30.51 requires, in part, that licensees maintain all appropriate records of 

disposal of radioactive waste. The U.S. Environmental Protection Agency (EPA) issued 

guidance for developing a comprehensive program to reduce hazardous waste that, in many 

instances, may also include radioactive waste as a contaminant. The NRC transmitted these 

guidelines to licensees in IN 94-23, “Guidance to Hazardous, Radioactive, and Mixed Waste 

Generators on the Elements of a Waste Minimization Program,” dated March 1994. 

Disposal by Decay-in-Storage (DIS) 

The NRC has concluded that materials with half-lives of less than or equal to 120 days are 

appropriate for DIS. The minimum holding period for decay is ten half-lives of the longest-lived 

radionuclide in the waste with a half-life of 120 days or less. Such waste may be disposed of as 

ordinary trash if radiation surveys (performed in a low background area and without any 

interposed shielding) of the waste at the end of the holding period indicate that radiation levels 
82 

are indistinguishable from background. All radiation labels must be defaced or removed from 

containers and packages prior to disposal as ordinary trash. If the decayed waste is 

compacted, all labels that are visible in the compacted mass must also be defaced or removed. 

Applicants should assure that adequate space and facilities are available for the storage of such 

waste. Licensees can minimize the need for storage space if the waste is segregated according 

to half-life. Waste containing radionuclides with half-lives 120 days or less may be segregated 

and stored in a container and allowed to decay for at least ten half-lives based on the longestlived radionuclide in the container. Waste management procedures should include: (a) 

methods of segregating waste by half-lives of 120 days or less, greater than 120 days; (b) 

methods of surveying waste prior to disposal to confirm that waste above background levels is 

not inadvertently released; and (c) maintenance of records of disposal. Disposal records for 

DIS should include the date when the waste was put in storage for decay, date when ten halflives of the longest-lived radionuclide had transpired, date of disposal, and results of the final 

survey taken prior to disposal to ordinary trash. Additionally, a model procedure for disposal of 

radioactive waste by DIS, which incorporates the above guidelines, is provided in Appendix O. 

Release into Sanitary Sewerage

10 CFR 20.2003, “Disposal by release into sanitary sewerage,” authorizes disposal of 

radioactive waste by release into sanitary sewerage if each of the following conditions is met: 

 Material is readily soluble (or is easily dispersible biological material) in water 

 Quantity of licensed material that the licensee releases into the sewer each month 

averaged over the monthly volume of water released into the sewer does not exceed the 

concentration specified in 10 CFR Part 20, Appendix B, Table 3 

 If more than one radionuclide is released, use the sum of the ratios between the monthly 

discharge of a radionuclide and the corresponding limit in 10 CFR Part 20, Appendix B, 

Table 3 

 The sum of such rations for all of the radionuclides in a mixture may not exceed “1” (i.e. 

unity) 

 Total quantity of licensed material released into the sanitary sewerage system in a year 

does not exceed 185 GBq (5 Ci) of H-3, 37 GBq (1 Ci) of C-14, and 37 GBq (1 Ci) of all 

other radionuclides combined. 

Licensees are responsible for demonstrating that licensed materials discharged into the 

sewerage system are indeed readily dispersible in water. NRC IN 94-07, “Solubility Criteria for 

Liquid Effluent Releases to Sanitary Sewerage under the Revised 10 CFR 20,” dated January 

1994, provides the criteria for evaluating solubility of liquid waste. Careful consideration should 

be given to the possibility of reconcentration of radionuclides that are released into the sewer. 

NRC alerted licensees to the potentially significant problem of reconcentration of radionuclides 

released to sanitary sewerage systems in IN 84-94, “Reconcentration of Radionuclides Involving 

Discharges into Sanitary Sewerage Systems Permitted under 10 CFR 20.303 (now 

10 CFR 20.2003),” dated December 1984. 
83 

Applicants electing to use this type of disposal should provide procedures that will ensure that 

all releases of radioactive waste into the sanitary sewerage meet the criteria stated in 

10 CFR 20.2003 and do not exceed the monthly and annual limits specified in regulations. 

Licensees are required to maintain accurate records of all releases of licensed material into the 

sanitary sewerage. A model program for disposal of radioactive waste via sanitary sewer is 

described in Appendix O. 

Note: Regulations in 10 CFR Part 20 prohibit the disposal of radioactive materials via a 

sewage treatment facility, septic system, or leach field owned or operated by the licensee. 

Transfer to an Authorized Recipient Licensees may transfer radioactive waste to an 

authorized recipient for disposal. However, it is the licensee’s responsibility to verify that the 

intended recipient is authorized to receive the radioactive waste prior to making any shipment. 

Waste generated at well logging and tracer facilities generally consists of low specific activity 

(LSA) material. The waste must be packaged in DOT-approved containers for shipment, and 

each container must identify the radionuclides and the amounts contained in the waste. 

Additionally, packages must comply with the requirements of the particular burial site’s license 

and State requirements. Each shipment must comply with all applicable NRC and DOT 

requirements. In some cases, the waste handling contractor may provide additional guidance 

and requirements to licensees for packaging and transportation; however, the licensee is 

ultimately responsible for ensuring compliance with all applicable regulatory requirements. 

The shipper must provide all information required in the NRC’s Uniform Low-Level Radioactive 

Waste Manifest and transfer this recorded manifest information to the intended recipient. Each 

shipment manifest must include a certification by the waste generator. Each person involved in 

the transfer for disposal and disposal of waste, including waste generator, waste collector, 

waste processor, and disposal facility operator, must comply with the NRC’s Uniform Low-Level 

Radioactive Waste Manifest. 

Licensees should implement procedures to reduce the volume of radioactive waste for final 

disposal in an authorized low-level radioactive waste (LLW) disposal facility. These procedures 

include volume reduction by segregating, consolidating, compacting, or allowing certain waste 

to decay in storage. Waste compaction or other treatments can reduce the volume of 

radioactive waste, but such processes may pose additional radiological hazards (e.g., airborne 

radioactivity) to workers and members of the public. The program should include adequate 

safety procedures to protect workers, members of the public, and the environment. 

Applicants may request alternate methods for the disposal of radioactive waste generated at 

their facilities. Such requests will be handled on a case-by-case basis and require that the 

applicant provide additional site-specific information. In most instances, requests for alternate 

methods of disposal must describe the types and quantities of waste containing licensed 

material, physical and chemical properties of the waste that may be important to making a 

radiological risk assessment, and the proposed manner and conditions of waste disposal. 

Additionally, the applicant must submit its analysis and evaluation of pertinent information 

specific to the affected environment, including the nature and location of other affected facilities, 

and provide an outline of its procedures to ensure that radiation doses are maintained ALARA 

and within regulatory limits.
84 

Because of the difficulties and costs associated with disposal of sealed sources, e.g., sealed 

sources containing americium-241, applicants should preplan disposal. Applicants may want 

to consider contractual arrangements with the source supplier as part of a purchase 

agreement. 

Response from Applicant:

A statement that: 

 “We will use sealed and/or unsealed radioactive materials with a half life greater than 

120 days, and will transfer or dispose of the material and/or contaminated waste to a 

licensed entity authorized to receive the material.” 

AND 

 “We will use the model waste procedures published in Appendix O to NUREG-1556, 

Volume 14, Revision 1, ‘Program-Specific Guidance about Well Logging, Tracer, and 

Field Flood Study Licenses’ for disposing of radioactive materials and/or contaminated 

waste.” 

OR 

 “We have provided our procedures for waste collection, storage, and disposal by any of 

the authorized methods described in this section.” 

References: Search the NRC’s public Web site at http://www.nrc.gov to obtain copies of: 

(1) Information Notice (IN) 94-23, “Guidance to Hazardous, Radioactive, and Mixed Waste 

Generators on the Elements of a Waste Minimization Program,” dated May 1994 

(2) IN 94-07, “Solubility Criteria for Liquid Effluent Releases to Sanitary Sewerage under the 

Revised 10 CFR 20,” issued January 1994 

(3) IN 84-94, “Reconcentration of Radionuclides Involving Discharges into Sanitary 

Sewerage Systems Permitted under 10 CFR 20.203 (now 10 CFR 20.2003),” issued 

December 1984 

The next two items on NRC Form 313 should be completed on the form itself. 

8.12 Item 12: License Fees 

On NRC Form 313, enter the appropriate fee category from 10 CFR 170.31 and the amount of 

the fee enclosed with the application. 

Direct all questions about the NRC’s fees or completion of Item 12 of NRC Form 313 to the 

Office of the Chief Financial Officer at NRC Headquarters in Rockville, MD, 301-415-7554. 

Information about fees may also be obtained by calling NRC’s toll free number, (800) 368-5642, 

extension 415-7554. The e-mail address for fees questions is Fees.Resource@nrc.gov. 
85 

Note: Applicants who wish to perform field flood tracer studies should review 10 CFR Part 51, 

“Environmental Protection Regulations for Domestic Licensing and Related Regulatory 

Functions” (particularly 10 CFR 51.30, 51.60, and 51.66) for further information concerning the 

environmental information needed by the NRC to prepare an environmental assessment. 

Environmental assessments are full-cost recovery items under 10 CFR Part 170. Full cost will 

be determined based on the professional staff time expended multiplied by the appropriate 

professional hourly rate, as described in footnote e.3. to 10 CFR 170.31, “Schedule of Fees for 

Materials Licenses and Other Regulatory Services, Including Inspections, and Import and 

Export Licenses.” 

8.13 Item 13: Certification 

A representative of the corporation or legal entity filing the application must sign and date NRC 

Form 313. The representative signing the application must be authorized to make binding 

commitments and to sign official documents on behalf of the applicant. As discussed previously 

in Chapter 3, “Management Responsibility,” signing the application acknowledges 

management’s commitment to and responsibility for the radiation protection program. The NRC 

will return all unsigned applications for proper signature. 

Notes: 

 It is a criminal offense to make a willful false statement or representation on applications 

or correspondence (18 U.S.C. 1001). 

 When the application references commitments, those items become binding and are part 

 of the license conditions and regulatory requirements. 

87 

9. AMENDMENTS AND RENEWALS TO A LICENSE 

It is the licensee’s obligation to keep the license current. If any of the information provided in 

the original application is to be modified or changed, the licensee must submit an application for 

a license amendment before the change takes place. The change is not in effect until the 

amendment has been issued. Also, to continue the license after its expiration date, the licensee 

must submit an application for a license renewal at least 30 days before the expiration date 

(10 CFR 2.109(a), 10 CFR 30.36(a)). 

Applicants for license amendment or renewal should do the following: 

 Use the most recent guidance in preparing an amendment or renewal request. 

 Submit either an NRC Form 313 or a letter requesting amendment or renewal. 

 Provide the license number and docket number. 

 For renewals, provide a complete and up-to-date application if many outdated 

documents are referenced or there have been significant changes in regulatory 

requirements, the NRC’s guidance, the licensee’s organization, or the licensee’s 

radiation protection program. Alternatively, describe clearly the exact nature of the 

changes, additions, and deletions. 

9.1 Timely Notification of Transfer of Control 

Regulation: 10 CFR 30.34(b) 

Criteria: Licensees must provide full information and obtain the NRC’s prior, written consent

before transferring control of the license, or, as some licensees call it, “change of ownership” 

and/or “transferring the license.” 

Discussion: Transferring control may be the result of mergers, buyouts, or majority stock 

transfers. Although it is not the NRC’s intent to interfere with the business decisions of 

licensees, it is necessary for licensees to obtain prior NRC written consent to ensure the 

following: 

 Radioactive materials are possessed, used, or controlled only by persons who have 

valid NRC licenses or Agreement State licenses. 

 Materials are properly handled and secured. 

 Persons using these materials are competent and committed to implementing 

appropriate radiological controls. 

 A clear chain of custody is established to identify who is responsible for disposition of 

records and licensed material. 

 Public health and safety are not compromised by the use of such materials.
88 

Response from Applicant: No response is required from an applicant for a new license. 

However, current licensees should refer to NUREG-1556, Volume 15, for more information 

about transfer of ownership. 
89 

10. APPLICATIONS FOR EXEMPTIONS 

Regulations: 10 CFR 19.31, 10 CFR 20.2301, 10 CFR 30.11, 10 CFR 39.91 

Criteria: Licensees may request exemptions from regulations. The licensee must demonstrate 

that the exemption is authorized by law; will not endanger life, property, or the common defense 

and security; and is otherwise in the public interest. 

Discussion: Various sections of the NRC’s regulations address requests for exemptions 

(e.g., 10 CFR 19.31, “Application for exemptions”; 10 CFR 20.2301, “Applications for 

exemptions”; 10 CFR 30.11, “Specific exemptions”; and 10 CFR 39.91 “Applications for 

exemptions”). These regulations state that the NRC may grant an exemption, acting on its own 

initiative or on an application from an interested person. 

Exemptions are not intended to revise regulations or apply to large classes of licensees and are 

generally limited to unique situations. Exemption requests must be accompanied by 

descriptions of the following: 

 Exemption requested and justification for the requested exemption. 

 Proposed compensatory safety measures intended to provide a level of health and 

safety equivalent to the regulation for which the exemption is being requested. 

 Alternative methods for complying with the regulation and an explanation of why 

compliance with the existing regulation is not feasible. 

Until the NRC has granted an exemption in writing, licensees must comply with all applicable 

regulations. 

91 

11. TERMINATION OF ACTIVITIES 

Regulations: 10 CFR 30.34(b), 10 CFR 30.35(g), 10 CFR 30.36(d), 10 CFR 30.36(j)(1), 

10 CFR 30.51(f), 10 CFR 30.36(g), 10 CFR 30.36(h) 

Criteria: The licensee must do the following: 

 Notify the NRC, in writing, within 60 days of the occurrence of any of the following: 

– Expiration of its license. 

– A decision to permanently cease licensed activities at the entire site. 

– A decision to permanently cease licensed activities in any separate building or 

outdoor area that contains residual radioactivity such that the building or area is 

unsuitable for release in accordance with NRC requirements. 

– No principal activities having been conducted at the entire site under the license 

 for a period of 24 months. 

– No principal activities have been conducted for a period of 24 months in any 

 separate building or outdoor area that contains residual radioactivity such that 

 the building or area is unsuitable for release according to NRC requirements. 

 Submit a decommissioning plan, if required by 10 CFR 30.36(g). 

 Conduct decommissioning, as required by 10 CFR 30.36(h) and 10 CFR 30.36(j). 

 Submit to the appropriate NRC regional office a completed NRC Form 314, “Certificate 

of Disposition of Materials” (or equivalent information), and a demonstration that the 

premises are suitable for release for unrestricted use (e.g., results of final survey). 

 Before a license is terminated, send the records important to decommissioning to the 

appropriate NRC regional office. If licensed activities are transferred or assigned in 

accordance with 10 CFR 30.34(b), transfer records important to decommissioning to the 

new licensee in accordance with 10 CFR 30.35(g). 

Discussion: To comply with the above criteria, before a licensee can decide whether it must 

notify the NRC, the licensee must determine whether residual radioactivity is present and, if so, 

whether the levels make the building or outdoor area unsuitable for release, according to NRC 

requirements. A licensee’s determination that a facility is not contaminated is subject to 

verification by NRC inspection. 

For guidance on the disposition of licensed material, see Section 8.11 “Waste Management.” 

For guidance on decommissioning records, see Section 8.5.3, “Financial Assurance and 

Recordkeeping for Decommissioning.” 

The permanent cessation of principal activities in an individual room or laboratory may require 

the licensee to notify the NRC if no other licensed activities are being performed in the building. 
92 

The applicant should contact their NRC regional office for additional guidance beyond the scope 

of this document. 

NUREG-1757, Volume 1, Revision 2, “Consolidated Decommissioning Guidance: 

Decommissioning Process for Materials Licensees” contains the current guidance concerning 

decommissioning of facilities and termination of licenses. This document takes a risk-informed, 

performance-based approach to the information needed to support an application for 

decommissioning a materials license and compliance with the radiological criteria for license 

termination in 10 CFR Part 20, Subpart E. NUREG-1575, “Multi-Agency Radiation Survey and 

Site Investigation Manual (MARSSIM),” should be reviewed by licensees who have large 

facilities to decommission. An acceptable method for calculating screening values to 

demonstrate compliance with the unrestricted dose limits is the Decontamination and 

Decommissioning (DandD) screening code. 

Response from Applicant: The applicant is not required to submit a response to the NRC 

during the initial application. The licensee’s obligations in this matter begin when the license 

expires or at the time the licensee ceases operations, whichever is earlier. These obligations 

are to undertake the necessary decommissioning activities, to submit NRC Form 314 or 

equivalent information, and to perform any other actions summarized in “Criteria” above. 

Reference: NRC Form 314 is available at http://www.nrc.gov/reading-rm/doc-collections/forms
APPENDIX A 

LIST OF DOCUMENTS CONSIDERED IN DEVELOPMENT OF THIS 

NUREG

A-1 

APPENDIX A LIST OF DOCUMENTS CONSIDERED IN DEVELOPMENT OF THIS NUREG

This report incorporates and updates the guidance previously found in the NUREG reports, 

regulatory guides (RGs), information notices (INs), and technical assistance requests (TARs) 

listed below. Other U.S Nuclear Regulatory Commission (NRC) documents, such as manual 

chapters (MCs), inspection procedures (IPs), and memoranda of understanding (MOUs) also 

were consulted during the preparation of this report. When this report is issued in final form, the 

documents marked with an asterisk (*) will be considered superseded and should not be used. 

Table A.1 List of Regulatory Guides, NUREG Reports, and Policy 

 and Guidance Directives 

Document 

Identification Title Date

Regulatory Guide

RG 4.20, Rev. 1 Constraints on Release of Airborne Radioactive Materials 

to the Environment for Licensees Other Than Power 

Reactors 

4/12 

RG 8.7, Rev. 2 Instructions for Recording and Reporting Occupational 

Radiation Exposure Data 

11/05 

RG 8.25, Rev. 1 Air Sampling in the Workplace 6/92 

RG 8.34 Monitoring Criteria and Methods to Calculate Occupational 

Radiation Doses 

7/92 

RG 8.9, Rev. 1 Acceptable Concepts, Models, Equations, and 

Assumptions for a Bioassay Program 

7/93 

RG 8.37 ALARA Levels for Effluents from Materials Facilities 7/93 

RG 8.32 Criteria for Establishing a Tritium Bioassay Program 7/98 

NUREG

NUREG-1556, 

Volume 3, Rev. 1 

Applications for Sealed Source and Device Evaluation and 

Registration 

4/04 

NUREG-1556, 

Volume 15 

Guidance About Changes of Control and About Bankruptcy 

Involving Byproduct, Source, or Special Nuclear Materials 

Licenses 

11/00 

NUREG-1748 Environmental Review Guidance for Licensing Actions 

Associated with NMSS Programs 

8/03 

NUREG-1575, Rev. 1 Multi-Agency Radiation Survey and Site Investigation 

Manual (MARSSIM) 

8/00 
A-2 

Document 

Identification Title Date

NUREG-1757, 

Volume 1, Rev. 2 

Consolidated Decommissioning Guidance: 

Decommissioning Process for Materials Licensees 

9/06 

NUREG-1757, 

Volume 3, Rev. 1 

Consolidated Decommissioning Guidance: Financial 

Assurance, Recordkeeping, and Timeliness 

2/12 

NCRP or ICRP Documents

National Council on 

Radiation Protection 

and Measurements 

(NCRP) Report No. 

151 

Structural Shielding Design and Evaluation for 

Megavoltage X- and Gamma-Ray Radiotherapy Facilities 

2005 

ANSI Documents

ANSI N13.1 Sampling Airborne Radioactive Materials in Nuclear 

Facilities 

1991 

ANSI N323A-1997 Radiation Protection Instrumentation Test and 

Calibration 

1997 

ANSI/HPS N43.6-

1997 

Sealed Radioactive Sources—Classifications 1997 

Other Documents

 A Review of Department of Transportation Regulations 

for Transportation of Radioactive Materials 

The Health Physics & Radiological Health Handbook, 

Revised Edition, Edited by Bernard Shleien 

1992 

Information Notices

IN 90-09 Extended Interim Storage of Low-Level Radioactive 

Waste by Fuel Cycle and Material Licensees 

2/5/90 

IN 93-50 Extended Storage of Sealed Sources 7/8/93 

IN 89-25 (Rev. 1) Unauthorized Transfer of Ownership or Control of 

Licensed Activities 

12/7/94

IN 94-07 Solubility Criteria for Liquid Effluent Releases to Sanitary 

Sewerage Under the Revised 10 CFR 20 

1/28/94
A-3 

Document 

Identification Title Date

IN 94-23 Guidance to Hazardous, Radioactive, and Mixed Waste 

Generators on the Elements of a Waste Minimization 

Program 

3/25/94

IN 96-28 Suggested Guidance Relating to Development and 

Implementation of Corrective Action 

5/1/96 

IN 97-30 Control of Licensed Material During Reorganizations, 

Employee-Management Disagreements and Financial 

Crises 

6/3/97 

IN 04-03 Radiation Exposures to Members of the Public in 

Excess of Regulatory Limits Caused by Failures to 

Perform Appropriate Radiation Surveys During Welllogging Operations 

2/24/04

IN 07-33 Exposures to Members of the Public Caused by 

Inadequate Controls Over Well Logging Sources 

9/29/07 

Inspection Procedures

IP 87103 Inspection of Material Licensees Involved in an Incident 

or Bankruptcy Filing 

2/97 

IP 87123 Well Logging Programs 11/25/0

3 

APPENDIX B 

U.S. NUCLEAR REGULATORY COMMISSION FORM 313

B-1 

APPENDIX B U.S. NUCLEAR REGULATORY COMMISSION FORM 313 

Please use the most current version of this form, which may be found at: 

http://www.nrc.gov/reading-rm/doc-collections/forms/ 

APPENDIX C 

SUGGESTED FORMAT FOR PROVIDING INFORMATION REQUESTED 

IN ITEMS 5 THROUGH 11 OF NRC FORM 313

C-1 

APPENDIX C SUGGESTED FORMAT FOR PROVIDING INFORMATION REQUESTED IN 

ITEMS 5 THROUGH 11 OF NRC FORM 313 

Item 

No.

Title and Criteria Use Table 

Below

Description 

Attached

5 & 6 RADIOACTIVE MATERIAL 

Sealed Sources and Devices

 Identify each radionuclide that will be used in sealed sources. 

 Identify each radionuclide that will be used in energy 

compensation sources. 

 Identify each radionuclide that will be used as tracer materials in 

single wells. 

 Identify each radionuclide that will be used as tracer materials in 

field flood studies in multiple wells. 

 Identify any depleted uranium that is used as shielding material 

or sinker bars. 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 

Well Logging Sealed Sources

Radionuclide Manufacturer/ 

Model No.

Maximum activity per source and total activity requested 

(mCi or Ci)

 

 

Neutron Generators

Radionuclide Manufacturer/ 

Model No.

Maximum activity per source and total activity 

requested (mCi or Ci)

 

Energy Compensation Sources

Radionuclide Manufacturer/ 

Model No.

Maximum activity per source and total activity 

requested (mCi or Ci)

 
C-2 

Unsealed Tracer Materials

Radionuclide Chemical or Physical Form Millicuries Per 

Injection

Total Quantity 

Requested

 [ ] Gas [ ] Liquid [ ] Labeled Frac 

Sands 

 

[ ] Gas [ ] Liquid [ ] Labeled Frac 

Sands 

 [ ] Gas [ ] Liquid [ ] Labeled Frac 

Sands 

 

Note: Indicate the rate of volatility or dispersion for each unsealed tracer material. 

Depleted Uranium

Radionuclide Manufacturer/ 

Model No.

Kilograms Requested

Depleted 

Uranium (DU) 

 

Sealed Sources Not Used in Well Logging Operations

Radionuclide Manufacturer/ 

Model No.

Maximum activity per source and total activity 

requested (mCi or Ci)

Commitment: Yes N/A

Confirm that each sealed source, device, and source/device combination used is 

registered as an approved sealed source and/or device by the NRC or an Agreement 

State. 

Confirm that each sealed source, device, and source/device combination will be 

possessed and used in accordance with the conditions specified in the registration 

certificate, and will not to exceed the maximum activity per source and/or device as 

specified in the Sealed Source and Device Registration Sheet. 

 [ ] 

[ ] 

 [ ] 

[ ] 
C-3 

Item 

No.

Title and Criteria Yes N/A Description 

Attached

RADIOACTIVE MATERIAL 

Financial Assurance and Record Keeping for 

Decommissioning

 Pursuant to 10 CFR 30.35(g), we will maintain drawings and 

records important to decommissioning and transfer these 

records to a new licensee before licensed activities are 

transferred, or assign the records to the appropriate NRC 

Regional Office before the license is terminated. 

AND 

 If financial assurance is required, we will submit evidence 

following NUREG-1757, Volume 3. 

[ ] 

[ ] [ ] 

Item 

No.

Title and Criteria Yes N/A Description 

Attached

6 PURPOSE(S) FOR WHICH LICENSED MATERIAL WILL BE 

USED

 Oil and gas well logging. 

 Mineral well logging. 

 Geophysical well logging. 

 Tracer studies in single wells. 

 Field flood or enhanced recovery studies in multiple wells 

OR 

 Specify the purposes for which the sources and device(s) will be 

used other than those included in the manufacturer’s 

recommendations, and as specified on the SSD registration 

certificate. 

AND 

 State “We plan to perform the following activities in freshwater

aquifers”: 

– Tracer studies 

– Well logging using sealed sources 

– Well logging using neutron generator 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 
C-4 

Item 

No.

Title and Criteria Yes N/A Description 

Attached

7 INDIVIDUAL(S) RESPONSIBLE FOR RADIATION SAFETY 

PROGRAM AND THEIR TRAINING EXPERIENCE 

Radiation Safety Officer (RSO)

 The name of the proposed RSO and other individuals who will 

be responsible for the radiation protection program. 

Name:______________________________________ 

 Demonstrate that the RSO has sufficient independence and 

direct communication with responsible management officials by 

providing a copy of an organizational chart by position, 

demonstrating day-to-day oversight of the radiation safety 

activities. 

AND EITHER 

 Documentation demonstrating that the proposed RSO is 

qualified by training and experience (i.e., certificate of 

completion of a well logging RSO or authorized user’s course). 

OR 

 Alternative information demonstrating that the proposed RSO is 

qualified by training and experience, e.g., listed by name as an 

authorized user or the RSO on an NRC or Agreement State 

license that requires a radiation safety program of comparable 

size and scope. 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 

[ ] 
C-5 

Item 

No.

Title and Criteria Yes N/A Description 

Attached

8 TRAINING FOR LOGGING SUPERVISORS AND LOGGING 

ASSISTANTS

 Submit an outline of the training to be given to prospective 

logging supervisors and logging assistants. 

 Submit your procedures for experienced logging supervisors 

who have worked for another licensee. 

 Provide a copy of a typical examination and the correct 

answers to the examination questions. State the passing 

grade percent. 

 Specify the qualifications of your instructors. 

 If training will be conducted by someone outside the applicant’s 

organization, identify the course by title and provide the name 

and address of the company providing the training. 

 Describe the field (practical) examination that will be given to 

prospective logging supervisors and logging assistants. 

 Describe the annual refresher training program, including 

topics to be covered and how the training will be conducted. 

 Submit a description of your program for annual inspections of 

the job performance of each well logging supervisor, as 

described in 10 CFR 39.13(d). 

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C-6 

Ite

m 

No.

Title and Criteria Yes N/A Description 

Attached

9 FACILITIES AND EQUIPMENT

 Submit a diagram, drawing or sketch of the proposed facility, 

identifying areas where radioactive materials, including 

radioactive wastes, will be used or stored. Diagrams, drawings, 

or sketches should include indication of the scale, or include 

dimensions on each drawing or sketch and be marked: 

“Security-Related Information–Withhold under 10 CFR 2.390” 

as appropriate. 

 Drawings should show, where applicable, adjacent buildings, 

boundary lines, security fences, and lockable storage areas. 

 Illustrate area(s) where explosive, flammable, or other 

hazardous materials may be stored. 

 Drawings should also show the relationship and distance 

between restricted areas and adjacent unrestricted areas. 

 Drawings should specify shielding materials (concrete, lead, 

etc.) and means for securing radioactive materials from 

unauthorized removal. 

 Submit a drawing or sketch of the proposed tracer material 

storage facilities, including rooms, buildings, below ground 

bunker storage areas, or containers used for storage of both 

tracer and tracer waste materials, if appropriate. Specify the 

types and amount of shielding materials (concrete, lead, etc.) 

and means for securing tracer materials from unauthorized 

removal. 

 Describe protective clothing (such as rubber gloves, coveralls, 

respirators, and face shields), auxiliary shielding, absorbent 

materials, injection equipment, secondary containers for waste 

water storage for decontamination purposes, plastic bags for 

storing contaminated items, etc., that will be available at well 

sites when using tracer materials. 

 Describe proposed laundry facilities, if applicable, used for 

contaminated protective clothing. Specify how the 

contaminated waste water from the laundry machines or sinks 

is disposed. Operating and emergency procedures should 

address decontamination of the laundry area and equipment. 

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C-7 

Ite

m 

No.

Title and Criteria Yes N/A Description 

Attached

9 FACILITIES AND EQUIPMENT (Cont’d)

 Describe proposed decontamination facilities for trucks, tracer 

injection tools, or other equipment contaminated by tracer 

materials, if applicable. Specify how the contaminated waste 

water for these decontamination facilities is disposed. 

Operating and emergency procedures should address 

decontamination of these types of equipment and facilities. 

 Describe, if applicable, equipment for “repackaging” gaseous, 

volatile, or finely divided tracer material. Most tracer users do 

not repackage materials and acquire their injections in 

precalibrated amounts or “ready to use” forms. However, 

should an applicant request the ability to repackage tracer, 

volatile, or finely divided material, the following equipment 

should be considered when repackaging tracer materials: 

sinks, trays with absorbent material, glove boxes, fume hoods 

with charcoal filtration, filtered exhaust, special handling 

equipment including special tools, rubber gloves, etc. 

 If applicable, we will have in place a security program in 

accordance with 10 CFR Part 37 prior to possessing category 1 

or category 2 quantities of radioactive materials. 

 State the physical location where NRC regulatory required 

records will be stored and available for review during NRC 

inspections. 

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C-8 

Item 

No.

Title and Criteria Yes N/A Description 

Attached

10 RADIATION SAFETY PROGRAM

The applicant is required to establish and submit its radiation 

protection program. The format used for providing information 

should be developed by the applicant. No specific format is 

required by the NRC for submitting a radiation safety program. 

The radiation safety program should include each of the following 

items: 

 steps to keep radiation exposures ALARA 

 description of equipment and facilities adequate to protect 

personnel, the public, and the environment 

 commitment that licensed activities will be conducted by 

individuals qualified by training and experience 

 written operating and emergency procedures 

 program for the annual inspection of the job performance of 

well logging personnel 

 description of organization structure and individuals 

responsible for ensuring implementation of radiation safety 

program 

 records management 

 methods or procedures for preventing the release of 

contaminated material, equipment, or vehicles to unrestricted 

use from tracer or field flood study operations 

 radiation safety procedures and the well logging supervisors’ 

responsibilities unique to tracer and field flood study operations

 tracer and field flood study equipment, techniques, and 

corresponding radiation safety procedures associated with the 

use of tracer materials 

Appendix E includes a description of procedures for using tracer 

materials in field flood study operations. 

[ ] 

Radiation Safety Program Audit: The applicant is not required 

to, and should not, submit its audit program to the NRC for 

review during the licensing phase. The licensee’s program for 

auditing its radiation safety program will be reviewed during 

inspections. 

Need Not Be Submitted 

With Application 
C-9 

Item 

No.

Title and Criteria Yes N/A Description 

Attached

Well Owner or Operator Agreement 

We will obtain a written agreement that meets the requirements 

specified in 10 CFR 39.15, “Agreement with well owner or 

operator,” prior to well logging: (1) with a sealed source; (2) with a 

neutron generator exceeding 30 curies; or (3) with a neutron 

generator in a well without a surface casing. 

[ ] [ ] [ ] 

Instruments

 We will use instruments that meet the radiation monitoring 

instrument specifications published in Appendix I of NUREG1556, Volume 14, Revision 1, “Program-Specific Guidance 

about Well Logging, Tracer and Field Flood Studies.” A 

description of the instrumentation that will be used to perform 

required surveys is attached. We reserve the right to upgrade 

our survey instruments as necessary. Our instruments will be 

calibrated by an authorized service provider. 

OR 

 We will use instruments that meet the radiation monitoring 

instrument specifications published in Appendix I of NUREG1556, Volume 14, Revision 1, “Program-Specific Guidance 

about Well Logging, Tracer and Field Flood Studies.” A 

description of the instrumentation that will be used to perform 

required surveys is attached. We reserve the right to upgrade 

our survey instruments as necessary. 

 Additionally, we will perform instrument calibrations 

implementing the model survey meter calibration program 

published in Appendix I of NUREG-1556, Volume 14, Revision 

1, “Program-Specific Guidance about Well Logging, Tracer and 

Field Flood Studies.” 

OR 

 A description of alternative equipment and/or procedures for 

ensuring that appropriate radiation monitoring equipment will 

be used during licensed activities and that proper calibration 

and calibration frequency of survey equipment will be 

performed. We reserve the right to upgrade our survey 

instruments as necessary. 

Note: Alternative responses will be reviewed using the criteria 

listed above. 

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C-10 

Item 

No.

Title and Criteria Yes N/A Description 

Attached

10 RADIATION SAFETY PROGRAM (Cont’d)

Material Receipt and Accountability

 Physical inventories will be conducted and documented at 

intervals not to exceed 6 months, to account for all byproduct 

materials (sealed sources and tracer materials) and devices 

containing depleted uranium received and possessed under 

the license. 

AND 

 We will comply with the National Source Tracking System 

(NSTS) reporting requirement as described in 10 CFR 20.2207, 

“Reports of Transactions Involving Nationally Tracked 

Sources.”

Occupational Dosimetry

 Personnel dosimeters (e.g., film badge, TLD, or OSL) will be 

processed and evaluated by a NVLAP-accredited entity, 

exchanged at the approved frequency, and worn by well 

logging supervisors and logging assistants. 

AND/OR 

 Individual logging supervisors and logging assistants using 

more than 50 millicuries of iodine-131 at any one time or in any 

5-day period will be provided a bioassay. 

 Bioassay plan attached. 

 Individual logging supervisors and logging assistants will not 

use more than 50 millicuries of iodine-131 at any one time or in 

any 5-day period at field stations or at temporary job sites. 

 We will contract with a vendor for bioassay services and each 

vendor is licensed or otherwise authorized by the NRC or an 

Agreement State to provide required bioassay services. 

OR 

We will not allow any individual to use more than: (1) 50 millicuries 

of iodine-131 at any one time or in any 5-day period at field stations 

or at temporary job sites; (2) or more than 3.7 Gbq (0.1 curie) of 

tritium (H-3) or more than 3700 Gbq (100 curies) of gaseous H-3 

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Public Dose

The applicant is not required to, and should not, submit a 

response to the public dose section during the licensing phase. 

This matter will be evaluated during an inspection.

Need Not Be Submitted 

With Application 
C-11 

Item 

No.

Title and Criteria Yes N/A Description 

Attached

10 RADIATION SAFETY PROGRAM (Cont’d)

Operating and Emergency Procedures 

 We will develop, implement, and maintain operating and 

emergency procedures that address the important radiation 

safety aspects as described in 10 CFR 39.63, “Operating and 

Emergency Procedures.” 

Leak Tests

 Leak tests sample collection and analysis will be performed by 

an organization authorized by the NRC or an Agreement State 

to provide leak testing services to other licensees; or by using a 

leak test sample collection kit supplied by an organization 

licensed by the NRC or an Agreement State to provide leak 

test kits or sample analysis services to other licensees and 

according to the instructions provided in the leak test sample 

collection kit. 

OR 

 Leak test sample collection and analysis will be done by the 

applicant. Provide the information in Appendix M supporting a 

request to perform leak test sample collection and sample 

analysis and either state that you will follow the model 

procedures in the appendix or submit a description of 

alternative procedures

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 [ ] 

Maintenance Before Use

 Before each use, visual inspections will be conducted and 

records maintained in accordance with 10 CFR 39.43(a), to 

ensure that well logging equipment is in good working condition 

and is labeled as required. 

AND 

 Submit the procedure(s) for conducting visual inspections 

before each use. [ ] [ ] 

[ ] 
C-12 

Item 

No.

Title and Criteria Yes N/A Description 

Attached

10 RADIATION SAFETY PROGRAM (Cont’d)

Semiannual Visual Inspection and Maintenance

 Semiannual visual inspections and routine maintenance will be 

conducted and records maintained in accordance with 10 CFR 

39.43(b), to ensure that required labeling is legible and that no 

physical damage is visible. 

AND 

 Submit the procedure(s) for conducting semiannual visual 

inspections and routine maintenance. 

[ ] [ ] 

[ ] 

Maintenance Requiring Special Authorization

 Activities described in 10 CFR 39.43(c) and (d) shall not be 

conducted unless written detailed procedures have been 

approved by the NRC. 

OR 

 Submit detailed procedures for any activities described in 10 

CFR 39.43(c) and (d), including radiation safety precautions 

that individuals will be expected to follow when performing 

these tasks and the minimum qualifications of these 

individuals. Each different task must be described. Should a 

procedure require the removal of the sealed source from the 

holder before performing any maintenance on the holder, 

applicants should describe the removal procedures. 

[ ] [ ] 

[ ] [ ] 

Transportation

No response is needed from applicants during the licensing phase. 

Transportation issues are reviewed during inspections. 

No Response is 

Necessary for this 

Section 
C-13 

Item 

No.

Title and Criteria Yes N/A Description 

Attached

10 RADIATION SAFETY PROGRAM (Cont’d)

Minimization of Contamination

The applicant does not need to provide a response to this item if 

the applicant has met the criteria in the following sections: 

“Radioactive Material–Sealed Sources and Devices, and Unsealed 

(Tracer) Radioactive Material,” “Facilities and Equipment,” 

“Radiation Safety Program–Leak Tests”, “Radiation Safety 

Program–Tracer Studies,” “Radiation Safety Program–Operating 

and Emergency Procedures,” and “Waste Management.” 

No Response is Necessary 

for this Section 

AND 

 We will not conduct decontamination of a facility contaminated 

by a leaking sealed source or contaminated by unsealed 

material with a half-life greater than 120 days. This type of 

decontamination activity will be conducted by an NRC or 

Agreement State licensee that is specifically authorized to 

conduct such activity. 

OR 

 We have submitted procedures for the conduct of 

decontamination of a facility contaminated by a leaking sealed 

source or contaminated by unsealed material with a half-life 

greater than 120 days. 

[ ] 

[ ] [ ] 

Use of Sealed Sources in Drill-to-Stop Well Logging 

Operations

 Submit step-by step operating and emergency procedures for 

conducting drill-to-stop (DTS) well logging operations. 

Procedures must address radiation safety aspects when 

conducting DTS well logging operations. 

[ ] [ ] [ ] 
C-14 

Item 

No.

Title and Criteria Yes N/A Description 

Attached

10 RADIATION SAFETY PROGRAM (Cont’d)

Use of Sealed Sources in Measurement While Drilling or 

Logging While Drilling Well Logging Operations

 Submit step-by-step operating and emergency procedures for 

conducting measurement while drilling (MWD) and logging 

while drilling (LWD) well logging activities. Procedures must 

address radiation safety aspects when conducting MWD and 

LWD well logging operations. 

[ ] [ ] [ ] 

Energy Compensation Sources

 Submit Step-by-Step Operating and Emergency Procedures for 

using and handling energy compensation sources (ECSs). 

Include, among other aspects, instructions for testing ECSs 

requiring leak tests at intervals not to exceed 3 years, 

instructions for conducting physical inventories of ECSs at least 

every 6 months, a record system for maintaining inventory 

records required by 10 CFR 39.37, “Physical Inventory,” and a 

record system for maintaining records of use for ECSs. 

[ ] [ ] [ ] 

Use of Sealed Sources and/or Neutron Generators in 

Freshwater Aquifers 

 State that: “We will not use sealed sources and/or neutron 

generators for conducting well logging operations in freshwater 

aquifers.” 

OR 

 Submit step-by-step operating and emergency procedures for 

conducting well logging activities using sealed sources and/or 

neutron generators in freshwater aquifers that meet the criteria 

in Section 8.10.12.4 of NUREG-1556, Volume 14, Revision 1; 

10 CFR 39.55; and 10 CFR 39.63.

[ ] 

[ ] [ ] 
C-15 

Item 

No.

Title and Criteria Yes N/A Description 

Attached

Tracer Studies in Single Well Applications 

 We will not perform tracer studies in single well 

applications. 

OR 

 We will perform tracer studies in single well applications and 

have submitted step-by-step operating and emergency 

procedures for conducting tracer studies in single well 

applications that meet the criteria in Section 8.10.13.1 of 

NUREG-1556, Volume 14, Revision 1; 10 CFR 39.45; and 10 

CFR 39.63. 

. 

[ ] 

[ ] 

10 RADIATION SAFETY PROGRAM (Cont’d)

Field Flood and Secondary Recovery Applications (Tracer 

Studies in Multiple Wells)

 Field flood studies using tracer materials will not be conducted. 

OR 

 Field flood studies using tracer materials will be conducted and 

we have submitted step-by-step procedures and information 

required in Appendix E, “Field Flood Studies/Enhanced 

Recovery of Oil and Gas Wells.” 

[ ] 

[ ] 

[ ] [ ] [ ] 

Tracer Studies in Freshwater Aquifers

 We will not knowingly inject tracer material into a freshwater 

aquifer. 

OR 

 We request authorization to inject tracer material into a 

freshwater aquifer and have submitted our reasons for 

performing the study and procedures to safeguard the public, 

licensee personnel, and the environment, and have provided 

an environmental report containing the information outlined in 

10 CFR 51.45, “Environmental Report.” 

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C-16 

Item 

No.

Title and Criteria Yes N/A Description 

Attached

10 RADIATION SAFETY PROGRAM (Cont’d)

Radioactive Collar and Subsidence or Depth Control Markers

 We will only use radioactive markers where each individual 

marker contains only quantities of licensed material not 

exceeding the exempt quantities authorized in 10 CFR 30.71, 

“Schedule B.” 

[ ] [ ] 

Neutron Accelerators Using Licensed Material

 We will not use neutron generators (accelerators) in our well 

logging operations. 

OR 

 We will use neutron generators (accelerators) in accordance 

with the criteria in Section 8.10.15 of NUREG-1556, Volume 

14, Revision 1, and will provide step-by-step operating and 

emergency procedures for NRC review. Calibration of neutron 

generators will be performed by an NRC or Agreement State 

licensee that is specifically authorized to conduct this activity. 

OR 

 We will use neutron generators (accelerators) in accordance 

with the criteria in Section 8.10.15 of NUREG-1556, Volume 

14, Revision 1, and will provide step-by-step operating and 

emergency procedures for NRC review. We will perform 

calibration of neutron generators and step-by-step procedures 

for conducting calibration of neutron generators that are 

submitted for NRC review. 

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C-17 

Item 

No.

Title and Criteria Yes N/A Description 

Attached

 10 RADIATION SAFETY PROGRAM (Cont’d)

Depleted Uranium Sinker Bars

 We will not use depleted uranium sinker bars in our well 

logging operations. 

OR 

 Depleted uranium sinker bars will be obtained under the 

provisions of a general license, per 10 CFR 40.51, “Transfer of 

Source or Byproduct Material,” and registration form NRC Form 

244 will be filed, as required. 

OR 

 Depleted uranium sinker bars will be obtained under a specific 

license. Specify the number of kilograms of material being 

requested. 

AND 

 Uranium sinker bars will be possessed and inspected as 

specified in Section 8.10.16 of NUREG-1556, Volume 14, 

Revision 1. 

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Security Program for Category 1 and Category 2 

Materials 

In accordance with 10 CFR Part 37, licensees that possess 

an aggregated Category 1 or Category 2 quantity 

of radioactive material must establish, implement, and 

maintain an access authorization program and a security 

program to ensure physical protection of the radioactive 

material.

Need not be 

submitted with 

application
C-18 

Item 

No.

Title and Criteria Yes N/A Description 

Attached

 10 RADIATION SAFETY PROGRAM (Cont’d)

Waste Management

 We will use sealed and/or unsealed radioactive materials with a 

half-life greater than 120 days, and will transfer or dispose of 

the material and/or contaminated waste to a licensed entity 

authorized to receive the material. 

AND 

 We will use the model waste procedures published in Appendix 

O to NUREG-1556, Volume 14, Revision 1, “Program-Specific 

Guidance about Well Logging, Tracer, and Field Flood Study 

Licenses,” for disposing of radioactive materials and/or 

contaminated waste. 

 OR 

 We have provided our procedures for waste collection, storage 

and disposal by any of the authorized methods described in 

this section. 

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[ ] 
APPENDIX D 

CHECKLIST FOR LICENSE APPLICATION 

D-1 

APPENDIX D CHECKLIST FOR LICENSE APPLICATION 

WELL LOGGING APPLICATION 

REVIEW CHECKLIST

Date: 

CONTENTS OF APPLICATION

ITEM 8.1 TYPE OF APPLICANT/LICENSEE 

Type of Action License No.

 [ ] A. New License Not Applicable 

[ ] B. Amendment 

[ ] C. Renewal 

ITEM 8.2 NAME OF APPLICANT/LICENSEE 

 LEGAL NAME: 

 MAILING ADDRESS: ________________________________________________________ 

ITEM 8.3 LOCATION OF USE 

[ ] Address listed above

[ ] Field Stations (Street Address, City, State, and Zip Code): 

( ) ___________________________________ 

( ) ___________________________________ 

( ) ___________________________________ 

[ ] Temporary Job Sites 

[ ] See attached list 

ITEM 8.4 CONTACT PERSON

NAME: 

 TELEPHONE NUMBER: 

ITEMS 8.5-8.6 RADIOACTIVE MATERIAL TO BE POSSESSED/*REQUESTED USE OF 

MATERIALS

[ ] energy compensation sources (ECS) 

[ ] tracer materials 

[ ] well logging sealed sources (MWD/LWD/DTS) 

[ ] radioactive collar/subsidence/depth markers 

[ ] depleted uranium 

[ ] neutron accelerator targets 

[ ] sealed sources for use above ground for other than well logging applications 

SEALED MATERIALS

[ ] Identify each radionuclide (element name and mass number) that will be used in each 

sealed source. 
D-2 

[ ] Provide the manufacturer’s (distributor’s) name and model number for each sealed source 

and, if applicable, device requested. 

[ ] Confirm that the activity per source and maximum activity in each device will not exceed the 

maximum activity listed on the approved certificate of registration issued by the NRC or by an 

Agreement State. 

[ ] Confirm that each sealed source, device, and source/device combination is registered as an 

approved sealed source or device by the NRC or an Agreement State. 

UNSEALED TRACER MATERIAL (Volatile & Nonvolatile)

[ ] Provide element name with mass number, chemical and/or physical form, and maximum 

requested possession limit. 

[ ] Provide information for volatile materials, if known, on the anticipated rate of volatility or 

dispersion. This information may be obtained from the tracer material vendor, supplier, or 

manufacturer. 

SEALED SOURCES

Radioisotope Mfg./Model No. 

SSD Certificate No.

Quantity 

(Curies/MBq/GBq)

*Use

UNSEALED TRACER MATERIALS

Radioisotop

e

-Chemical/Physical 

Form 

-Max. Amount Used Per 

Injection

Quantity 

(Curies/MBq/GB

q)

*Use Volatility/Dispersi

on

*MATERIAL USE LEGEND 

O=Oil Well Logging G=Gas Well 

Logging 

M=Mineral Well 

Logging 

T=Tracer Studies in 

single wells 
D-3 

*MATERIAL USE LEGEND 

FF=Field Flood or 

Enhanced 

Recovery 

Operations 

N=Neutron 

Generators 

C=Calibration 

Sources in above 

ground 

applications 

FINANCIAL ASSURANCE

[ ] Financial assurance not required 

[ ] Financial assurance required and financial assurance documents submitted for review 

[ ] Decommissioning records file established 

ITEM 8.7 RESPONSIBLE INDIVIDUALS

Corporate Organization Chart Submitted for Review:

Radiation Safety Organizational Chart Submitted for Review:

Name(s) of responsible individual(s) 

[ ] Title(s) of individual(s) 

[ ] Training of individual(s) 

[ ] Experience (1-year minimum) 

Radiation Safety Officer Information: 

[ ] Name [ ] Experience [ ] Training [ ] Independent 

Authority to stop 

unsafe operations 

[ ] Organizational Chart (Day-to-Day Radiation Safety Positions) provided 

[ ] Alternative Training and Experience, if applicable 

[ ] See Appendix for the minimum RSO duties and responsibilities 

ITEM 8.8 TRAINING FOR WELL LOGGING SUPERVISORS AND WELL LOGGING 

ASSISTANTS 

LOGGING ASSISTANT TRAINING [§39.61(b)] and (d)

[ ] In-house Training: 

[ ] Received copies of Parts 19, 20, & OE Procedures 

[ ] Classroom instruction in Parts 19 & 20 (2-4 hours) 

[ ] Instruction in the use of licensed materials, remote handling tools, survey equipment, etc. (1-

2 hours) 

[ ] Successfully completed a verbal or written examination 

[ ] Exam with key 

Minimum passing grade % 

[ ] Records maintained for 3 years (copies of quizzes and dates of oral examinations) 
D-4 

LOGGING SUPERVISOR TRAINING [§39.61(a) and (d)] 

[ ] §39.61(e) Topics, by vendor 

Vendor(s) Name: 

[ ] Instructor’s Name: 

[ ] Instructor’s Qualifications: 

[ ] Classroom Training Conducted by Licensee (~24 hours): 

[ ] §39.61(e) Topics: 

< > Fundamentals of radiation safety 

< > Characteristics of radiation 

< > Units of radiation dose and quantity of radiation 

< > Hazard of exposure 

< > Levels of radiation for licensed material 

< > Methods of controlling radiation dose (time, distance, shielding) 

< > Radiation safety practices, including prevention of contamination, and methods of 

decontamination 

[ ] Radiation detection instruments: 

< > Use 

< > Operation 

< > Calibration 

< > Instrument limitations 

< > Survey techniques 

< > Use of personnel monitoring 

[ ] Equipment to be used: 

< > Operation of equipment, including: 

□ source handling equipment 

□ remote handling tools 

< > Storage, control, and disposal of licensed material 

< > Maintenance of equipment 

[ ] Federal regulations 

[ ] Case histories 

[ ] In-house Classroom Training (~8 hours): 

[ ] 10 CFR 19, 20, & 39 

[ ] OE Procedures (§39.63) 

[ ] License 

[ ] ~8 hours of classroom instruction in the above 

[ ] Successfully completed a written examination 

Minimum passing grade % 

Exam Key 

[ ] In-house instructor qualifications 

[ ] Maintain for 3 years copies of written quizzes 

[ ] Field training 

[ ] Field/practical exam 

[ ] On-the-job Training: 

[ ] 3 months (520 hours) 

[ ] 1 month (160 hours) mineral well logging 

[ ] 50 tracer operations or 3 months OJT 

[ ] Logging supervisors with previous training 
D-5 

ALTERNATIVE TO DESCRIBING A TRAINING PROGRAM 

[ ] Identify each individual to be specified on the license as logging supervisor or logging 

assistant 

[ ] For each individual identified, provide the following: 

[ ] Copies of graded tests 

[ ] Certificate of course completion 

[ ] Details of previous well logging work experience 

ANNUAL SAFETY REVIEW (REFRESHER TRAINING) [§39.61(c) and (d)] 

[ ] Description of topics covered 

[ ] Instructor name

ANNUAL JOB PERFORMANCE AUDIT OF WELL LOGGING SUPERVISORS [§39.13(d)]

[ ] Description of the program 

[ ] Discussion of management action 

[ ] Commitment to inspect each logging supervisor at intervals not to exceed 1 year 

[ ] Inspections made on-the-job and unannounced 

[ ] Commitment that an individual who has not performed logging for more than 1 year will be 

inspected the first time that person engages in logging operations 

[ ] Name, training, and experience of each person who will conduct inspection 

ITEM 8.9 FACILITIES AND EQUIPMENT

Facility: For Each Field Station

[ ] Sketch/drawing to scale of the facility and all work areas where materials (tracer and/or 

sealed source) will be used or stored 

[ ] Identify the following, where applicable: 

[ ] Areas where explosive, flammable, or other hazardous materials stored 

[ ] Buildings 

[ ] Boundary lines 

[ ] Security fences 

[ ] Local Lockable storage areas 

[ ] Drawn to specified scale 

[ ] Distance between restricted areas and adjacent unrestricted areas 

[ ] Specify in the sketch/drawing the shielding material used 

[ ] For tracer and/or sealed sources, sketch/drawing of: 

< > locked storage container 

< > underground storage bunker 

< > security of licensed materials 

Facility: For Tracer Authorization, Provide

[ ] Ready Usage ONLY of “pre-calibrated amounts” or “ready-to-use” forms 

[ ] Usage of OTHER than “pre-calibrated amounts” or “ready-to-use” forms 

[ ] Describe equipment for “repackaging” gaseous, volatile or finely divided tracer (field station 

and/or temporary job site) 

< > Sinks 

< > Tray with absorbent material 

< > Glove boxes 

< > Fume hoods with charcoal filtration 

< > Filtered exhaust 

< > Special handling equipment and tools 
D-6 

< > Rubber gloves, face shield, respirator, coveralls, absorbent material, plastic bags, 

secondary container for waste storage for decontamination purposes 

[ ] Description of injection equipment 

[ ] Bench top preparation 

( ) Describe laboratory areas for sample preparation 

< > Hoods 

< > Hood filters 

< > Sinks 

< > Trays with absorbent materials 

< > Remote handling tools 

< > Rubber gloves 

[ ] Storage provisions 

[ ] Describe and provide a drawing of storage facilities 

[ ] Storage of waste materials included 

[ ] Security provisions 

[ ] Adequate shielding 

[ ] General safety equipment available at temporary job sites: [§39.45(a)] 

[ ] rubber gloves 

[ ] face shield 

[ ] respirator 

[ ] coveralls 

[ ] auxiliary shielding 

[ ] absorbent material 

[ ] secondary container for waste storage for decontamination purposes 

[ ] plastic bags

[ ] Description of laundry facility for contaminated clothing, etc. Description of how 

contaminated waste water from laundry facility will be disposed. Operating and emergency 

procedures should address decontamination of the laundry area and equipment. 

[ ] Description of decontamination facilities for trucks, tracer injection tools, or other equipment 

contaminated by tracer materials. Operating and emergency procedures should address 

decontamination of these types of equipment and facilities. 

Facility: Records

[ ] State the physical location where NRC regulatory required records will be stored and 

available for review during NRC inspections. 

Facility: Security 

[ ] If applicable, confirmation that the applicant will have in place the requirements of 10 CFR 

Part 37, “Physical Protection of Category 1 and Category 2 quantities of Radioactive Material,” 

for the proposed field station(s) before the NRC performs the initial security inspection. 

[ ] If applicable, confirmation that the applicant will have a program in place to monitor and, 

without delay, detect, assess, and respond to unauthorized access to radioactive material 

quantities of concern and/or devices for the proposed field station(s) before the NRC performs 

the initial security inspection. 

[ ] If applicable, the applicant will coordinate, to the extent practicable, with LLEA regarding a 

pre-arranged plan for assistance in response to an actual or attempted theft, sabotage, or 

diversion of radioactive material quantities of concern and/or devices for the proposed field 

station(s) before the NRC performs the initial security inspection. 

ITEM 8.10.1 AGREEMENT WITH WELL OWNER/OPERATOR [§39.15]

[ ] Elements of the Agreement: 

[ ] A reasonable effort be made to recover the source 
D-7 

[ ] A person not attempt to recover a lodged sealed source in a manner which, in the licensee’s 

opinion, could result in its rupture 

[ ] Radiation monitoring be conducted during recovery operations 

[ ] Contaminated equipment, personnel, or environment be decontaminated before release 

from site or before released for unrestricted use 

[ ] Irretrievable classified sources: 

< > Immobilized and sealed in place 

< > Means to prevent inadvertent intrusion on the source 

< > Permanent identification plaque with regulatory required information as per §39(a)(5)(iii) 

[ ] Agreement refers to §39.15(a) 

[ ] Blanket agreement 

[ ] Emergency Abandonment of DTS or MWD/LWD sealed sources 

[ ] Abandonment of Neutron Generator with activity greater than 110 GBq (30 curies) 

[ ] Abandonment of ECSs with activity greater than 3.7 MBq (100 microcuries) 

ITEM 8.10.2 RADIATION SAFETY PROGRAM AUDIT 

[ ] Reviewed on an annual basis 

[ ] ALARA 

[ ] NRC/DOT regulations and license 

[ ] Occupational/Public Doses 

[ ] Audit program not submitted, but available for inspection by the NRC 

[ ] Appendix F reviewed 

ITEM 8.10.3 RADIATION MONITORING INSTRUMENTS [§39.33(a)]

[ ] 0.1-50 mR/h 

[ ] Type of instruments (GM, ion chamber, scintillation) 

[ ] Type of radiation detected (α, β, γ, neutron) 

[ ] Availability of survey instrument pursuant to 10 CFR 39.33(b)

Survey Instrument 

 Manufacturer 

 Model No. 

 # Available 

 Type 

– GMI onchamber 

– Scintillation 

Instrument Probes 

 Model No. 

Range 

 CPM 

 DPM 

 mR/hr 

 mr/hr 

Radiation Detected 

 α

 β

 γ

 neutron 

Counting Equipment For: 

 Analysis of Contamination Swipes 

 Analysis of Bioassay Samples 

Calibration 

Standards 

Minimum 

Detectable 

Activity 
D-8 

Special Equipment 

 Air Samplers 

 Direct Reading Dosimeters 

 Condenser R meter 

# Available Description 

 CALIBRATION OF RADIATION DETECTION INSTRUMENTS [§39.33(c)] 

[ ] 6-month calibration frequency 

[ ] In-house 

[ ] By manufacturer 

[ ] By outside firm 

 Name: 

 License No.: 

[ ] Calibration procedures in Appendix I adopted 

[ ] Alternative calibration procedures for radiation detection instruments provided for NRC 

review 

ITEM 8.10.4 MATERIAL RECEIPT AND ACCOUNTABILITY/PHYSICAL INVENTORY 

[§39.37]

[ ] Semiannual frequency 

[ ] Maintain records of receipt, transfer, and disposal in accordance with 10 CFR 30.51, 

“Records” 

[ ] Required Information 

[ ] Quantity and kind of licensed material (Sealed Source/Tracer) 

[ ] Location of licensed material 

[ ] Date of inventory 

[ ] Name of individual conducting inventory 

[ ] Inventory records for sealed sources may be combined with leak test records 

[ ] National Source Tracking System (NSTS) reporting requirement 

ITEM 8.10.5 PERSONNEL MONITORING [§39.65(a)]

[ ] TLD 

[ ] Film 

[ ] OSL-Note: Exemption should be requested

[ ] Neutron capability 

[ ] NVLAP-Approved 

[ ] Exchange frequency 

< > Monthly 

< > Quarterly

 BIOASSAYS [§39.65(b)] 

[ ] Procedures in RG 8.20 adopted for conducting bioassays 

[ ] Commitment not to expose any individual to 50 mCi of I-131 at a time or in any 5 days 

[ ] Commercial Service: 

[ ] Name: 

[ ] License No.: 
D-9 

ITEM 8.10.6 PUBLIC DOSE

[ ] No response required 

[ ] Appendix K reviewed 

ITEM 8.10.7 OPERATING AND EMERGENCY PROCEDURES [§39.63] 

[ ] Instructions for handling and using licensed materials, including sealed sources in wells, 

without surface casing for protecting freshwater aquifers 

[ ] Instructions for maintaining security during storage and transportation 

[ ] Instructions to keep licensed material under control and immediate surveillance during use 

[ ] Steps to take to keep radiation exposures ALARA 

[ ] Steps to maintain accountability during use 

[ ] Steps to control access to work sites 

[ ] Steps to take and whom to contact when an emergency occurs 

[ ] Instructions for using remote handling tools when installing into well logging tools or 

handling sealed sources when returning them to their transport containers. Although good 

information, instructions are not necessary when handling low-activity calibration sources and 

radioactive tracer materials. 

[ ] Methods and occasions for conducting radiation surveys, including surveys for detecting 

contamination, as required by 10 CFR 39.67(c)-(e) 

[ ] Procedures to minimize personnel exposure during routine use and in the event of an 

incident, including exposures from inhalation and ingestion of licensed tracer materials 

[ ] Methods and occasions for locking and securing stored licensed materials 

[ ] Personnel monitoring, including bioassays, and the use of personnel monitoring equipment 

[ ] Transportation of licensed materials to field stations or temporary job sites, packaging of 

licensed materials for transport in vehicles, placarding of vehicles when needed, and physically 

securing licensed materials in transport vehicles during transportation to prevent accidental loss, 

tampering, or unauthorized removal 

[ ] Procedures for picking up, receiving, and opening packages containing licensed materials, 

in accordance with 10 CFR 20.1906, “Procedures for receiving and opening packages” 

[ ] Instructions for the use of tracer materials, how to decontaminate the environment, 

equipment, and personnel 

[ ] Instructions for maintaining records in accordance with the regulations and the license 

conditions 

[ ] Steps for the use, inspection, and maintenance of sealed sources, source holders, logging 

tools, injection tools, source handling tools, storage containers, transport containers, and 

uranium sinker bars, as required by 10 CFR 39.43, “Inspection, maintenance, and opening of a 

source or source holder” 

[ ] Procedures for identifying and reporting to the NRC defects and noncompliance, as required 

by 10 CFR 21.21(a) 

[ ] Actions to be taken if a sealed source is lodged in a well 

[ ] Procedures and actions to be taken if a sealed source is ruptured, including actions to 

prevent the spread of contamination and minimize inhalation and ingestion of licensed materials 

and actions to obtain suitable radiation survey instruments, as required by 10 CFR 39.33(b). 

Key elements described in Appendix P are addressed in the procedures. 

[ ] Instructions for the proper storage and disposal of radioactive waste 

[ ] Procedures for laundering contaminated clothing and for decontaminating equipment and 

vehicles 
D-10 

[ ] Procedures to be followed in the event of uncontrolled release of radioactive tracer material 

to the environment, including notification of the RSO, NRC, and other Federal and State 

agencies 

ITEM 8.10.8 LEAK TESTING [§39.35] 

[ ] Vendor(s) Name: 

Address: 

Agreement State/NRC License No.: 

[ ] Leak test kit 

[ ] Leak testing conducted in-house using Appendix M procedures 

[ ] Alternative leak testing procedures submitted for NRC review

ITEM 8.10.9 MAINTENANCE

[ ] Daily visual inspection and 6-month routine maintenance [§39.43(a)-(b)] 

[ ] source holders 

[ ] logging tools 

[ ] injection tools 

[ ] source handling tools 

[ ] storage containers 

[ ] transport containers 

[ ] uranium sinker bars 

[ ] Daily [§39.43(a)] 

[ ] Defects (§39.43(a)) 

[ ] Repairs made and recorded, or equipment taken out of service 

[ ] Operation performed by logging supervisor

SEMIANNUAL MAINTENANCE [§39.43(b)] 

[ ] 6-month

( ) Defects (§39.43(b)) 

( ) Repairs made and recorded, or equipment taken out of service 

( ) Operation performed by logging supervisor 

 

REMOVAL OR MAINTENANCE ON A SEALED SOURCE OR HOLDER [§39.43(c)] 

[ ] Services performed by manufacturer 

[ ] Performed by individual licensed by Agreement State/NRC 

[ ] Performed by licensee 

[ ] Detailed procedures for each task provided for NRC review 

[ ] Radiation safety precautions outlined in O&E procedures

SEALED SOURCES STUCK IN A SOURCE HOLDER [§39.43(d)]

[ ] Performed by licensed equipment manufacturer 

[ ] Performed by individual licensed by Agreement State/NRC 

[ ] Performed by licensee 

[ ] Detailed procedures for each task provided for NRC review 

[ ] Radiation safety precautions outlined in O&E procedures 

 OPENING, REPAIR, OR MODIFICATION OF SEALED SOURCES [§39.43(e)] 

[ ] Performed by Agreement State/NRC-licensed firm 

[ ] Performed by licensee 
D-11 

[ ] Detailed procedures for each task provided for NRC review 

[ ] Radiation safety precautions outlined in O&E procedures 

ITEM 8.10.10 TRANSPORTATION

[ ] No response required; DOT regulations will be followed 

[ ] Appendix N reviewed 

ITEM 8.10.11 MINIMIZATION OF CONTAMINATION [§39.69] 

[ ] Implementation of and adherence to good health physics practices while performing 

operations 

[ ] Minimization of distance to areas, to the extent practicable, where licensed materials are 

used and stored 

[ ] Maximization of survey frequency, within reason, to enhance detection of contamination 

[ ] Segregation of radioactive material in waste storage areas 

[ ] Segregation of sealed sources and tracer materials to prevent cross-contamination 

[ ] Separation of radioactive material from explosives 

[ ] Separation of potentially contaminated areas from clean areas by barriers or other controls 

[ ] Decontamination of a facility contaminated by a leaking source or 

contaminated by unsealed material with a half-life greater than 120 days 

will not be conducted by the licensee but instead will be conducted by 

an NRC or Agreement State licensee that is specifically authorized to 

conduct these activities. 

[ ] Request to Conduct Major Decontamination Activities of a Facility 

Contaminated by a Leaking Source or contaminated by unsealed 

material with a half-life greater than 120 days 

[ ] Instructions to personnel on how to determine presence through survey 

[ ] Levels of contamination 

[ ] Decontamination operating and emergency procedures 

[ ] Decontamination equipment 

[ ] Prevention of contamination of personnel during decontamination 

[ ] How to handle contaminated waste materials 

[ ] Re-surveying of contaminated area to determine effectiveness 

[ ] Records of survey: 

[ ] Before 

[ ] After 

[ ] Contact person 

 

[ ] Decontamination activities will be conducted by outside sources 

licensed by NRC or an Agreement State to conduct these activities. 

ITEM 8.10.12 SEALED SOURCES 

USE OF SEALED SOURCES IN DRILL-TO-STOP WELL LOGGING OPERATIONS

[ ] Step-by-step O&E procedures provided for NRC review 

[ ] Summary or outline addressing important aspects of O&E procedures provided for review 

[ ] For use of sealed sources in well without surface casing 

[ ] Knowledge of borehole conditions 

[ ] Caliper log 

[ ] Running dummy tool log 
D-12 

[ ] Temporary casing 

USE OF SEALED SOURCES IN MWD/LWD WELL LOGGING OPERATIONS

[ ] Step-by-step O&E procedures provided for NRC review 

[ ] Summary or outline addressing important aspects of O&E procedures provided for review 

ENERGY COMPENSATION SOURCES

[ ] Step-by-step O&E procedures provided for NRC review 

[ ] Summary or outline addressing important aspects of O&E procedures provided for review 

[ ] Instructions for testing ECSs requiring leak tests at intervals not to exceed 3 years 

[ ] Instructions for conducting physical inventories of ECSs at least every 6 months 

[ ] A system for maintaining inventory records required by 10 CFR 39.37, “Physical Inventory,” 

[ ] A system for maintaining records of use for ECSs 

[ ] For use of ECSs in well without surface casing 

[ ] Knowledge of borehole conditions 

[ ] Caliper log 

[ ] Running dummy tool log 

[ ] Temporary casing 

USE OF SEALED SOURCES AND/OR NEUTRON GENERATORS IN 

FRESHWATER AQUIFERS 

[ ] Applicant will not use sealed sources and/or neutron generators for conducting well logging 

operations in freshwater aquifers 

[ ] Step-by-step O&E procedures provided for NRC review. Procedures meet the criteria in 

Section 8.10.12.4 of NUREG-1556, Volume 14, revision 1; 10 CFR 39.55, “Tritium neutron 

generator target source”; and 10 CFR 39.63, “Operating and emergency procedures.” 

ITEM 8.10.13 TRACER STUDIES 

Tracer Studies in Single Well Applications [§39.45]

[ ] Methods and occasions for conducting radiation surveys 

[ ] Methods and occasions for locking and securing tracer materials 

[ ] Personnel monitoring and the use of personnel monitoring equipment 

[ ] Transportation to temporary job sites and field stations, including the packaging and placing 

of tracer materials in vehicles, placarding of vehicles, and securing tracer materials during 

transportation 

[ ] Procedures for minimizing exposure to members of the public and occupationally exposed 

individuals in the event of an accident 

[ ] Maintenance of records at field stations and temporary job sites 

[ ] Use, inspection, and maintenance of equipment (injector tools, remote handling tools, 

transportation containers, etc.) 

[ ] Procedures to be used for picking up, receiving, and opening packages containing 

radioactive material 

[ ] Decontamination of the environment, equipment, and personnel 

[ ] Notifications of proper personnel in the event of an accident 

Field Flood and Secondary Recovery Applications 

[ ] Field flood or Secondary Recovery Applications will not be conducted 

[ ] Agreement with well operator or owner, although not required by NRC regulations, is a good 

practice 

[ ] Field flood study project design 
D-13 

[ ] Pre-injection phase of the field flood project 

[ ] Injection phase 

[ ] Post-injection phase 

[ ] Emergency procedures 

[ ] Reporting and record keeping requirements 

[ ] Waste management 

[ ] Methods and occasions for conducting radiation surveys 

[ ] Methods and occasions for locking and securing tracer materials 

[ ] Personnel monitoring and the use of personnel monitoring equipment 

[ ] Transportation to temporary job sites and field stations, including the packaging and placing 

of tracer materials in vehicles, placarding of vehicles, and securing tracer materials during 

transportation 

[ ] Procedures for minimizing exposure to members of the public and occupationally exposed 

individuals in the event of an accident 

[ ] Maintenance of records at field stations and temporary job sites 

[ ] Use, inspection and maintenance of equipment (injector tools, remote handling tools, 

transportation containers, etc.) 

[ ] Procedures to be used for picking up, receiving, and opening packages containing 

radioactive material 

[ ] Decontamination of the environment, equipment, and personnel 

[ ] Notifications of proper personnel in the event of an accident 

[ ] Information requested in Appendix E provided 

Tracer Studies in Single Well Applications in Freshwater Aquifers [§39.45]

[ ] Tracer Studies in Single Well Application will not be conducted in Freshwater Aquifers 

[ ] Tracer Studies in Single Well Application will be conducted in Freshwater Aquifers, and an 

environmental report is provided for the NRC’s review 

ITEM 8.10.14 RADIOACTIVE COLLAR AND SUBSIDENCE OR DEPTH CONTROL 

MARKERS [§39.47]

[ ] Operating and emergency procedures must include a commitment that radioactive markers 

can be used only where each individual marker contains quantities of licensed material not 

exceeding the quantities identified in 10 CFR 30.71, “Schedule B” 

[ ] Licensees are not restricted to using only one marker, and may use multiple markers in each 

pipe joint, provided each individual marker (wires, tape, nails, etc.) is not greater than the 

quantities identified in 10 CFR 30.71 

[ ] Provisions included in O&E procedures to ensure that radioactive markers be physically 

inventoried at intervals not to exceed 6 months, as specified in 10 CFR 39.37 

ITEM 8.10.15 NEUTRON ACCELERATORS USING LICENSED MATERIAL 

[ ] Neutron generator tubes are not considered well logging sealed sources and are not 

required to satisfy the requirement for well logging sealed sources 

[ ] Neutron generator tubes containing less than 110 GBq (30 curies) of tritium are: 

[ ] Exempt from leak testing requirements if they contain less than 3.7 MBq (100 microcuries) 

[ ] Exempt from abandonment requirements 

[ ] Exempt from the performance requirements of sealed sources used in well logging 

operations 

[ ] Neutron generators containing target sources greater than 100 GBq (30 curies) cannot be 

used in wells without surface casing to protect freshwater aquifers, unless approved by the NRC 

[ ] O&E procedures address handling of contamination resulting from the routine use, initial 

installation, replacement, or accidental damage of the targets or glass tubes 
D-14 

ITEM 8.10.16 DEPLETED URANIUM [§40.51]

[ ] Depleted uranium sinker bars will be obtained under the provisions of a general license per 

10 CFR 40.51, “Transfer of source or byproduct material,” and registration form NRC Form 244 

will be filed, as required 

[ ] Depleted uranium sinker bars will not be obtained under the provision of general license 10 

CFR 40.51 

[ ] Uranium sinker bars will be possessed and inspected as specified 

[ ] Number of kilograms of specifically licensed depleted uranium specified 

ITEM 8.11 WASTE MANAGEMENT [10 CFR Part 20, Subpart K] 

[ ] Decay-in-storage disposal for radioactive materials with half-lives less than or equal to 120 

days 

[ ] When a container is transferred to the waste storage area, mark the container with an 

identification label that includes the date sealed, the isotope in the container, and the initials of 

the person sealing the container 

[ ] less than 120 day half-life (T1⁄2) material 

[ ] Held for decay a minimum of 10 T1⁄2 

[ ] Confirm that prior to disposal as in-house waste, you will monitor each container, as follows: 

< > Check radiation detection survey meter for proper operation 

< > Monitor container in a low-level area (less than 0.05 mrem/hr) 

< > Remove any shielding from container 

< > Monitor all surfaces 

< > Discard only those containers that cannot be distinguished from background 

< > Container that can be distinguished from background must be returned to storage area for 

further decay or transferred to person licensed to receive such waste 

[ ] Return to manufacturer authorized recipient 

[ ] Extended Interim Storage of materials pending disposal or transfer to authorized recipient 

[ ] Licensed company 

[ ] Sand-out, flowback, screenout, etc. 

[ ] Disposal by release into sanitary sewerage (§20.2003) 

[ ] Appendix O reviewed 

ITEM 8.12 FEES 

[ ] Fee, if any required, attached 

ITEM 8.13 CERTIFICATION 

[ ] Individual signing an application authorized to make binding commitments and to sign 

official documents on behalf of the legal entity or applicant 
APPENDIX E 

FIELD FLOOD STUDIES/ENHANCED RECOVERY 

OF OIL AND GAS WELLS 

E-1 

APPENDIX E FIELD FLOOD STUDIES/ENHANCED RECOVERY OF OIL AND GAS WELLS 

A formal contractual agreement with the well operator or owner should specify control points 

where samples will be taken, establish criteria for setting minimum sample requirements, and 

confirm the willingness of the client company to abide by effluent restrictions and undertake 

remedial action, if required. Following are some examples: 

Samples of recovered fluids or gas will be collected and measured according to the established 

sampling schedule. 

 Appropriate remedial action will be taken if accidents or incidents occur that may result 

in the release of licensed materials to the environment. For example, if the 

concentration in the recovered fluid or gas approaches or exceeds the design limits, 

remedial action should be taken, such as reducing the injection pressure, temporarily 

shutting in the well, or diluting with non-tracer-bearing fluid or gas. 

Planning Stage 

Reservoir Information 

Describe the reservoir information that you need in order to design a radionuclide tracer study 

for a field flood operation. Examples of reservoir information are shown below: 

 reservoir volume 

 reservoir thickness 

 porosity 

 injected volumes (liquids/gases) 

 oil/water saturation ratios 

Project Design 

Outline the design of the tracer application requested. Examples of items to consider are the 

following: 

 Choice of radionuclides and method used to determine (1) the amount of radionuclide to 

be injected, and (2) the expected concentration of radionuclide in the fluids (gas, water, 

oil) at a recovery well site. Indicate your adherence to the as low as is reasonably 

achievable (ALARA) principle 

 How breakthrough time is predicted 

 How tracer concentrations in the recovered liquids and gases are estimated 

 How the sampling schedule at production wellheads is determined. Include a 

description of how you would determine when sampling could be discontinued. As an 

example, monitoring of samples may be ended when the design life of the project is 

completed, unless the effluent concentration at the control point is above a specified 

fraction of the maximum permissible concentration (as listed for unrestricted areas in 

Title 10 of the Code of Federal Regulations (10 CFR) Part 20, “Standards for Protection 
E-2 

Against Radiation”) and is increasing. In that case, the control point will be monitored 

until the concentration is below the specified fraction of the annual average 

concentration specified in 10 CFR Part 20, Appendix B, Table 2. 

Pre-injection Stage 

Transportation of licensed materials. State that the applicant will comply with U.S. Nuclear 

Regulatory Commission (NRC) and U.S. Department of Transportation (DOT) regulations 

pertaining to the transportation of licensed material. Particular attention should be directed to 

monitoring requirements upon receipt of packages containing licensed materials.

Integrity of wellhead assembly and wellbore. Describe the test procedures used to ensure 

that the wellhead assembly, including injection equipment, will not leak under operating 

conditions. Describe the procedures used to ensure that the wellbore will not leak underground. 

For example, if the injection well operates properly for a 2-week period, integrity of the wellbore 

may be considered ensured. 

Injection Stage 

Outline radiation safety practices during injection process. 

Following are examples of practices: 

 Remain upwind, if practical. 

 Keep nonessential personnel at a distance. 

 Use personnel monitoring devices (thermoluminescent dosimeters (TLDs), optically 

stimulated luminescence dosimeters (OSLs), film badges, finger badges, pocket 

dosimeters, etc.) and other radiation detection instruments in your monitoring and 

surveillance programs. 

 Use special tools and devices to handle licensed material and to facilitate the injection 

process. 

 Perform visual inspection, check pressure gauge, etc., to assure absence of leaks and 

proper delivery of injection liquid or gas. 

Continuously or intermittently monitor radiation levels outside the injection assembly to 

assure that the injection is proceeding according to the plan. Allow sufficient time 

before opening wellhead assembly. 

Post-injection Stage 

Outline radiation safety practices that will be put into place after the injection phase is 

completed. Examples of practices include the following: 

 Check exposure rate at wellhead assembly for residual activity. 
E-3 

 Take smear samples to detect removable contamination on wellhead assembly. 

 Clean reusable tools and check for residual activity before securing for reuse. 

 Collect contaminated materials or contaminated tools and package them into an 

appropriate waste container. 

 Establish schedule for taking samples for bioassay when, for example, handling tritium 

(H-3) exceeding 3.7 Gbq (0.1 Ci) or gaseous H-3 exceeding 3,700 Gbq (100 Ci), or 

handling radioiodine exceeding 1.85 Gbq (50 mCi) of iodine-131 or iodine-125. See 

Section 8.10.5, “Occupational Dosimetry” of NUREG 1556 Volume 14, Revision 1, for 

additional guidance on bioassay programs. 

 Provide instructions to well operator’s personnel for taking post-injection samples and 

shipping the samples to your facilities for analysis. Include handling, packaging, and 

shipping procedures. 

 Package waste materials for transportation, prepare appropriate labels and shipping 

papers, and check for radiation level and removable contamination outside the package. 

 Measure concentrations of radionuclides in recovered liquids or gases, according to your 

established sampling schedule. 

 Take corrective measures if the concentrations in the recovered liquids or gas approach 

or exceed design levels. 

 Conduct area and personnel monitoring before leaving injection site. 

Emergency Procedures 

Outline procedures that you will follow in the event of incidents or accidents that release 

radioactive materials to the environment. Following are examples of incidents and accidents: 

 discovering contamination on the outside surface of the shipping package 

 discovering that the radioactive material container is leaking 

 dropping and breaking a radioactive material container, thereby spilling the material on 

the ground 

 detecting leakage of radioactive materials from wellhead assembly 

 measuring concentrations in liquids or gas from production wells exceeding limits 

specified in Table 2, Appendix B, 10 CFR Part 20. 

Reporting, Record Keeping, and Notification 

Outline the report that will be submitted to the NRC and the records maintained regarding the 

field flood injections. Following are examples of releases to include: records on the 
E-4 

identification of wells, radionuclides, and quantities injected; concentrations of radionuclides in 

liquids or gases produced at production wells; and concentrations of radionuclides in products 

released from the field. 

Also outline the procedures you will follow in case of accidents; and procedures for notifying the 

proper persons or organizations, such as your company management (radiation safety officer), 

well operator or owner, and Federal, State, or municipal governmental agencies involved with 

the control and oversight of affected wells. 

Waste Management 

The applicant should outline the procedures for disposing of licensed material. Wastes from 

tracer operations such as unused materials, and contaminated wipes, gloves, tools, clothing, 

containers, etc., should be disposed of in accordance with 10 CFR Part 20. Recovered waste 

fluids that contain radioactive tracers should either be reinjected or treated as radioactive waste. 

A commonly used method of disposal is transfer to a commercial firm licensed by the NRC or an 

Agreement State to accept radioactive wastes. In dealing with these firms, prior contact is 

needed to determine the specific services they can provide. If commercial services will be used, 

this should be specified.
APPENDIX F 

SUGGESTED WELL LOGGING AND SUBSURFACE TRACER STUDIES 

AUDIT CHECKLIST 

F-1 

APPENDIX F SUGGESTED WELL LOGGING AND SUBSURFACE TRACER STUDIES 

AUDIT CHECKLIST 

All areas indicated in audit notes may not be applicable to every license and may not need to be 

addressed during each audit. For example, licensees do not need to address areas that do not 

apply to the licensee’s activities, and activities that have not occurred since the last audit need 

not be reviewed at the next audit. Audits should be performance based, that is focused on 

observing activities and identifying deficiencies rather than only reviewing records. For 

example, rather than just review records to ensure that daily checks of equipment are being 

performed, observe the daily checks to ensure staff are appropriately performing the activity. 

Date of This Audit _______________________ Date of Last Audit ___________________ 

Next Audit Date _______________________ 

Auditor ___________________________ Date _________________________ 

 (Signature) 

Management Review __________________________ Date _________________________ 

 (Signature) 

A. AUDIT HISTORY 

1. Last audit of this location conducted on (date). 

2. Were previous audits conducted at intervals not to exceed 12 months? [10 CFR 20.1101] 

3. Were records of previous audits maintained? [10 CFR 20.2102] 

4. Were any deficiencies identified during last two audits or 2 years, whichever is longer? 

5. Were corrective actions taken? (Look for repeated deficiencies) 

6. Were corrective actions effective? 

B. ORGANIZATION AND SCOPE OF PROGRAM 

1. If the mailing address or places of use changed, was the license amended? [10 CFR 30.34] 

2. If ownership changed or bankruptcy filed, was the U.S. Nuclear Regulatory Commission’s 

(NRC’s) prior consent obtained or was NRC notified? [10 CFR 30.34] 

3. Authorized Users 

a. Are well logging supervisors trained in accordance with 10 CFR 39.61(a)? 

b. Are well logging assistants trained in accordance with 10 CFR 39.61(b)? 

c. If there are new logging supervisors or logging assistants since the last audit, was the 

license amended (if required)? 

4. Radiation Safety Officer 
F-2 

a. Is the RSO new since the last audit? 

b. If the RSO was changed, was the license amended? 

c. Is the RSO fulfilling his/her duties? 

d. To whom does the RSO report? 

e. Does the RSO have sufficient time to perform his/her radiation safety duties? 

C. FACILITIES 

1. Are facilities as described in the NRC application? 

2. If facilities have changed, has the NRC license been amended? 

3. Are licensed materials secured from unauthorized removal or access? [10 CFR 20.1801] 

4. Is control and constant surveillance maintained of licensed material not in storage? 

[10 CFR 20.1802] 

5. Do storage locations comply with the appropriate security program measures? 

[10 CFR Part 37] 

D. EQUIPMENT AND INSTRUMENTATION 

1. Instruments 

a. Are calibrated and operable radiation survey instruments capable of detecting beta and 

gamma radiation available at each storage location, field station, and temporary jobsite? 

[10 CFR 39.33] 

b. Are radiation survey instruments capable of measuring 0.001 mSv (0.1 mrem) per hour 

through at least 0.5 mSv (50 mrem) per hour? [10 CFR 39.33(a)] 

c. Are additional calibrated and operable radiation detection instruments available that are 

sensitive enough to detect the low radiation and contamination levels that could be 

encountered if a sealed source ruptured? [10 CFR 39.33(b)] 

d. Are radiation survey instruments calibrated— 

(1) at intervals not to exceed 6 months and after instrument servicing? 

(2) for linear scale instruments, at two points located approximately 1/3 and 2/3 of fullscale on each scale; for logarithmic scale instruments, at midrange of each decade, 

and at two points of at least one decade; and for digital instruments, at appropriate 

points? 

(3) so that an accuracy within plus or minus 20 percent of the calibration standard can 

be demonstrated on each scale? 

e. Are Radiation Detection Instrument calibration records retained for a period of 3 years 

 after the date of calibration for inspection by the Commission? [10 CFR 39.33(d)] 
F-3 

2. Sources, Source Holders, Tools 

 

a. Are Sources, Source Holders, and Tools labeled in accordance with 10 CFR 39.31 (a)? 

b. When licensed materials are transported, are the licensed materials packaged, labeled, 

marked, and accompanied by appropriate shipping papers in accordance with 

10 CFR 71? 

c. Are licensed materials stored and transported in accordance with the security 

precautions described in 10 CFR 39.31(b)? 

d. Do sealed sources used for well logging applications meet the design and performance 

criteria described in 10 CFR 39.41? 

e. Are uranium sinker bars (if used) marked in accordance with 10 CFR 39.49? 

f. Are source handling tools compatible with the type of sealed source being used? 

E. MATERIAL USE, CONTROL, AND TRANSFER 

1. Security and Control 

a. Are restricted areas, defined as in 10 CFR 20.1003, limited for the purpose of protecting 

individuals against undue risks from exposure to radiation and radioactive materials? 

b. Are unrestricted areas, defined in 10 CFR 20.1003, re-evaluated when radioactive 

material storage areas are altered/changed or radioactivity was increased to verify that 

the relocation of the material has not affected the unrestricted area? 

c. Are licensed materials that are stored in controlled or unrestricted areas secured from 

unauthorized removal or access as required by 10 CFR 20.1801? 

d. Is licensed material that is in a controlled or unrestricted area and that is not in storage 

controlled and maintained under constant surveillance as required by 10 CFR 20.1802? 

e. Is a logging supervisor (defined in 10 CFR 39.2), physically present at a temporary 

jobsite whenever licensed materials are being handled or are not stored and locked in a 

vehicle or storage place, as required by 10 CFR 39.71(a)? 

f. As required by 10 CFR 39.71(b) during well logging, except when radiation sources are 

below ground or in shipping or storage containers, does the logging supervisor or other 

individual designated by the logging supervisor maintain direct surveillance of the 

operation to prevent unauthorized entry into a restricted area, as defined in 

10 CFR 20.1003? 

2. Receipt and Transfer of Licensed Material 

a. During receipt and transfer of licensed materials, are dose limits for individual members 

of the public maintained in accordance with 10 CFR 20.1302? 
F-4 

b. Do the procedures for the receipt and opening of packages meet the requirements of 

10 CFR 20.1906 and are these procedures followed? 

c. Are licensed materials transferred in accordance with 10 CFR 30.41? 

d. Are records of the receipt, transfer, and disposal of licensed materials maintained in 

accordance with 10 CFR 30.51? 

3. Radionuclide, Chemical Form, Quantity, and Use 

a. Is a semi-annual physical inventory conducted to account for all licensed material 

received and possessed in accordance with 10 CFR 39.37? 

b. Are records of the semi-annual physical inventories maintained in accordance with 

10 CFR 39.37? 

c. Are the quantities of licensed material used in radioactive markers limited to quantities 

not exceeding the quantities specified in 10 CFR 30.71? 

d. Are radioactive markers inventoried in accordance with 10 CFR 39.37? 

F. INSPECTION AND MAINTENANCE 

1. Routine Inspection Program 

a. Are visual checks of source holders, logging tools, and source handling tools, for defects 

made before each use to ensure that the equipment is in good working condition and 

that required labeling is present? [10 CFR 39.43(a)] 

b. If defects were found, was the equipment removed from service until repaired, and a 

record made listing: the date of check, name of inspector, equipment involved, defects 

found, and repairs made? [10 CFR 39.43(a)] 

c. Are records of defects identified during routine inspection retained for 3 years after the 

defect is found? [10 CFR 39.43(a)] 

2. Semiannual Inspection Program 

a. Is there a program for semiannual visual inspection and routine maintenance of source 

holders, logging tools, injection tools, source handling tools, storage containers, 

transport containers, and uranium sinker bars to ensure that the required labeling is 

legible and that no physical damage is visible? [10 CFR 39.43(b)] 

b. If defects are found, was the equipment removed from service until repaired, and a 

record made listing: date, equipment involved, inspection and maintenance operations 

performed, any defects found, and any actions taken to correct the defects? 

[10 CFR 39.43(b)] 

c. Are records of defects identified during the semiannual inspection retained for 3 years 

after the defect is found? [10 CFR 39.43(b)] 
F-5 

3. Removal of Sources from Source Holders 10 CFR 39.43(c) 

a. Have written procedures been developed pursuant to 10 CFR 39.63 and been approved 

either by the Commission pursuant to 10 CFR 39.13(c) or by an Agreement State for the 

removal of a sealed source from a source holder or logging tool, and maintenance on 

sealed sources or holders in which sealed sources are contained? 

4. Stuck Sealed Sources 10 CFR 39.43(d) 

a. Has specific approval by the Commission or an Agreement State been granted to 

perform any operation, such as drilling, cutting, or chiseling, on the source holder, if a 

sealed source is stuck in the source holder? 

NOTE: The opening, repair, or modification of any sealed source must be performed by 

persons specifically approved to do so by the Commission or an Agreement State. 

[10 CFR 39.43(e)] 

5. Notification of failure to comply or existence of a defect and its evaluation [10 CFR 21.21] 

a. If defects were found during routine or semiannual inspections, were these defects 

evaluated in accordance with 10 CFR 21.21? 

b. Were any defects reported under the requirements of 10 CFR 21.21? 

G. AREA RADIATION SURVEYS AND CONTAMINATION CONTROL 

1. Compliance with dose limits for individual members of the public [10 CFR 20.1302] 

a. Have surveys or calculations been made to demonstrate compliance with the annual 

dose limit for individual members of the public? 

b. Are records demonstrating compliance with the dose limit for individual members of the 

public maintained in accordance with 10 CFR 20.2107? 

2. Radiation Surveys [10 CFR 39.67] 

a. Were radiation surveys made in the storage areas for radioactive materials? 

b. Are radiation surveys made of the position occupied by each individual in the vehicle and 

of the exterior of each vehicle used to transport the licensed materials, before 

transporting licensed materials? 

c. Are radiation surveys made of the logging tool if the sealed source assembly is removed 

from the logging tool before departure from the temporary jobsite, to confirm that the 

logging tool is free of contamination by energizing the logging tool detector or by using a 

survey meter? 
F-6 

d. Were any radiation surveys made during or after an operation where the encapsulation 

of the sealed source could have been damaged? 

e. Were radiation surveys at temporary jobsite(s) made before and after each subsurface 

tracer study to confirm the absence of contamination? 

f. Are the results of surveys required by 10 CFR 39.67 recorded and include the date of 

the survey, the name of the individual making the survey, the identification of the survey, 

instrument used, and the location of the survey? 

g. Are radiation survey records maintained for inspection by the Commission for 3 years 

after they are made? 

3. Contamination Control [10 CFR 39.69] 

a. Were there any events where there was evidence that a sealed source had ruptured or 

licensed materials had caused contamination? 

b. Were the emergency procedures required by 10 CFR 39.63, initiated immediately? 

c. Were there contamination events resulting from use of licensed material in well logging 

that required decontamination of work areas, equipment and unrestricted areas? 

d. During efforts to recover a sealed source lodged in a well, did the licensee continuously 

monitor, with an appropriate radiation detection instrument or a logging tool with a 

radiation detector, the circulating fluids from the well, if any, to check for contamination 

resulting from damage to the sealed source? 

4. Leak Tests [10 CFR 39.35] 

a. Is each sealed source (except an energy compensation source (ECS)) tested at intervals 

not to exceed 6 months? 

b. Does the method of leak testing meet the requirements of 10 CFR 39.35(b)? 

c. Are the records of leak test results in units of microcuries and retained for inspection by 

the Commission for 3 years after the leak test is performed? 

NOTE: In the absence of a certificate from a transferor that a test has been made within 

the 6 months before the transfer, the sealed source may not be used until tested. 

d. Has each ECS that is not exempt from testing in accordance with 10 CFR 39.35(e) been 

tested at intervals not to exceed 3 years? 

NOTE: In the absence of a certificate from a transferor that a test has been made within 

the 3 years before the transfer, the ECS may not be used until tested. 

e. During the audit period, did any sealed sources, or ECS, require removal from service 

and reporting as required by 10 CFR 39.35(d)? 

5. Tracer Studies [10 CFR 39.45] 
F-7 

a. Are personnel handling radioactive tracer material required to use protective gloves and 

other protective clothing and equipment? 

b. When using radioactive tracer material, are precautions taken to avoid ingestion or 

inhalation of radioactive tracer material and to avoid contamination of field stations and 

temporary jobsites? 

c. During the audit period, was specific authorization granted by the Commission to 

knowingly inject licensed material into freshwater aquifers? 

6. Use of sealed sources in a well without a surface casing [10 CFR 39.51] 

a. During the audit period, were sealed sources used in a well without a surface casing for 

protecting freshwater aquifers? 

b. If sealed sources were used in a well without a surface casing, were procedures 

followed to reduce the probability of the source becoming lodged in the well? 

c. Were these procedures approved by the Commission pursuant to 10 CFR 39.13(c) or by 

an Agreement State? 

7. Did the auditor make any independent survey measurements? 

a. Describe the type, location, and results of measurements. Also note the survey 

instrument used, serial number, and calibration date. 

b. Does any radiation level exceed regulatory limits? [10 CFR 20.1501(a), 

10 CFR 20.1502(a)] 

H. TRAINING AND INSTRUCTION TO WORKERS 

1. Instruction to Workers [10 CFR 19.12] 

a. Are all individuals likely to receive in a year an occupational dose in excess of 100 

millirem (1 millisievert): 

(1) Kept informed of the storage, transfer, or use of radiation and/or radioactive 

material? 

(2) Instructed in the health protection problems associated with exposure to radiation 

and/or radioactive material, in precautions or procedures to minimize exposure, and 

in the purposes and functions of protective devices employed? 

(3) Instructed in, and required to observe, to the extent within the 

workersworkersworkers’ control, the applicable provisions of Commission regulations 

and licenses for the protection of personnel from exposure to radiation and/or 

radioactive material? 
F-8 

(4) Instructed in the appropriate response to warnings made in the event of any unusual 

occurrence or malfunction that may involve exposure to radiation and/or radioactive 

material? 

(5) Advised as to the radiation exposure reports that workers may request pursuant to 

10 CFR 19.13? 

2. Training [10 CFR 39.61] 

a. Have all logging supervisors received training as required pursuant to 10 CFR 39.61(a)? 

b. Have all logging assistants received training as required pursuant to 10 CFR 39.61(b)? 

c. Were safety reviews for logging supervisors and logging assistants provided at least 

once during the calendar year as required pursuant to 10 CFR 39.61(c)? 

d. Are records maintained, at least 3 years, for each logging supervisor and logging 

assistant training and annual safety review? 

e. Are the subjects outlined in 10 CFR 39.61(e) included in the training program? 

I. RADIATION PROTECTION 

1. Dosimetry 

a. Are ALARA considerations incorporated into the Radiation Protection Program? [10 CFR 

20.1101(b)] 

b. Were prospective evaluations performed showing that unmonitored individuals receive 

less than or equal to 10 percent of the limit? [10 CFR 20.1502(a)] 

c. Did unmonitored individuals’ activities change during the year that could put them over 

10 percent of the limit? 

d. If yes to “c.” above, was a new evaluation performed? 

e. Is external dosimetry required (individuals likely to receive greater than 10 percent of the 

limit)? And is dosimetry provided to these individuals? 

(1) Is the dosimetry supplier NVLAP-approved? [10 CFR 20.1501(d)] 

(2) Are the dosimeters exchanged at appropriate frequency? 

(3) Are dosimetry reports reviewed by the RSO when they are received? 

(4) Are the records on NRC Forms or equivalent? [10 CFR 20.2104(d), 10 CFR 

20.2106(c)] 

a. NRC-Form 4 “Cumulative Occupational Exposure History” completed? 

b. NRC-Form 5 “Occupational Exposure Record for a Monitoring Period” 

completed? 
F-9 

(5) Declared pregnant worker/embryo/fetus 

a. If a worker declared her pregnancy, did licensee comply with [10 CFR 20.1208]? 

b. Were records kept of embryo/fetus dose per [10 CFR 20.2106(e)]? 

(6) Are workers notified annually of their exposures? 

(7) Are records of exposures, surveys, monitoring, and evaluations maintained? 

[10 CFR 20.2102, 10 CFR 20.2103, 0 CFR 20.2106] 

2. Programs 

a. Has a radiation protection program commensurate with the scope and extent of licensed 

activities and sufficient to ensure compliance with the provisions of 10 CFR Part 20 been 

developed, documented, and implemented as required by 10 CFR 20.1101(a)? 

b. Has to the extent practical, procedures and engineering controls based upon sound 

radiation protection principles been used to achieve occupational doses and doses to 

members of the public that are as low as is reasonably achievable (ALARA)? 

c. Has the radiation protection program been reviewed at least annually, as required by 

10 CFR 20.1101(c), for program content and implementation? 

d. Are licensed activities subject to the constraint on air emissions of radioactive material to 

the environment required by 10 CFR 20.1101(d)? 

(1) Has a constraint on air emissions of radioactive material to the environment been 

established? 

(2) If subject to the constraint on air emissions of radioactive material to the 

environment requirement: 

A. Has the dose constraint been exceeded? 

B. Was this exceedance reported as required by 10 CFR 20.2203 and were 

prompt appropriate corrective actions taken to ensure against recurrence? 

J. RADIOACTIVE WASTE MANAGEMENT 

1. Waste Storage Areas 

a. Is storage area properly posted? [10 CFR 20.1902] 

b. Are containers properly labeled? [10 CFR 20.1904] 

c. Is the waste area secured against unauthorized removal of or access to licensed 

material? [10 CFR 20.1801] 

2. Sealed Sources 
F-10 

a. Are sources transferred to authorized individuals? [10 CFR 20.2006, 10 CFR 20.2001, 

10 CFR 30.41] 

b. Name of organization:___________________________________. 

c. Are records of sealed sources transferred to authorized individuals maintained? 

[10 CFR 20.2108] 

3. Decay-in-Storage [10 CFR 20.2001] 

a. Are Decay-in-Storage procedures available and followed? 

b. Do radionuclides being stored all have half-lives less than 120 days? 

c. Are radionuclides being segregated for storage according to half-life? 

d. Before waste is disposed of: 

(1) Is a survey performed at the container surface with an appropriate survey instrument 

set on its most sensitive scale, with no interposed shielding, to determine that its 

radioactivity cannot be distinguished from background? 

(2) Are all radiation labels removed or obliterated, as appropriate? [10 CFR 20.1904] 

e. Are records of waste disposed of by the decay-in-storage method maintained? 

[10 CFR 20.2108] 

4. Disposal by release into sanitary sewerage [10 CFR 20.2003] 

a. Are procedures available and followed for disposal by release into sanitary sewerage? 

b. Is licensed material readily soluble or readily dispersible in water? [10 CFR 

20.2003(a)(1)] 

c. Does the quantity of licensed material that the licensee releases into the sewer each 

month averaged over the monthly volume of water released into the sewer not exceed 

the concentration specified in 10 CFR Part 20, Appendix B, Table 3? 

d. If more than one radionuclide is released, does the sum of the ratios of the average 

monthly discharge of a radionuclide to the corresponding limit in 10 CFR Part 20, 

Appendix B, Table 3, not exceed unity? 

e. Does the total quantity of licensed material and other radioactive material released into 

the sanitary sewerage system in a year not exceed 5 curies (185 GBq) of hydrogen-3, 1 

curie (37 GBq) of carbon-14, and 1 curie (37 GBq) of all other radioactive materials 

combined? [10 CFR 20.2003(a)(4)] 

f. Are records of waste disposed of by release into sanitary sewerage maintained? 

[10 CFR 20.2108] 

5. Transfer to Authorized Recipient 
F-11 

a. Is any waste being transferred to a person specifically authorized to receive it? 

[10 CFR 20.2001] 

b. Is waste being transferred to a person specifically authorized to receive it, properly 

manifested? [10 CFR 20.2006] 

c. Are records of waste disposed of by transfer to a person specifically authorized to 

receive it maintained? [10 CFR 20.2108] 

K. RECORD KEEPING FOR DECOMMISSIONING 

1. Are records kept of information important for decommissioning? [10 CFR 30.35(g)] 

2. Do records include all information outlined in 10 CFR 30.35(g)? 

3. Are records of surveys required by 10 CFR 20.2103(a) maintained with records important for 

decommissioning as required by 10 CFR 20.1501(b)? 

L. TRANSPORTATION [10 CFR 71.5(a) 

1. Shipments are: 

 Delivered to common carriers 

 Transported in company’s private vehicle 

 Both 

 No shipments since last audit 

2. Have personnel responsible for preparing a package containing licensed material, 

transporting a package containing licensed material or delivering a package to a carrier for 

transport received HAZMAT training in accordance with 49 CFR 172.700-172.704? 

3. Packages 

a. Are authorized packages used for transporting licensed material? [49 CFR 173.415, 

49 CFR 173.416] 

b. Are performance test records on file: 

(1) For Special Form sources? [49 CFR 173.476(a)] 

(2) For DOT-7A packages? [49 CFR 173.415(a)] 

4. Are Certificates of Compliance (COC’s) for Type B packages on file? [10 CFR 71.17(c)(1)] 

5. Does each package containing licensed material have two labels with Transportation Index 

(TI), Nuclide, Activity, and Hazard Class? [49 CFR 173.403, 49 CFR 173.441] 

6. Are packages properly marked (Shipping name, UN number, Package Type, Reportable 

Quantity (RQ), Name and address of consignee)? [49 CFR 172.301, 49 CFR 172.310, 

49 CFR 172.324, 49 CFR 172.101] 
F-12 

7. Are packages containing licensed material closed and sealed during transport? 

[49 CFR 173.475(f), 49 CFR 173.412(a)] 

8. Are shipping papers prepared and used? [49 CFR 172.200(a)] 

9. Do shipping papers contain proper entries? (Shipping name; Hazard Class; Identification 

Number (UN Number); Total Quantity; Package Type; Nuclide; Reportable Quantity (RQ); 

Physical and Chemical Form; Activity (SI units required); category of label; TI; Shipper’s 

Name, Certification, and Signature; Emergency Response Phone Number; Emergency 

Response Information; and Cargo Aircraft Only (if applicable)) [49 CFR 172.200, 

49 CFR 172.201, 49 CFR 172.202, 49 CFR 172.203, 49 CFR 172.204, 49 CFR 172.604] 

10. Are shipping papers within driver’s reach and readily accessible during transport? 

[49 CFR 177.817(e)] 

11. Are packages secured against movement? [49 CFR 177.834] 

12. Are vehicles placarded, if required? [49 CFR 172.504] 

13. Are incidents reported to the DOT National Response Center? [49 CFR 171.15, 49 CFR 

171.16] 

M. NOTIFICATION AND REPORTS 

1. Was any licensed material lost or stolen? Were reports made? [10 CFR 20.2201, 

10 CFR 30.50] 

2. Did any reportable incidents occur? Were reports made? [10 CFR 20.2202, 10 CFR 30.50] 

3. Did any overexposures or high radiation levels occur? Were they reported? 

[10 CFR 20.2203, 10 CFR 30.50] 

4. Were any contaminated packages or packages with surface radiation levels exceeding 200 

mrem received? Were they reported to the NRC? 

5. If any events (as described in items A through D above) did occur, what was the root cause? 

Were appropriate notifications made and corrective actions taken? 

6. Is the management/RSO aware of the telephone number for the NRC Emergency 

Operations Center? [301-816-5100] 

N. POSTING AND LABELING 

1. Is NRC-Form 3, “Notice to Workers” posted? [10 CFR 19.11] 

2. Are NRC regulations and license documents posted or is a notice indicating where 

documents can be examined posted? [10 CFR 19.11, 10 CFR 21.6, Section 206 of Energy 

Reorganization Act of 1974] 

3. Are other posting and labeling requirements met unless exempted by 10 CFR 20.1903 or 

10 CFR 20.1905? [10 CFR 20.1902, 10 CFR 20.1904] 
F-13 

O. FIELD STATIONS AND TEMPORARY JOB SITES 

1. Are documents and records required by 10 CFR 39.73 available at each field station? 

2. Are documents and records required by 10 CFR 39.75 available at each temporary jobsite 

until the well logging operation is completed? 

P. ABANDONMENT OF SOURCES 

1. Is well logging with a sealed source performed only after obtaining a written agreement with 

the employing well owner or operator? [10 CFR 39.15] 

2. Do written agreements with well owners or operators include the items contained in 

10 CFR 39.15? 

3. During the audit period, did any events occur requiring reporting under 10 CFR 39.77? 

Q. BULLETINS AND INFORMATIONAL NOTICES 

1. Are NRC Bulletins, NRC Informational Notices, Office of Nuclear Material Safety and 

Safeguards (NMSS) Newsletters received? 

2. Are appropriate actions and training taken in response? 

R. DEFICIENCIES IDENTIFIED IN AUDIT; CORRECTIVE ACTIONS 

1. Summarize problems/deficiencies identified during the audit. 

2. If problems/deficiencies were identified in this audit, describe corrective actions planned or 

taken by the facility. Include date(s) when corrective actions are implemented. 

3. Provide any other recommendations for improvement.

APPENDIX G 

WELL LOGGING SUPERVISOR AND LOGGING ASSISTANT TRAINING 

REQUIREMENTS

G-1 

APPENDIX G WELL LOGGING SUPERVISOR AND LOGGING ASSISTANT TRAINING 

REQUIREMENTS 

Requirement Training Criteria

10 CFR 39.61(a) Logging Supervisor 

A. Receive Training in Title 10 of the 

Code of Federal Regulations (10 CFR) 

39.61(e) Topics 

(Classroom Training-Approximately 24 

hours in length) 

Topics in 10 CFR 39.61(e) 

Fundamentals of Radiation Safety

 characteristics of gamma radiation 

 units of radiation dose and quantity of 

radioactivity 

 hazards of exposure to radiation 

 levels of radiation from licensed material 

 methods of controlling radiation dose 

(time, distance, and shielding) 

 radiation safety practices, including 

prevention of contamination, and methods 

of decontamination 

Radiation Detection Instruments

 use, operation, calibration and limitations 

 survey techniques 

 use of personnel monitoring equipment 

Equipment to be Used

 operation of equipment, including source 

handling equipment and remote handling 

tools 

 storage, control, and disposal of licensed 

material 

 inspection and maintenance of equipment 

Requirements of Pertinent Federal 

Regulations

Case histories of accidents in well logging 

operations 
g 

G-2 

Requirement Training Criteria

10 CFR 39.61(a) Logging Supervisor 

B. On-the-Job Training-using sealed 

sources 

160 hours for a mineral logging licensee, 

or a licensee using sealed sources with 

activities less than 500 millicuries 

OR

3 months or 520 hours for gas or oil well 

logging operations using sealed sources 

with activities greater than 500 millicuries 

Under the supervision of a qualified logging 

supervisor 

C. On-the-Job Training-using tracer 

materials 

Single Well Tracer Operations

3 months or 520 hours or completion of 

50 tracer operations 

Field Flood Operations

3 months or 520 hours or completion of 3 

field flood tracer operations involving 

multiple wells 

Under the supervision of a qualified logging 

supervisor 

D. Completion of a Written Examination Complete a written examination submitted 

and approved by the NRC 

E. Must receive Copies of and Instruction 

in: 

(Classroom Training-Approximately 8 

hours in length) 

NRC Regulations 

 Applicable sections of 10 CFR Parts 19, 

20, and 39 

 The NRC License under which the logging 

supervisor will perform well logging 

 The Licensee’s Operating & Emergency 

Procedures required by 10 CFR 39.63 

F. Pass Written Examination on 

10 CFR 39.61(e) Topics outlined in 

Item A 

 Complete a written examination submitted 

and approved by the NRC. 

 Passing Grade 80 percent 
g 

G-3 

Requirement Training Criteria

10 CFR 39.61(a) Logging Supervisor 

G. Receive Equipment Training 

(Approximately 4 hours in length) 

Training includes: 

 Well Logging Equipment 

 Sealed sources 

 Handling equipment 

 Survey meters 

 Daily inspection 

H. Demonstrate Understanding in Use of 

Well Logging Equipment by Passing 

Practical Field Exam 

Questions on topics determined by the 

licensee 

Use the Well Logging Supervisor/Logging 

Assistant Inspection Checklist as a potential 

source of questions 

I. Annual Refresher Training Review the following: 

 Annual radiation safety program review 

 New procedures, equipment, or 

techniques 

 New regulations 

 Observations and deficiencies during 

audits of well logging supervisor and 

logging assistants and discussion of any 

significant incidents or accidents involving 

well logging 

 Employee questions 

J. Records To be maintained in accordance with 10 

CFR 39.61(d) 

Requirement Training Criteria

10 CFR 39.61(b) Logging Assistant 

A. Must receive Copies of and Instruction 

in: 

(Classroom Training-Approximately 8 

hours in length) 

NRC Regulations 

 Applicable sections of 10 CFR Part 19 and 

Part 20 

 The Licensee’s Operating & Emergency 

Procedures required by 10 CFR 39.63 
g 

G-4 

Requirement Training Criteria

10 CFR 39.61(b) Logging Assistant 

B. Pass Oral or Written Exam  Complete a written examination submitted 

and approved by the NRC. 

 Passing Grade 80 percent 

C. Receive Equipment Training 

(Approximately 2-4 hours in length) 

Training under the supervision of a 

qualified well logging supervisor 

appropriate for the logging assistant’s 

intended job responsibilities: 

 well logging equipment 

 sealed sources 

 handling equipment 

 survey meters 

 daily inspection 

D. Annual Refresher Training Review the following: 

 Any significant item identified in the annual 

review of the Radiation Safety Program 

 New procedures or equipment 

 New regulations 

 Observations and deficiencies during 

audits and discussion of any significant 

incidents or accidents involving well 

logging operations 

 Employee questions 

E. Records To be maintained in accordance with 

10 CFR 39.61(d) 
H-1 

APPENDIX H 

ANNUAL INTERNAL JOB PERFORMANCE INSPECTION CHECKLIST 

FOR WELL LOGGING SUPERVISORS AND WELL LOGGING 

ASSISTANTS

 

H-2 

APPENDIX H ANNUAL INTERNAL JOB PERFORMANCE INSPECTION CHECKLIST FOR 

WELL LOGGING SUPERVISORS AND WELL LOGGING ASSISTANTS 

Well Logging Location Date 

Logging Supervisor Time 

Logging Assistant 

Inspector 

Yes No Questions

1. Personnel dosimetry (TLD, or OSL badge, other) available and properly worn? 

 2. Individuals working within the restricted area wearing personnel dosimeters? 

 3. Restricted areas properly controlled to prevent unauthorized entry? 

 4. Individuals working within the restricted area using calibrated and operable 

survey meters? Availability of survey instrument calibration record? 

 5. Individuals working with licensed material performing regulatory required 

radiation surveys? 

6. Most current survey records as required by paragraphs 10 CFR 

39.67available? 

 Measurements of areas of storage and use 

 Measurements of positions occupied in transport vehicle 

 Measurement of vehicle exterior 

 Contamination check of well logging tool prior to transport 

 Measurements before and after subsurface tracer use 

 7. Shipping papers for transportation of radioactive material available and properly 

filled out? 

8. Utilization log properly filled out with complete and accurate information? 

 9. Visual check of well logging equipment to identify defects and to identify that 

required labels are present is being performed before each use? Defective well 

logging equipment removed from service, sent to repair, record made in 

accordance with 10 CFR 39.43? 

10. Copy of 10 CFR Parts 19, 20 and 39 of NRC regulations, copy of the 

radioactive materials license, operating and emergency procedures, radiation 

survey instrument calibration, leak test records, physical inventory records, 

utilization records, inspection and maintenance records, training records and 

survey records available at field stations? 
H-3 

Yes No Questions

11. Copy of the applicant’s operating and emergency procedures, survey meter 

calibrations records, survey records, and copy of the radioactive materials 

license available at temporary jobsites? 

 12. Licensed material stored and secured properly to prevent unauthorized 

removal? Licensed material under constant surveillance when in use and not 

in storage? 

13. Storage area properly posted with “Caution or Danger Radioactive Material” 

signs? 

14. Are well logging supervisors and/or well logging assistants following ALARA 

and company’s operating and emergency procedures? 

15. Are well logging supervisors and/or well logging assistants using specific 

handling tools that are compatible with the sealed sources in accordance with 

manufacturers/distributors instructions? 

 16. Additional items of noncompliance noted during this audit? (If any, explain, in 

remarks.) 

Remarks: 
APPENDIX I 

RADIATION MONITORING INSTRUMENT SPECIFICATIONS AND 

MODEL SURVEY INSTRUMENT CALIBRATION PROGRAM 

I-1 

APPENDIX I RADIATION MONITORING INSTRUMENT SPECIFICATIONS AND MODEL 

SURVEY INSTRUMENT CALIBRATION PROGRAM 

Radiation Monitoring Instrument Specifications 

The specifications in Table I.1 will help applicants and licensees choose the proper radiation 

detection equipment for monitoring the radiological conditions at their facilities. 

Table I.1 Typical Survey. Instruments used to measure radiological conditions at licensed 

facilities.4

Portable Instruments Used for Contamination and Ambient Radiation Surveys

Detectors Radiation Energy Range Efficiency 

Exposure Rate Meters Gamma, 

X-ray 

μR-R N/A 

Count Rate Meters 

GM Alpha All energies (dependent 

on window thickness) 

Moderate 

Beta All energies (dependent 

on window thickness) 

Moderate 

Gamma All energies < 1% 

NaI Scintillator Gamma All energies (dependent 

on crystal thickness) 

Moderate 

Plastic Scintillator Beta Carbon-14 or higher 

(dependent on window 

thickness) 

Moderate 

Stationary Instruments Used to Measure Wipe, Bioassay, and Samples from 

Tracer/Field Flood Study Job sites

Detectors Radiation Energy Range Efficiency 

Liquid Scintillation 

Counter* 

Alpha All energies High 

Beta All energies High 

Gamma Moderate 

 

4

 Table adapted from The Health Physics & Radiological Health Handbook, Revised Edition, Edited by 

Bernard Shleien, 1992 (except for * items). 
I-2 

Stationary Instruments Used to Measure Wipe, Bioassay, and Samples from 

Tracer/Field Flood Study Job sites (Cont’d)

Gamma 

Spectroscopy 

System using 

a (NaI)* detector 

Gamma All energies High 

Gas Proportional Alpha All energies High 

Beta All energies Moderate 

Gamma All energies < 1% 

Model Instrument Calibration Program 

Training 

Before allowing an individual to perform survey instrument calibrations, the radiation safety 

officer (RSO) will ensure that he or she has sufficient training and experience to perform 

independent survey instrument calibrations. 

Classroom training may be in the form of lecture, videotape, or self-study and will cover the 

following subject areas: 

 Principles and practices of radiation protection 

 Radioactivity measurements, monitoring techniques, and using instruments 

 Mathematics and calculations basic to using and measuring radioactivity 

 Biological effects of radiation 

Appropriate on-the-job training consists of the following: 

 Observing authorized personnel performing survey instrument calibration 

 Conducting survey meter calibrations under the supervision and in the physical presence 

of an individual authorized to perform calibrations. 

Facilities and Equipment for Calibration of Dose Rate or Exposure Rate Instruments 

 To reduce doses received by individuals not calibrating instruments, calibrations will be 

conducted in an isolated area of the facility or at times when no one else is present. 

 Individuals conducting calibrations will wear assigned dosimetry. 

 Individuals conducting calibrations will use a calibrated and operable survey instrument to 

ensure that unexpected changes in exposure rates are identified and corrected. 
I-3 

Model Procedure for Calibrating Survey Instruments 

A radioactive sealed source(s) used for calibrating survey instruments will: 

 Approximate a point source. 

 Have its apparent source activity or the exposure rate at a given distance traceable by 

documented measurements to a standard certified to be within ± 5% accuracy by 

National Institute of Standards and Technology (NIST). 

 Approximate the same energy and type of radiation as the environment in which the 

calibrated device will be employed or develop energy curves to compensate for differing 

energies. 

 For dose rate and exposure rate instruments, the source shall be strong enough to give 

an exposure rate of at least about 7.7 x 10-6 coulombs/kilogram/hour (30 mR/hr) at 100 

cm [e.g., 3.1 gigabecquerels (85 mCi) of cesium-137 or 7.8 x 102

 megabecquerels (21 

mCi) of cobalt-60]. 

The three kinds of scales frequently used on dose or dose rate survey meters are calibrated as 

follows5

: 

 Linear readout instruments with a single calibration control for all scales shall be 

adjusted at the point recommended by the manufacturer or at a point within the normal 

range of use. Instruments with calibration controls for each scale shall be adjusted on 

each scale. After adjustment, the response of the instrument shall be checked at 

approximately 20 percent and 80 percent of full scale. The instrument’s readings shall 

be within ± 15 percent of the conventionally true values for the lower point and ± 10 

percent for the upper point. 

 Logarithmic readout instruments, which commonly have a single readout scale spanning 

several decades, normally have two or more adjustments. The instrument shall be 

adjusted for each scale according to site specifications or the manufacturer’s 

specifications. After adjustment, calibration shall be checked at a minimum of one point 

on each decade. Instrument readings shall have a maximum deviation from the 

conventionally true value of no more than 10 percent of the full decade value. 

 Meters with a digital display device shall be calibrated the same as meters with a linear 

scale. 

 Readings above 2.58 X 10-4 coulombs/kilogram/hour (1 R/hr) need not be calibrated, but 

such scales shall be checked for operation and response to radiation. 

 The inverse square and radioactive decay laws shall be used to correct changes in 

exposure rate due to changes in distance or source decay. 

 

5

 ANSI N323B-2003, “Radiation Protection Instrumentation Test and Calibration-Portable Survey Instrument 

for Near Background Operation.” 
I-4 

Surface Contamination Measurement Instruments

 A survey meter’s efficiency must be determined by using sealed sources with similar 

energies and types of radiation that the survey instrument will be used to measure or by 

developing energy curves to compensate for differing energies. 

 If each scale has a calibration potentiometer, the reading shall be adjusted to read the 

conventionally true value at approximately 80 percent of full scale, and the reading at 

approximately 20 percent of full scale shall be observed. If only one calibration 

potentiometer is available, the reading shall be adjusted at mid-scale on one of the 

scales, and readings on the other scales shall be observed. Readings shall be within 20 

percent of the conventionally true value. 

Model Procedures for Calibrating, Liquid Scintillation Counters, Gamma Counters, Gas Flow 

Proportional Counters, and Multichannel Analyzers 

A radioactive sealed source used for calibrating instruments will do the following: 

 Approximate the geometry of the samples to be analyzed. 

 Have its apparent source activity traceable by documented measurements to a standard 

certified to be within ± 5 percent accuracy by NIST. 

 Approximate the same energy and type of radiation as the samples that the calibrated 

device will be used to measure. 

Calibration 

 Calibration of survey instruments used in well logging procedures for assessing dose or 

exposure rates must be conducted at least every 6 months or after instrument servicing. 

 Calibration must produce readings within ± 20 percent of the actual values over the 

range of the instrument. 

 Calibration of liquid scintillation counters will include quench correction. 

Calibration Records 

Calibration reports, for all survey instruments, shall indicate the procedure used and the data 

obtained. The calibration record shall include: 

 the owner or user of the instrument 

 a description of the instrument, including the manufacturer’s name, model number, serial 

number, and type of detector 

 a description of the calibration source, including the exposure rate at a specified 

distance or activity on a specified date 
I-5 

 for each calibration point, the calculated exposure rate or count rate, the indicated 

exposure rate or count rate, the deduced correction factor (the calculated exposure rate 

or count rate divided by the indicated exposure rate or count rate), and the scale 

selected on the instrument 

 for instruments with external detectors, the angle between the radiation flux field and the 

detector (i.e., parallel or perpendicular) 

 for instruments with internal detectors, the angle between radiation flux field and a 

specified surface of the instrument 

 for detectors with removable shielding, an indication whether the shielding was in place 

or removed during the calibration procedure 

 the exposure rate or count rate from a check source, if used 

 the name of the person who performed the calibration and the date it was performed 

The following information shall be attached to the instrument as a calibration sticker or tag: 

 for exposure rate meters, the source radionuclide used to calibrate the instrument (with 

correction factors) for each scale 

 the efficiency of the instrument, for each radionuclide the instrument will be used to 

measure (if efficiency is not calculated before each use) 

 for each scale or decade not calibrated, an indication that the scale or decade was 

checked only for function but not calibrated 

 the date of calibration and the next calibration due date 

 the apparent exposure rate or count rate from the check source, if used 

References: 

 

1. “The Health Physics & Radiological Health Handbook, Revised Edition,” edited by 

Bernard Shleien, dated 1992. 

2. ANSI N323B-2003, “Radiation Protection Instrumentation Test and Calibration-Portable 

Survey Instrument for Near Background Operation.” Copies may be obtained from the 

American National Standards Institute at the following address: www.ansi.org. 

APPENDIX J 

GUIDANCE FOR DEMONSTRATING THAT UNMONITORED 

INDIVIDUALS ARE NOT LIKELY TO EXCEED 10 PERCENT OF THE 

ALLOWABLE LIMITS 

J-1 

APPENDIX J GUIDANCE FOR DEMONSTRATING THAT UNMONITORED INDIVIDUALS 

ARE NOT LIKELY TO EXCEED 10 PERCENT OF THE ALLOWABLE LIMITS

Dosimetry is required for individual adults who are likely to receive in 1 year an occupational 

dose from sources external to the body in excess of 10 percent of the applicable regulatory 

limits in 10 CFR 20.1201, “Occupational Dose Limits for Adults.” However, logging supervisors 

or logging assistants are required by 10 CFR 39.65(a) to wear either a film badge or a 

thermoluminescent dosimeter (TLD) when handling licensed tracer materials or sealed sources. 

In instances where pocket ion chamber dosimeters are used instead of film badges or TLDs to 

assess radiation dosage of personnel who are not logging supervisors or logging assistants, a 

check of the response of the dosimeters to radiation should be made every 12 months. 

Acceptable pocket dosimeters should read within plus or minus 20 percent of the true radiation 

dose. To demonstrate to the NRC that dosimetry is not required for non-logging personnel, a 

licensee needs to have available an evaluation demonstrating that these nonmonitored workers 

are not likely to exceed 10 percent of the applicable annual limits—5 mSv (500 millirems) per 

year. 

The applicable TEDE (whole body) limit is 50 mSv (5 rems) per year, and 10% of that 

value is 5 mSv (500 millirems) per year.

Three common ways that individuals may exceed 10 percent of the applicable limits are 

mishandling tracer radionuclides, logging tools, or any devices containing sealed sources. 

However, most routine well logging or tracer activities result in minimal doses to well logging 

and tracer personnel. A licensee will need to conduct an evaluation of doses occupationally 

exposed workers could receive in performing tasks involving the handling of radioactive 

materials to assess the need for dosimetry. 

Example: A careful radiation measurement using a survey meter of the location producing the 

highest dose rate at the rear of the logging truck where radioactive material is stored in its 

transport compartment and where mechanics routinely work, is found to be 0.015 mSv/hr (1.5 

mrem/hr). Mechanics are not expected to spend any more than a total of 3 hours per week at 

the location near the storage containers where the sealed sources are housed at the rear of the 

truck. Based on this measured dose rate, the annual dose is expected to be less than 2.34 mSv 

(234 mrem). Specifically, 3 hr/wk x 1.5 mrem/hr x 52 wk/yr = 234 mrem. Based on the above, if 

any mechanic works in the area less than 6.4 hours per week, no dosimetry is required. 

Note: The measurement 6.4 hours is the total amount of hours it would take for an individual to 

meet the 5 mSv (500 millirems) per year limit. 

APPENDIX K 

GUIDANCE FOR DEMONSTRATING THAT INDIVIDUAL MEMBERS OF 

THE PUBLIC WILL NOT RECEIVE DOSES EXCEEDING THE 

ALLOWABLE LIMITS

K-1 

APPENDIX K GUIDANCE FOR DEMONSTRATING THAT INDIVIDUAL MEMBERS OF THE 

PUBLIC WILL NOT RECEIVE DOSES EXCEEDING THE ALLOWABLE LIMITS

Licensees must ensure that: 

 The radiation dose received by individual members of the public does not exceed 1 mSv 

(100 mrem) in one calendar year resulting from the licensee’s possession or use of 

licensed materials. 

Members of the public include persons who live, work, or may be near locations where

licensed material is used or stored and employees whose assigned duties do not include the 

use of licensed materials and who work in the vicinity where it is used or stored. 

 The radiation dose in unrestricted areas does not exceed 0.02 mSv (2 mrem) in any one 

hour. 

Typical unrestricted areas may include offices, shops, laboratories, areas outside buildings, 

property, and nonradioactive equipment storage areas. The licensee does not normally 

control access to these areas for purposes of controlling exposure to radiation or radioactive 

materials; however, the licensee may control access to these areas for other reasons, such as 

security. 

Licensees must demonstrate compliance with both of the above regulations. For areas adjacent 

to facilities where licensed material is used or stored, calculations or a combination of 

calculations and measurements (e.g., using an environmental TLD) are often used to show 

compliance. 
K-2 

Figure K.1 Bird’s-eye view of office 

Calculation Method6

These measurements must be made with calibrated survey meters sufficiently sensitive to 

measure background levels of radiation. However, licensees must exercise caution when 

making these measurements, and they must use currently calibrated radiation survey 

instruments. A maximum dose of 1 mSv (100 mrem) received by an individual over a period of 

2080 hours (i.e., a “work year” of 40 hr/wk for 52 wk/yr) is equal to less than 0.5 microsievert 

(0.05 mrem) per hour. 

This rate is well below the minimum sensitivity of most commonly available Geiger-Mueller 

(G-M) survey instruments. 

Instruments used to make measurements for calculations must be sufficiently sensitive. An 

instrument equipped with a scintillation-type detector (e.g., NaI(Tl)) or a micro-R meter used in 

making very low gamma radiation measurements should be adequate. 

Licensees may also choose to use environmental TLDs in unrestricted areas next to the downhole source storage area for monitoring. This direct measurement method would provide a 

definitive measurement of actual radiation levels in unrestricted areas without any restrictive 

assumptions. Records of these measurements can then be evaluated to ensure that rates in 

unrestricted areas do not exceed the 1 mSv/yr (100 mrem/yr) limit. 

 

6

 For ease of use, the examples in this Appendix use conventional units. The conversions to 

SI units are as follows: 1 foot (ft) = 0.305 meter; 1 mrem = 0.01 mSv. 

A Bird’s Eye View of Office

1556-019a.ppt

041300

Radiation Measurement 

taken at 1 foot above the 

below-ground storage bunker

Hallway

4 Feet

Cs-137 Sealed 

Source in 

below-ground 

storage bunker

A Bird’s Eye View of Office

1556-019a.ppt

041300

Radiation Measurement 

taken at 1 foot above the 

below-ground storage bunker

Hallway

4 Feet

Cs-137 Sealed 

Source in 

below-ground 

storage bunker

Radiation Measurement 

taken at 1 foot above the 

below-ground storage bunker

Hallway

4 Feet

Cs-137 Sealed 

Source in 

below-ground 

storage bunker
K-3 

TLDs used for personnel monitoring (e.g., LiF) may not have sufficient sensitivity for this 

purpose. Generally, the minimum reportable dose received is 0.1 mSv (10 mrem). Suppose a 

TLD monitors dose received and is changed once a month. If the measurements are at the 

minimum reportable level, the annual dose received could have been about 1.2 mSv (120 

mrem), a value in excess of the 1 mSv/yr (100 mrem/yr) limit. If licensees use TLDs to 

evaluate compliance with the public dose limits, they should consult with their TLD supplier 

and choose more sensitive TLDs, such as those containing CaF2 that are used for 

environmental monitoring. 

The combined measurement-calculational method may be used to estimate the maximum dose 

to a member of the public. The combined measurement-calculational method takes a tiered 

approach, going through a two-part process, starting with a worst case situation and moving 

toward more realistic situations. It makes the following simplifications: (1) each 

cesium-137 logging source is a point source; (2) typical radiation levels are encountered when 

the source is in the unshielded position; and (3) no credit is taken for any shielding found 

between the source storage area and the unrestricted areas. The method is only valid for the 

source activity at the time of measurement and must be repeated if the source strength or 

shielding is changed. Part 1 of the combined measurement-calculational method is simple but 

conservative. It assumes that an affected member of the public is present 24 hours a day and 

uses only the inverse square law to determine if the distance between the down-hole storage 

area and the affected member of the public is sufficient to show compliance with the public dose 

limits. Part 2 considers not only distance, but also the time that the affected member of the 

public is actually in the area under consideration. Using this approach, licensees make only 

those calculations that are needed to demonstrate compliance. The results of these 

calculations typically result in higher radiation levels than would exist at typical facilities, but they 

provide a method for estimating conservative doses that could be received. 

1556-020.ppt

041300

Keep Out Keep Out

Figure K.2 Down-hole storage array
K-4

Example 

To better understand the combined measurement-calculational method, we will examine EZ 

Well Logging, Inc., a well logging licensee. Yesterday, the company’s president noted that the 

top shield of the down-hole storage area is close to an area used by workers whose assigned 

duties do not include the use of licensed materials, and he asked Elmo, the radiation safety 

officer (RSO), to determine if the company is complying with NRC’s regulations. 

The area in question is near the floor under the workers’ desks, which constitutes the primary 

shield of the down-hole storage area. Elmo measures the distance from the shield to the center 

of the area in question and, using a calibrated survey instrument, measures the highest dose 

rate at one foot from the shield to be 2 mrem per hour. 

Table K.1 summarizes the information Elmo has on the down-hole storage area. 

Table K.1 Information Known about Dose at the Shield of the Cs-137 Source 

Description of Known Information Cesium-137 Logging 

Source

Dose rate encountered at 1 foot from the top of the shield, in 

mrem/hr. 

2 mrem/hr. 

Distance from the face of the shield to the nearest occupied 

work area, in ft. 

4 ft 

Example: Part 1 

Elmo’s first thought is that the distance between the down-hole storage area shield and the area 

in question may be sufficient to show compliance with the regulation in 10 CFR 20.1301, “Dose 

Limits for Individual Members of the Public.” So, taking a worst case approach, he assumes: 

(1) the cesium-137 is constantly located in down-hole storage area (i.e., 24 hours a day (hr/d)), 

and (2) the workers are constantly in the unrestricted work area (i.e., 24 hr/d). Elmo proceeds 

to calculate the dose the workers might receive hourly and yearly from the source, as shown in 

Table K.2 below. 

Table K.2 Calculational Method, Part 1: Hourly and Annual Doses Received from a Logging 

Source Stored in Above Ground Transportation Container 

Step 

No.

Description Input Data Result

s

1 Multiply the measured dose rate measured at 1.0 ft 

from the face of the shield floor in mrem/hr by the 

square of the distance (ft) at which the measurement 

was made (e.g., 1 foot from the face of the shield) 

 2 x (1)2 2 

2 Square of the distance (ft) from the face of the shield to 

the nearest unrestricted area, in ft2 

(4)2 16 
K-5

Step 

No.

Description Input Data Result

s

3 Divide the result of Step 1 by the result of Step 2 to 

calculate the dose received by an individual in the area 

near the shield. HOURLY DOSE RECEIVED FROM 

SOURCE, in mrem in an hour 

2/16 0.12

5

4 Multiply the result of Step 3 by 40 hr/work week x 52 

weeks/year = MAXIMUM ANNUAL DOSE RECEIVED 

FROM Cs-137 Source, in mrem in a year 

0.125 X 40 X 

52 

260

Note: The result in Step 3 demonstrates compliance with the 2 mrem in any one hour limit. Reevaluate if assumptions change. If the result in Step 4 exceeds 100 mrem/yr, proceed to Part 2 

of the calculational method.

At this point, Elmo is pleased to see that the total dose that an individual could receive in any 

one hour is only 0.125 mrem, less than the 2 mrem in any one hour limit but notes that an 

individual could receive a dose of 260 mrem in a year, higher than the 100 mrem limit. 

Example: Part 2 

Elmo reviews the assumptions and recognizes that the workers are not in an area near the 

shield all of the time. A realistic estimate of the number of hours the workers spend in the area 

is made, keeping the other assumptions constant (i.e., the source is constantly in the down-hole 

storage area (i.e., 24 hr/d). The annual dose received is then recalculated. 

Table K.3 Calculational Method, Part 2: Annual Dose Received from a Logging Source 

Stored in Above Ground Transportation Container 

Step 

No.

Description Results

6 A. Average number of hours per day an individual spends in area 

of concern (e.g., a non-radiation worker spends 3.0 hr/day at 

their desk in the area near the shield; the remainder of the day 

the worker is away from the area assigned to jobs unrelated to 

radiation. (painting, grounds keeping, etc.) 

B. Average number of days per week in area 

C. Average number of weeks per year in area (e.g., full time 

workers) 

3.0 

5 

52 

7 Multiply the results of Step 7.A. by the results of Step 7.B. by the 

results of Step 7.C. = AVERAGE NUMBER OF HOURS IN 

AREA OF CONCERN PER YEAR

 3 x 5 x 52 = 

780
K-6

Step 

No.

Description Results

8 Multiply the results in Step 3 by the results of Step 8 = ANNUAL 

DOSE RECEIVED FROM CESIUM-137 LOGGING SOURCE 

CONSIDERING REALISTIC ESTIMATE OF TIME SPENT IN 

AREA OF CONCERN, in mrem in a year 

0.125 x 780 = 

97.5

Elmo is pleased to note that the calculated annual dose received is significantly lower, and does 

not exceed the 100 mrem in a year limit. 

Elmo is glad to see that the results in Step 8 show compliance with the 100 mrem in a year limit. 

Had the result in Step 8 been higher than 100 mrem in a year, then Elmo could have done one 

or more of the following: 

 Consider whether the assumptions used to determine occupancy are accurate, revise 

the assumptions as needed, and recalculate using any new assumptions. 

 Consider the assumption used to determine occupancy including the average time the 

source is stored at the down-hole storage area. 

 Calculate the effect of any shielding located between the storage area and the floor of 

the public area—such calculation is beyond the scope of this Appendix. 

 Take corrective action (e.g., change work patterns to reduce the time spent in the area 

near the shield) and perform new calculations to demonstrate compliance. 

 Designate the area inside the use area as a restricted area and the workers as 

occupationally exposed individuals. This would require controlling access to the area for 

purposes of radiation protection and training the workers as required by 10 CFR 19.12, 

“Instruction to Workers.” 

National Council on Radiation Protection and Measurements (NCRP) Report No. 151, 

“Structural Shielding Design and Evaluation for Megavoltage X- and Gamma-Ray 

Radiotherapy Facilities (2005)”, contains helpful information to determine doses to members of 

the public based on occupancy factors, work load, and shielding. It is available from NCRP, 

7910 Woodmont Avenue, Suite 400, Bethesda, MD 20814-3095. NCRP’s telephone number 

is: 301-657-2652 or 1-800-229-2652. NCRP’s Web address is: 

http://www.ncrppublications.org. 
K-7 

Note that in the example, Elmo evaluated the unrestricted area outside only one wall of the 

down-hole storage area. Licensees also need to make similar evaluations for other unrestricted 

areas and to keep in mind the as low as is reasonably achievable (ALARA) principle, taking 

reasonable steps to keep radiation dose received below regulatory requirements. In addition, 

licensees need to be alert to changes in situations (e.g., adding sources to the storage area, 

changing the work habits of the workers, or otherwise changing the estimate of the portion of 

time spent in the area in question) and to perform additional evaluations, as needed. 

RECORDKEEPING: Regulations in 10 CFR 20.2107 require licensees to maintain 

records demonstrating compliance with the dose limits for individual members of the 

public.

APPENDIX L 

NOTIFICATION OF PROPER PERSONS IN THE EVENT OF AN 

ACCIDENT

L-1 

APPENDIX L NOTIFICATION OF PROPER PERSONS IN THE EVENT OF AN ACCIDENT 

Emergency Procedure 

Notify the persons listed below of the situation, in the order shown. 

Name* Work Phone Number* Home Phone Number*

Radiation Safety Officer (RSO) 

Senior Logging Supervisors 

Manufacturers/Distributors 

Consultant 

* Fill in with (and update, as needed) the names and telephone numbers of appropriate 

personnel (e.g., the Radiation Safety Officer (RSO) or other knowledgeable licensee staff, 

licensee’s consultant, device manufacturer) to be contacted in case of emergency. 

Follow the directions provided by the person contacted above. 

RSO and Licensee Management Discuss emergency operating procedures, and ensure no 

operations are conducted until the situation has been discussed with and approved by the RSO 

or other knowledgeable staff, consultants, or the device manufacturer. Management should 

have access to emergency equipment to keep doses as low as is reasonably achievable. 

Emergency equipment may include special survey equipment required by 10 CFR 39.33(b). 

Notify local authorities as well as the NRC, as required. (Even if notification is not required, 

ANY incident may be reported to the NRC by calling NRC’s Emergency Operations Center at 

301-816-5100, which is staffed 24 hours a day and accepts collect calls.) NRC notification is 

required when sources or devices containing licensed material are lost or stolen and when 

sealed or unsealed radioactive material or equipment is involved in incidents that may have 

caused or that threaten to cause an exposure in excess of 10 CFR 20.2202, “Records of 

Radiation Protection Programs,” limits. Reports to the NRC must be made within the reporting 

time frames specified by the regulations. Notification and reporting requirements are found in 

10 CFR 20.2201–2203, 10 CFR Part 21.21, 10 CFR 30.50 and 10 CFR 39.77. 

Notifications 

Event Telephone 

Notification

Written 

Report

Regulatory Requirement

Theft or loss of material immediate 30 

days 

10 CFR 

20.2201(a)(1)(i) 

Whole body dose greater than 0.25 Sv 

(25 rems) 

immediate 30 

days 

10 CFR 

20.2202(a)(1)(i) 
L-2 

Event Telephone 

Notification

Written 

Report

Regulatory Requirement

Extremity dose greater than 2.5 Sv (250 

rems) 

immediate 30 

days 

10 CFR 

20.2202(a)(1)(iii) 

Whole body dose greater than 0.05 Sv 

(5 rems) in 24 hours 

24 hours 30 

days 

10 CFR 

20.2202(b)(1)(i) 

Extremity dose greater than 0.5 Sv (50 

rems) in 24 hours 

24 hours 30 

days 

10 CFR 

20.2202(b)(1)(iii) 

Whole body dose greater than 0.05 Sv 

(5 rems) 

none 30 

days 

10 CFR 

20.2203(a)(2)(i) 

Dose to individual member of public 

greater than 1 mSv (100 mrems) 

none 30 

days 

10 CFR 

20.2203(a)(2)(iv) 

Defect in equipment that could create a 

substantial safety hazard subject to the 

requirements of 10 CFR Parts 30, 40, 

and 70 

2 days 30 

days 

10 CFR 21.21(d)(3)(i) 

Event that prevents immediate protective 

actions necessary to avoid exposure to 

radioactive materials that could exceed 

regulatory limits 

immediate 30 

days 

10 CFR 30.50(a) 

Unplanned contamination event that 

requires restricted access for greater 

than 24 hours. 

24 hours 30 

days 

10 CFR 30.50(b)(1) 

Equipment is disabled or fails to function 

as designed when required to prevent 

radiation exposure in excess of 

regulatory limits 

24 hours 30 

days 

10 CFR 30.50(b)(2) 

Unplanned fire or explosion that affects 

the integrity of any licensed material or 

device, container, or equipment with 

licensed material 

24 hours 30 

days 

10 CFR 30.50(b)(4) 

Rupture of sealed source immediate 30 

days 

10 CFR 39.77(a) 

Sealed source becomes lodged in well 

bore and becomes classified as 

irretrievable, or licensee is requesting an 

extension to complete abandonment 

procedures 

24 hours 30 

days 

10 CFR 39.77(c) 

10 CFR 39.77(d) 
L-3 

Event Telephone 

Notification

Written 

Report

Regulatory Requirement

Leak test of sealed source resulting in 

leakage greater than 185 Bq (0.005 

microcuries) 

none 5 

days 

10 CFR 39.35(d) 

Failure of any component to perform its 

intended safety function 

none 30 

days 

10 CFR 21.21 

Note: Telephone notifications shall be made to the NRC Operations Center at 301-816-5100

except as noted.

APPENDIX M 

MODEL LEAK TEST PROGRAM 

M-1 

APENDIX M MODEL LEAK TEST PROGRAM

Training 

Before allowing an individual to perform leak testing, the licensee must ensure that he or she 

has sufficient classroom and on-the-job training to show competency in performing leak test 

analysis. 

Classroom training may be provided in the form of lecture, online, videotape, or self-study, and 

shall cover the following subject areas: 

 principles and practices of radiation protection 

 radioactivity measurements, monitoring techniques, and using instruments 

 mathematics and calculations used for measuring radioactivity 

 biological effects of radiation 

Appropriate on-the-job training consists of the following: 

 observing authorized personnel collecting and analyzing leak test samples 

 collecting and analyzing leak test samples under the supervision and in the physical 

presence of an individual authorized to perform leak tests and leak test analysis 

Facilities and Equipment 

 To ensure achieving the required sensitivity of measurements, analyze leak tests in a 

low-background area. 

 Use a calibrated and operable survey instrument to check leak test samples for gross 

contamination before they are analyzed. 

 Analyze the leak test sample using an instrument that is appropriate for the type of 

radiation to be measured (e.g., NaI(Tl) well counter system for gamma-emitters, liquid 

scintillation for beta-emitters, gas-flow proportional counters for alpha-emitters). 

 If the sensitivity of the counting system is unknown, the minimum detectable activity 

(MDA) shall be determined. The MDA may be determined using the following formula: 

 MDA = 2.71 + 4.65√(bkg x t) 

t x E 

where MDA = minimum detectable activity in disintegrations per minute (dpm) 

 bkg = background count rate in counts per minute (cpm) 

 t = background counting time in minutes 

 E = detector efficiency in counts per disintegration 
M-2 

For example: 

where bkg = 200 counts per minute (cpm) 

 E = 0.1 counts per disintegration (10% efficient) 

 t = 2 minutes 

 MDA = 2.71 + 4.65√(200 cpm x 2 minutes) = 2.71 + 4.65√(400) 

 2 x 0.1 0.2 

 = 2.71 + 4.65 (20) = 2.71 + 93 = 95.71 

 0.2 0.2 0.2 

 = 478.55 disintegrations 

 Minute 

 becquerels (Bq) = 1 disintegration 

 second 

 Bq = 478.55 disintegration x minute = 7.976 Bq 

 minutes 60 seconds 

Frequency for Conducting Leak Tests of Sealed Sources 

Leak tests on well logging sealed sources will be conducted, in accordance with 10 CFR 39.35, 

at intervals not to exceed 6 months, or, for Energy Compensation Sources requiring leak tests, 

at intervals not to exceed 3 years. 

Procedure for Performing Leak Testing and Analysis 

 For each source to be tested, list identifying information such as the manufacturer’s 

name, model number, serial number, radionuclide, and activity of the sealed source. 

 Prepare a separate wipe sample (e.g., cotton swab or filter paper) for each source. 

 Number each wipe to correlate with identifying information for each source. 

 Using appropriate radiation safety principles (such as time, distance, and shielding) wipe 

the most accessible area (but not directly from the surface of the source) where 

contamination would accumulate if the sealed source were leaking (e.g., the leak test 

can be taken of the part that connects to the source or the inside of the transport 

container that has recently transported the source). 

 Use a calibrated and operable survey instrument to check leak test samples for gross 

contamination before they are analyzed. 

 Select an instrument for analysis that is sensitive enough to detect 185 Bq (0.005 

microcuries) of the radionuclide. 

 Using the selected instrument, count and record background count rate. 
M-3 

 Check the instrument’s counting efficiency using a standard source of the same 

radionuclide as the source being tested or one with similar energy characteristics. 

Accuracy of standards shall be within plus or minus 5 percent of the stated value and 

traceable to primary radiation standards such as those maintained by the National 

Institute of Standards and Technology (NIST). 

 Calculate efficiency. 

For example: [(cpm from std) - (cpm from bkg)] = efficiency in cpm/Bq 

 activity of std in Bq 

where: cpm = counts per minute 

 std = standard 

 bkg = background 

 Bq = Becquerel 

 Count each wipe sample; determine net count rate. 

 For each sample, calculate and record estimated activity in Bq (or μCi). 

For example: [(cpm from wipe sample) - (cpm from bkg)] = Bq on wipe sample 

 efficiency in cpm/Bq 

Sign and date the list of sources, data and calculations. Retain records for 3 years (under 10 

CFR 20.2103(a)). 

If the wipe test activity is 185 Bq (0.005 microcurie) or greater, notify the Radiation Safety 

Officer (RSO), so that the source can be withdrawn from use and disposed of properly. Also 

notify the NRC. 

APPENDIX N 

TRANSPORTATION—MAJOR DOT REGULATIONS; SAMPLE 

SHIPPING DOCUMENTS, PLACARDS AND LABELS

N-1 

APPENDIX N TRANSPORTATION—MAJOR DOT REGULATIONS; SAMPLE SHIPPING 

DOCUMENTS, PLACARDS AND LABELS

Note: The reference charts included at the end of this appendix are for reference only and are 

not a substitute for DOT and NRC transportation regulations. 

The major areas in the DOT regulations that are most relevant for transportation of licensed 

material shipped as Type A quantities are as follows: 

 Table of Hazardous Materials and Special Provisions—Subpart B, 49 CFR 172.101, 

App. A, list of hazardous substances and reportable quantities (RQ), Table 2: 

Radionuclides 

 Shipping Papers—Subpart C, 49 CFR 172.200-204: General entries, description, 

additional description requirements, shipper’s certification 

 Marking—Subpart D, 49 CFR 172.300, 49 CFR 172.301, 49 CFR 172.303, 

49 CFR 172.304, 49 CFR 172.310, 49 CFR 172.324: General marking requirements for 

non-bulk packaging, prohibited marking, marking requirements, radioactive material, 

hazardous substances in non-bulk packaging 

 Labeling—Subpart E, 49 CFR 172.400, 49 CFR 172.401, 49 CFR 172.403, 

49 CFR 172.406, 49 CFR 172.407, 49 CFR 172.436, 49 CFR 172.438, 49 CFR 172.440, 

49 CFR 172.450: General labeling requirements, prohibited labeling, radioactive 

materials, placement of labels, specifications for radioactive labels and, specifications for 

“Empty” labels 

 Placarding—Subpart F,49 CFR 172.500, 49 CFR 172.502, 49 CFR 172.504, 49 CFR 

172.506, 49 CFR 172.516, 49 CFR 172.519, 49 CFR 172.556: Applicability, prohibited 

and permissible placarding, general placarding requirements, providing and affixing 

placards: highway, visibility and display of placards, specifications for “Radioactive” 

placards 

 Emergency Response Information—Subpart G, 49 CFR 172.600, 49 CFR 172.602, 49 

CFR 172.604, 49 CFR 172.606: Applicability and general requirements, emergency 

response information, emergency response telephone number and, carrier information 

contact 

 Training—Subpart H, 49 CFR 172.702, 49 CFR 172.704: Applicability and responsibility 

for training and testing, training requirements 

 Shippers—General Requirements for Shipments and Packaging—Subpart I, 49 CFR 

173.403, 49 CFR 173.410, 49 CFR 173.412, 49 CFR 173.415, 49 CFR 173.431, 49 CFR 

173.433, 49 CFR 173.435, 49 CFR 173.441, 49 CFR 173.443, 49 CFR 173.448, 49 CFR 

173.475, 49 CFR 173.476: Definitions, general design requirements, additional design 

requirements for Type A packages, authorized Type A packages, activity limits for Type 

A packages, requirements for determining A1 and A2 values, table of A1 and A2 values for 

radionuclides, radiation level limitations, contamination control, general transportation 
N-2 

requirements, quality control requirements prior to each shipment, approval of special 

form radioactive materials 

 Carriage by Public Highway - General Information and Regulations, 49 CFR 177.816, 49 

CFR 177.817, 49 CFR 177.834(a), 49 CFR 177.842: Driver training, shipping paper, 

general requirements (secured against movement), Class 7 (radioactive) material. 

The following are the major areas in DOT regulations most relevant for transporting licensed 

material that is shipped as Type B quantities in addition to the applicable requirements stated 

above: 

A. Package Markings 

49 CFR 172.310 - Radioactive material [Type B] 

B. Shippers—General Requirements for Shipments and Packaging—49 CFR 173 

 Class 7 (Radioactive Materials) – Subpart I. 

(1) 49 CFR 173.25 - Authorized packagings and overpacks 

(2) 49 CFR 173.403 – Definitions 

(3) 49 CFR 173.410 - General design requirements 

(4) 49 CFR 173.413 - Requirements for Type B packages 

(5) 49 CFR 173.416 - Authorized Type B packages 

(6) 49 CFR 173.441 – Radiation level limitations and exclusive use provisions 

(7) 49 CFR 173.443 – Contamination control 

(8) 49 CFR 173.471 - Requirements for U.S. Nuclear Regulatory Commission 

approved packages 

 
N-3 
N-4 
N-5 
N-6 
N-7 
N-8 
N-9 
N-10 
N-11 

Sample 2 

* Substitute appropriate information for your device and shipment. 

HAZARDOUS MATERIAL SHIPPING CERTIFICATION

FOR COMPANY VEHICLE TRANSPORTING IRIDIUM 192 SEALED SOURCES 

SHIPPER*

EZ Logging, Inc. 

1234 Main Street 

Anywhere, USA 20000 

CONSIGNEE*

Mo-Rad, Inc. 

1234 Main Street 

Anywhere, USA 20000 

DATE* S.I. UNITS 

(CURIES)

TRANSPORT* 

INDEX 

(mSv/hr @ 

1meter) 

(Mr/hR @ 3.3 ft) 

CERTIFYING* 

SIGNATURE

35915 EZ Logging Pipe 

Services 

4321 Broad Street 

Somewhere, USA 

 

 

DESCRIPTION OF PIECES AND CONTENTS

RQ RADIOACTIVE MATERIAL - SPECIAL FORM N.O.S. - UN 2974 - CLASS 7 

YELLOW LABEL II - TRANSPORT INDEX NOT TO EXCEED 1.0 

YELLOW LABEL II - TRANSPORT INDEX NOT TO EXCEED 10.0 

LIQUID/GAS/SOLID (RQ 

RADIOACTIVE MATERIAL - 

N.O.S.7) 

□ UN 2982 

SPECIAL FORM 

□ UN 2974 

RADIOACTIVE MATERIAL 

EXCEPTED PACKAGE - 

LIMITED QUANTITY 

□ UN 2910 

This is to certify that the above named materials are properly classified, described, packaged, 

marked, labeled and are in proper condition for transportation according to the applicable 

regulations of the DEPARTMENT OF TRANSPORTATION. (See certifying signature above) 

APPENDIX O 

MODEL WASTE MANAGEMENT PROCEDURES 

O-1 

APPENDIX O MODEL WASTE MANAGEMENT PROCEDURES

Model Waste Disposal Program 

General Guidelines 

A. All radioactivity labels must be defaced or removed from containers and packages prior 

to disposal. If nonradioactive waste is compacted, all radioactivity labels that are visible 

in the compacted mass must be defaced or removed. 

B. Remind workers that non-radioactive waste should not be mixed with radioactive waste. 

C. Procedures and associated activities should be reviewed periodically to ensure that 

radioactive waste is not created unnecessarily. Review all new procedures to ensure 

that waste is handled in a manner consistent with established operating and emergency 

procedures. 

D. Evaluate the entire impact of various available disposal routes. Consider occupational 

and public exposure to radiation, other hazards associated with the material and routes 

of disposal (e.g., toxicity, carcinogenicity, pathogenicity, flammability), and costs. 

E. Waste management program should include waste handling procedures. Also, 

procedures should be available for well logging personnel who may collect waste from 

areas of use to bring to the storage area for eventual disposal. 

Model Procedure for Disposal by Decay-in-Storage (DIS) 

A. Only short-lived waste (physical half-life of less than or equal to 120 days) shall be 

disposed of by DIS. 

B. Short-lived waste shall be segregated from long-lived waste (half-life greater than 120 

days) at the source. 

C. Waste shall be stored in suitable containers, labeled in accordance with 

10 CFR 20.1904, “Labeling containers,” and the containers shall be adequately shielded. 

D. Liquid and solid wastes must be stored separately. 

E. When the waste container is full, it shall be sealed. The sealed container shall be 

identified with a label affixed or attached to it. 

F. In addition to the labeling requirements in 10 CFR 20.1904, the container shall be 

identified with the date the container was sealed, the longest-lived radionuclide in the 

container, date when ten half-lives of the longest-lived radionuclide will have transpired, 

and the initials of the individual who sealed the container. The container may be 

transferred to the DIS area. 
O-2 

G. The contents of the container shall be allowed to decay for at least 10 half-lives of the 

longest-lived radionuclide in the container. The decay interval beginning at the time the 

radioactive waste container is sealed and placed in storage for DIS shall be used for 

calculations and projected removal times. 

H. Prior to disposal as ordinary trash, each container shall be monitored as follows: 

1. Check the radiation detection survey meter for proper operation. 

2. Survey the contents of each container in a low background area. 

3. Remove any shielding from around the container. 

4. Monitor all surfaces of the container. 

5. Discard the contents as ordinary trash only if the surveys of the contents indicate 

no residual radioactivity, i.e., surface readings are indistinguishable from 

background. 

6. If the surveys indicate residual radioactivity, return the container to DIS area and 

contact the RSO for further instructions. 

I. If the surveys indicate no residual radioactivity, record the date when the container was 

sealed, the disposal date, type of waste (used or unused material, gloves, etc.), survey 

instrument used, and the initials of the individual performing surveys and disposing of 

the waste. 

Model Procedure for Disposal of Liquids into Sanitary Sewerage 

A. Confirm that the liquid radioactive waste containing radioactive material being 

discharged is soluble or readily dispersible in water. 

B. Calculate the amount of each radionuclide that can be discharged by using the 

information from prior, similar discharges and the information in 10 CFR 20, “Standards 

for Protection against Radiation,” Appendix B. 

C. Make sure that the amount of each radionuclide does not exceed the monthly and 

annual discharge limits specified in 10 CFR 20.2003, “Disposal by Release into Sanitary 

Sewerage,” and 10 CFR 20, Appendix B. 

D. Record the date, radionuclide(s), estimated activity of each radionuclide, location where 

the material is discharged, and the initials of the individual discharging the radioactive 

waste. 

E. Liquid radioactive waste must be discharged only via designated locations. 

F. Discharge radioactive liquid waste slowly with water running from the faucet to dilute it. 
O-3 

G. Survey the designated disposal locations and surrounding work surfaces to confirm that 

no residual material or contamination remains. 

H. Prior to leaving the area, decontaminate all areas or surfaces, if found to be 

contaminated. 

I. Maintain disposal records that identify each radionuclide and its quantity and the 

concentration that is released into the sanitary sewer system.

. 

APPENDIX P 

ACTIONS TO BE TAKEN IF A SEALED SOURCE IS RUPTURED OR IF 

LICENSED MATERIALS HAVE CAUSED CONTAMINATION 

P-1 

APPENDIX P ACTIONS TO BE TAKEN IF A SEALED SOURCE IS RUPTURED OR IF 

LICENSED MATERIALS HAVE CAUSED CONTAMINATION

Regulations in Title 10 of the Code of Federal Regulations (10 CFR) 39.69(a) require immediate 

initiation of emergency procedures if there is evidence that a sealed source has ruptured or that 

licensed materials have caused contamination. 

Your procedures should instruct logging personnel to: 

 Stop well logging activities immediately after finding evidence that a sealed source has 

ruptured or that licensed materials have caused contamination. 

 Notify immediately the Radiation Safety Officer (RSO) or other appropriate management 

personnel. 

 Follow emergency procedures as directed by the RSO. 

 Secure and restrict access to the area until responsible individuals arrive. 

 Instruct individuals on site not to take any unnecessary actions that could spread 

contamination. 

 Minimize inhalation or ingestion of licensed material by using protective clothing and 

respirators. 

 Discuss procedures for preventing the spread of contamination and for minimizing 

inhalation or ingestion with any potentially exposed personnel. 

 Obtain suitable radiation survey instruments as required by 10 CFR 39.33, “Radiation 

Detection Instruments.” 

 Notify the well owner or operator as soon as possible. 

 Notify immediately the U.S. Nuclear Regulatory Commission operations center at the 

telephone number specified in 10 CFR 20.2202(d)(2) — 301-816-5100. Collect calls are 

accepted.

 

APPENDIX Q 

MODEL DELEGATION OF AUTHORITY

Q-1 

APPENDIX Q MODEL DELEGATION OF AUTHORITY 

Memo To: Radiation Safety Officer 

From: Chief Executive Officer 

Subject: Delegation of Authority 

You, _______________________________, have been appointed radiation safety officer and 

are responsible for ensuring the safe use of radiation. You are responsible for managing the 

Radiation Protection Program, identifying radiation protection problems, initiating, 

recommending, or providing corrective actions, verifying implementation of corrective actions, 

stopping unsafe activities, and ensuring compliance with regulations. You are hereby delegated 

the authority necessary to meet those responsibilities, including prohibiting the use of byproduct 

material by employees who do not meet the necessary requirements and shutting down 

operations, when justified, to maintain radiation safety. You are required to notify management 

if staff does not cooperate and does not address radiation safety issues. In addition, you are 

free to raise issues with the U.S. Nuclear Regulatory Commission at any time. It is estimated 

that you will spend _____ hours per week conducting radiation protection activities. 

__________________________________ ____________________ 

Signature of Management Representative Date 

I accept the above responsibilities, 

___________________________________ ____________________ 

Signature of Radiation Safety Officer Date 

cc: Affected department heads 

APPENDIX R 

INTERIM STAFF GUIDANCE ON CONSTRUCTION 

R-1 

APPENDIX R INTERIM STAFF GUIDANCE ON CONSTRUCTION 

INTERIM STAFF GUIDANCE TO NUREG-1556 AND NUREG-1520: 

COMMENCEMENT OF CONSTRUCTION AT EXISTING AND PROPOSED SOURCE, 

BYPRODUCT, AND SPECIAL NUCLEAR MATERIAL FACILITIES AND IRRADIATORS WITH 

SIGNIFICANT ENVIRONMENTAL IMPACTS 

PURPOSE AND SCOPE 

This Interim Staff Guidance (ISG) provides guidance to U.S. Nuclear Regulatory Commission 

(NRC) staff on the new definition of construction and the consideration of activities that can be 

performed by materials license applicants and potential applicants (hereinafter collectively 

referred to as “applicants”), and licensees before the NRC staff has concluded its environmental 

review of the proposed licensing action. 

This ISG applies to the review of licensing actions related to the receipt and possession of 

licensable source, byproduct, and special nuclear material (SNM) for the conduct of any activity 

which the NRC determines will significantly affect the quality of the environment. This ISG is 

intended to provide guidance to NRC staff but may also be instructive to all holders of operating 

licenses for source, byproduct, and SNM facilities and irradiators, and all persons that have 

submitted applications to construct source, byproduct, and SNM facilities or irradiators, or have 

submitted letters of intent to submit such applications under Title 10 of the Code of Federal 

Regulations (10 CFR) Parts 30, 36, 40, and 70. 

This ISG applies to all Part 30, 36, 40 and 70 materials facilities other than uranium recovery 

facilities. Site preparation activities at uranium recovery facilities are addressed in Regulatory 

Issue Summary 2009-12, Uranium Recovery Policy Regarding Site Preparation Activities at 

Proposed, Unlicensed Uranium Recovery Facilities, September 23, 2009, ML092090353. 

If a licensing action initiated pursuant to 10 CFR Parts 30, 40, or 70 meets any of the criteria in 

10 CFR 51.20 or 51.21, then commencement of construction of a facility before the NRC staff 

has completed its environmental review process is grounds for denial of the license application, 

in accordance with 10 CFR 30.33(a)(5), 40.32(e), and 70.23(a)(7). However, if the licensing 

action meets the criteria in 10 CFR 51.22(c) for a categorical exclusion, and the NRC has not 

determined that an environmental assessment or an environmental impact statement is required 

in accordance with 10 CFR 51.22(b), then commencement of construction before the NRC staff 

concludes the environmental process should not be the sole basis for denial of the license 

application, as the NRC has already determined that this category of actions does not have a 

significant impact on the environment. In accordance with 10 CFR 36.15, commencement of 

construction of an irradiator will only be grounds for denial if the licensee or applicant has not 

submitted both an application and the requisite licensing fee. 

BACKGROUND 

The NRC amended its regulations in September 2011, by revising certain provisions applicable 

to the licensing and approval processes for byproduct, source and SNMs licenses, and 

irradiators in the final rule, “Licenses, Certifications, and Approvals for Materials Licensees” (76 

FR 56951; September 15, 2011) (Material Licenses Construction Rule). The revisions 

contained in the Material Licenses Construction Rule revised the definitions of “construction” 

and “commencement of construction” with respect to materials licensing actions conducted 
R-2 

under the NRC's regulations. The NRC adopted these changes to further improve the 

effectiveness and efficiency of the licensing and approval processes for future materials license 

applications, as well as to eliminate certain inconsistencies that existed within the NRC's 

regulations with respect to the use and definition of the terms “construction” or “commencement 

of construction” for certain materials licensees for purposes of its environmental reviews. 

The new definitions of “commencement of construction” in 10 CFR 30.4, 36.2, 40.4, and 70.4 

are identical. 

Commencement of construction means taking any action defined as “construction” or any other 

activity at the site of a facility subject to the regulations in this part that has a reasonable nexus 

to: 

 1. Radiological health and safety; or 

 2. Common defense and security. 

In 10 CFR 150.31, commencement of construction means taking any action defined as 

“construction” or any other activity at the site of a facility subject to the regulations in this part 

that has a reasonable nexus to radiological health and safety. The regulations in 10 CFR 

150.31 address the requirement for Agreement State regulation of byproduct material. Although 

Agreement State licensees may find this ISG informative, they should also communicate with 

the pertinent Agreement State agency for that agency’s applicable requirements and guidance. 

The new definitions of “construction” in 10 CFR 30.4, 36.2, and 70.4 are also identical. 

Construction means the installation of foundations, or in-place assembly, erection, fabrication, 

or testing for any structure, system, or component of a facility or activity subject to the 

regulations in this part that are related to radiological safety or security. The term “construction” 

does not include: 

(1) Changes for temporary use of the land for public recreational purposes; 

(2) Site exploration, including necessary borings to determine foundation conditions or 

 other preconstruction monitoring to establish background information related to the 

 suitability of the site, the environmental impacts of construction or operation, or the 

 protection of environmental values; 

(3) Preparation of the site for construction of the facility, including clearing of the site, 

 grading, installation of drainage, erosion and other environmental mitigation measures, 

 and construction of temporary roads and borrow areas; 

(4) Erection of fences and other access control measures that are not related to the safe 

 use of, or security of, radiological materials subject to this part; 

(5) Excavation; 

(6) Erection of support buildings (e.g., construction equipment storage sheds, warehouse 

 and shop facilities, utilities, concrete mixing plants, docking and unloading facilities, 

 and office buildings) for use in connection with the construction of the facility; 

(7) Building of service facilities (e.g., paved roads, parking lots, railroad spurs, exterior 

 utility and lighting systems, potable water systems, sanitary sewerage treatment 

 facilities, and transmission lines); 

(8) Procurement or fabrication of components or portions of the proposed facility occurring 

 at other than the final, in-place location at the facility; or 

 (9) Taking any other action that has no reasonable nexus to: 

(i) Radiological health and safety, or 

(ii) Common defense and security.
R-3 

“Construction,” as defined in 10 CFR 40.4, also includes the installation of wells associated with 

radiological operations (e.g., production, injection, or monitoring well networks associated with 

in-situ recovery or other facilities). 

The Atomic Energy Act of 1954, as amended, expressly limits the NRC’s regulatory authority to 

matters concerning the radiological public health and safety or common defense and security 

and non-radiological hazards to the extent such hazards result from the actual processing of byproduct material. The NRC has determined that this authority does not extend to site 

preparation activities that do not have a nexus to radiological health and safety or common 

defense and security. 

This guidance provides criteria for NRC staff to use in evaluating whether a particular 

construction activity has a nexus to radiological health and safety, and thus falls under the 

jurisdiction of the NRC for licensing purposes. An activity or action has a reasonable nexus to 

radiological health and safety or the common defense and security if that activity or action has a 

rational, direct link to ensuring that a materials facility is operating, or will operate, in accordance 

with the NRC’s regulations and in a manner that protects the public health and safety or the 

common defense and security from radiological hazards. The revised definition of construction 

in 10 CFR 30.4, 36.2, 40.4, 70.4, and 150.31 list activities that are not considered “construction.” 

This guidance provides examples of activities that fall under each of the excepted activities that 

do not constitute construction. This guidance addresses some important considerations for 

materials licensees and applicants that were emphasized in the response to comments on the 

proposed Material Licenses Construction Rule. For example, site preparation activities that are 

not considered “construction,” while not under NRC jurisdiction may be subject to the regulatory 

authority of another Federal, State, or local agency which may require National Environmental 

Policy Act or state environmental review. NRC’s responsibilities under the National Historic 

Preservation Act of 1966, as amended (NHPA), must also be satisfied before a license is 

issued. Specifically, as noted in the SOC to the final Material Licenses Construction Rule, 

under certain circumstances the NRC may be required to deny a license application if the NRC 

determines that the applicant intentionally significantly adversely affected, or allowed to be 

affected, a historic property with intent to avoid the requirements of §106 of the NHPA. 

DISCUSSION OF EXAMPLES 

In addition to the background discussion provided above, the following examples clarify the 

delineation of site preparation activities and construction activities. It is important to recognize 

that the NRC may have regulatory authority over activities that can occur before construction 

begins, such as procurement of basic components as defined in 10 CFR Part 21, the process 

of dedicating commercial grade items or basic components, or procurement of items relied on 

for safety (IROFS) as defined in 10 CFR Part 70. It should also be noted that, while site 

preparation activities may not require prior NRC approval, various local, State, or other Federal 

permits may be required. 

BYPRODUCT MATERIAL (10 CFR PART 30) 

Prior to the conclusion of the environmental review process, applicants for byproduct material 

licenses or license amendments should not perform construction activities that have a nexus to 

radiological health and safety or the common defense and security. An activity or action has a 
R-4 

reasonable nexus to radiological health and safety or the common defense and security if that 

activity or action has a rational, direct link to ensuring that a licensed materials facility is 

operating, or will operate, in accordance with the NRC’s regulations and in a manner that 

protects the public health and safety or the common defense and security from radiological 

hazards. 

Installation of foundations or in-place assembly, erection, fabrication, or testing for any structure, 

system, or component of a facility or activity subject to 10 CFR Part 30 that are related to 

radiological health and safety or common defense and security should not be performed prior to 

the conclusion of the environmental review of a license application or amendment. Byproduct 

material license applicants subject to 10 CFR Part 30 may perform those site preparation 

activities identified in revised 10 CFR 30.4 before the NRC has completed its environmental 

review of the license application. 

Excavation and other site preparation activities that do not have a reasonable nexus to 

radiological public health and safety or common defense and security, whether permanent or 

temporary, are not “construction” activities. For example, piles driven to support the erection of 

a bridge for a temporary or permanent access road to a new facility would not be considered as 

construction and may be performed prior to the NRC staff concluding its environmental review 

of a proposed action. 

The installation of a temporary feature within an excavation for a building in which materials 

license activities will be conducted and that will be removed during construction is a site 

preparation activity. Such features include retaining walls, dewatering systems, ramps, and 

other structures that will have no physical presence following construction. 

Construction includes installation of the foundation, including soil compaction; the installation of 

permanent drainage systems and geofabric; the placement of backfill, concrete (e.g., mudmats), 

or other materials that will not be removed before placement of the foundation of a structure; the 

placement and compaction of a subbase; the installation of reinforcing bars to be incorporated 

into the foundation of the structure; the erection of concrete forms for the foundations that will 

remain in place permanently (even if nonstructural); and the placement of concrete or other 

material constituting the foundation of any safety-related feature. 

The term “permanent” in this context includes anything that will exist in its final, in-place facility 

location after commencement of operations with licensed material. Construction also includes 

the “onsite, in-place” fabrication, erection, integration, or testing activities for any in-scope 

safety-related equipment. The terms “onsite, in place, fabrication, erection, integration, or 

testing” describe the process of constructing a facility in its final, onsite plant location, where 

components or modules are integrated into the final, in-plant location. The fabrication, 

assembly, and testing of components and modules in a shop building, warehouse, or laydown 

area, even if located onsite, is not construction. However, the installation or integration of the 

safety-related equipment into its final plant location is construction. 

Construction also includes driving piles for safety-related equipment. Hence, an applicant must 

obtain a license before driving piles for safety-related equipment. However, driving piles that do 

not ensure the structural stability or integrity of a safety-related structure (e.g., piles driven to 

support the erection of a bridge for a temporary or permanent access road) is not construction; 
R-5 

therefore, those piles may be driven prior to the NRC staff concluding its environmental review 

of a proposed action. 

IRRADIATORS (10 CFR PART 36) 

An applicant for a new irradiator license under 10 CFR Part 36 may perform the nonconstruction activities identified in revised 10 CFR 36.2 at any time. However, installation of 

foundations or in-place assembly, erection, fabrication, or testing for any structure, system, or 

component of a facility or activity subject to 10 CFR Part 36 that have a reasonable nexus to 

radiological safety or security should not be performed prior to the submission of an application 

for a license and the fee required by 10 CFR 170.31. An activity or action has a reasonable 

nexus to radiological health and safety or the common defense and security if that activity or 

action has a rational, direct link to ensuring that a licensed materials facility is operating, or will 

operate, in accordance with the NRC’s regulations and in a manner that protects the public 

health and safety or the common defense and security from radiological hazards. Activities that 

have a reasonable nexus to radiological health and safety or common defense and security 

include, but are not limited to, construction of systems subject to 10 CFR Part 36, Subpart C, 

and the following: 

 Earthwork 

 Pool excavation 

 Footings and foundation for pool 

 Irradiator foundations and walls 

 Backfill pool 

 Install pool liner 

 Mechanical rough-in 

 Electrical rough-in 

 Shoring for roof 

 Form and place roof 

 Slab on grade 

Subpart C of 10 CFR Part 36 currently lists the systems that have a nexus to radiological health 

and safety and defines the related engineering and safety concerns associated with each 

system: 

 Access Control: Adequacy of access control systems using interlocks and radiation 

monitors to prevent inadvertent entry to areas where radiation sources are unshielded; 

to provide emergency exits; and to ensure compliance with all the requirements of 10 

CFR 36.23. For computer-controlled access-control systems, licensing staff should 

consider expert evaluation of the software/system logic before operational testing. 

 Site: Potential need for protection against flooding and earth slides. 

 Base (soil, rock) for the Pool and Shielding Structures: Strength, settlement, 

liquefaction, ground water, soil compaction. 

 Footers and Foundations for the Pool and Shielding Structures: Strength and 

reinforcement, alignment with pool and shielding structures. 

 Pool and Shielding Structures: Strength and reinforcement, proper density of shielding 

materials, correct dimensions, minimization of voids in concrete or other shielding. 

 Pool Liner: Contact with pool structure, penetrations in the liner, leak-tight welds. 
R-6 

 Pool Plumbing: Makeup water system; water cleanup system; effect of construction 

materials on pool-water chemistry; drainage system (potentially contaminated spilled 

water should flow into the pool); siphon breakers; radiation detection and alarm systems. 

 Penetrations Through Shielding: Any significant effect on structural strength, shielding, 

or both. 

 Source Rack Protection: If the product to be irradiated moves on a product conveyor 

system, the source rack and the mechanism that moves the rack must be protected by a 

barrier or guides to prevent products and product carriers from hitting or touching the 

rack or mechanism. 

 Source-Rack Mechanical Positioning System: Strength and stiffness of the rack and 

positioning cables or chains, source shroud will not interfere with source positioning, 

adequacy of motive power, potential for jamming. 

 Source-Rack Movement and Position-Sensing System: Structural attachments for 

electrical and mechanical transducers, adequacy of transducers for interacting with the 

source-rack control system. 

 Source-Rack Electrical Control System: Adequacy of the design of logistical and 

operational electrical circuitry and electromechanical components, to ensure 

unambiguous response of the system, which includes programmable controllers or 

computers and their interaction with operations, interlocks, doors, signals, and alarms. 

 Source-Leak Detection: Adequacy of systems for detecting and isolating leaking 

sources. 

 Hard Wiring: Adequacy of wire gauge and insulation to safely carry design currents and 

to withstand radiation and ozone damage if exposed; locating and attaching wiring to 

prevent fretting, wear, and exposure to potential fire hazards; accessibility to wiring for 

inspection and repair. 

 Uninterruptable Electrical Power Supply: Adequate and reliable power capability to 

operate all electrical systems that are important to safety (including backup power 

sources); compatibility of the power supply with the electrical system. 

 Fire Protection System: Adequacy to detect fire and smoke and to be manually as well 

as automatically initiated; must ensure that raised sources are immediately lowered into 

the pool. 

 Emergency Systems for Returning an Up-stuck Source Rack to the Pool: Capability of 

the electrical control system to sense and signal the occurrence of an up-stuck sourcerack; adequacy of mechanical or electrical means for personnel to safely release and 

lower the rack; need for, and adequacy of, a system to cool the source-rack until it can 

be released and lowered. 

 Ozone Ventilation System: Capability of the system to be properly initiated and to 

provide adequate volume flow rate of air to protect personnel and components. 

 System for Transferring Sources from and to Transport Vehicles: Adequately sized 

openings in the shield-structure roof if sources are roof-loaded; structural adequacy of 

the roof-shield plug and its supports for its removal and replacement; structural and 

mechanical adequacy of systems for moving shipping containers into and out of the pool 

area. 
R-7 

URANIUM CONVERSION FACILITIES, ENRICHMENT FACILITIES, FUEL FABRICATION 

FACILITIES, AND URANIUM HEXAFLUORIDE (UF6) DECONVERSION FACILITIES (10 CFR 

PART 40 and 10 CFR PART 70) 

If any of the following actions are performed before the NRC staff has completed its 

environmental review process, then the NRC has grounds for denial of a license application, in 

accordance with 10 CFR 40.32(e), and 70.23(a)(7): 

 1. Procurement or construction of engineered items that are items relied on for safety 

 (IROFS) required to meet the performance requirements of 10 CFR 70.61. 

 2. Construction of guard stations, fences, vehicle barriers, or other features that are, or will 

 become, components of physical security systems required by regulations or orders. 

 3. Construction or installation of equipment whose purpose is the detection of radioactive 

 material accidents or mitigation of the consequences of radioactive material accidents. 

 4. Installation of storage tanks that contain chemicals that could affect the safety of 

 licensed material. 

 5. Construction of facilities or warehouses that will be used for operations involving 

 licensed material. 

 6. Driving of piles; subsurface preparation; placement of backfill, concrete, or permanent 

 retaining walls within an excavation; installation of foundations; or in-place assembly, 

 erection, fabrication, or testing, which are for IROFS and on-site emergency facilities. 

 7. Erection of buildings, offices, construction trailers and warehouses that will become part 

 of a Standard Practice Procedures Plan for Protection of Classified Information. 

Construction includes the onsite, in-place fabrication, erection, integration, or testing activities 

for any safety related item. The terms “onsite, in place, fabrication, erection, integration, or 

testing” describe the process of constructing a fuel cycle facility in its final, onsite plant location, 

where components or modules are integrated into the final, in-plant location. Under the 

definition of “construction” applicants and existing licensees may be able to fabricate, assemble, 

and test components and modules in a shop building, warehouse, or laydown area, even if 

these facilities are located onsite. However, the installation or integration of that safety related 

equipment into its final plant location is a construction activity and should not be performed until 

after the NRC staff concludes its environmental review of the license application. 

Excavation includes the removal of any soil, rock, gravel, or other material below the final 

ground elevation to the final parent material, and may be conducted prior to the conclusion of 

the NRC staff’s environmental review. However, placing permanent, nonstructural dewatering 

materials, mudmats, or engineered backfill in advance of placing the foundation and associated 

permanent retaining walls for buildings or structures that will contain licensed materials are 

construction activities and should not be performed prior to the conclusion of the NRC staff’s 

environmental review. 

Construction includes driving piles for buildings or structures that will contain licensed materials. 

Hence the driving of piles for such buildings or structures should not be performed before the 

NRC staff concludes its environmental review. Driving piles that do not ensure the structural 

stability or integrity of buildings or structures within the scope of the definition of “construction” 

(e.g., piles driven to support the erection of a bridge for a temporary or permanent access road) 

is not “construction”; therefore, those piles may be driven prior to the conclusion of the NRC 

staff’s environmental review.
R-8 

In addition to 10 CFR 40.4, 51.4, and 70.4 criteria that are used to determine the scope of 

activities that fall within the definition of construction, construction includes the necessary 

excavation for safety related items. A necessary excavation is the portion of an excavation that 

provides sufficient construction access to the structures that are within the definition of 

construction. Applicants should ensure, and NRC staff will confirm, that these construction 

activities are separate from, and do not result in, adverse interactions with construction-related 

safety related item including influence on the stability (static and dynamic) analyses. 

Construction includes any change made to the parent material in which the excavation occurs 

(e.g., soil compaction, rock grouting); the driving of piles; the installation of foundations; the 

installation of permanent drainage systems and geofabric; the placement of backfill, concrete 

(e.g., mudmats) or other materials that will not be removed before placement of the foundation 

of a structure; the placement and compaction of a subbase; and the installation of reinforcing 

bars to be incorporated into the foundation of any safety related items that fall within the 

definition of construction. The foregoing items fall within the definition of construction because 

they have a rational, direct link to ensuring that a licensed materials facility is operating, or will 

operate, in accordance with the NRC’s regulations and in a manner that protects the public 

health and safety from radiological hazards. 

ACTIVITIES WHICH HAVE NO REASONABLE NEXUS TO RADIOLOGICAL SAFETY OR 

SECURITY 

The NRC has determined that, in general, the following activities at source, byproduct, and SNM 

facilities and irradiators listed in 10 CFR 30.4, 36.2, 40.4, and 70.4, do not have a reasonable 

nexus to radiological health and safety and the common defense and security may be 

performed by a licensee or applicant at any time. Note that in some circumstances, based on 

the specific licensing proposal, any of these activities could be determined to have a reasonable 

nexus to radiological health and safety or common defense and security and, based on that 

determination, these activities would be construction: 

(1) Changes for temporary use of the land for public recreational purposes; 

(2) Site exploration, including necessary borings to determine foundation conditions or 

other preconstruction monitoring to establish background information related to the 

suitability of the site, the environmental impacts of construction or operation, or the 

 protection of environmental values; 

(3) Preparation of the site for construction of the facility, including clearing of the site, 

grading, installation of drainage, erosion and other environmental mitigation measures, 

and construction of temporary roads and borrow areas; 

(4) Erection of fences and other access control measures that are not related to the safe 

use of, or security of, radiological materials subject to 10 CFR Parts 30, 36, 40, or 70; 

(5) Excavation; 

(6) Erection of support buildings (e.g., construction equipment storage sheds, warehouse 

and shop facilities, utilities, concrete mixing plants, docking and unloading facilities, 

and office buildings) for use in connection with the construction of the facility; 

(7) Building of service facilities (e.g., paved roads, parking lots, railroad spurs, exterior 

 utility and lighting systems, potable water systems, sanitary sewerage treatment 

 facilities, and transmission lines); 

(8) Procurement or fabrication of components or portions of the proposed facility occurring 

at other than the final, in-place location at the facility; or
R-9 

(9) Taking any other action that has no reasonable nexus to: 

 (i) Radiological health and safety, or 

 (ii) Common defense and security. 

While the above site preparation activities may not require prior NRC approval, other Federal, 

State, or Local permits may be required. 

FINAL RESOLUTION 

This interim staff guidance will be incorporated into the next revisions of NUREG-1556, and 

NUREG-1520. 

APPLICABILITY 

This ISG is applicable to all 10 CFR Parts 30, 36, 40, and 70 license applicants and existing 

licensees considering site preparation activities or construction activities at a facility that is 

subject to, or will be subject to, the licensing requirements of these parts. 

REFERENCES 

1) NUREG-1556, Volume 6, “Consolidated Guidance About Material Facilities: Program- 

 Specific Guidance About 10 CFR Part 36 Irradiator Licenses,” January 1999. 

2) NUREG-1556, Volume 12, “Consolidated Guidance About Materials Licenses: Program 

 Specific Guidance About Possession Licenses for Manufacturing and Distribution,” 

 December 2000. 

3) NUREG-1520, “Standard Review Plan for the Review of a License Application for a Fuel 

 Cycle Facility,” Revision 1, May 2010. 

4) Regulatory Issue Summary 2009-12, Uranium Recovery Policy Regarding Site Preparation 

 Activities at Proposed, Unlicensed Uranium Recovery Facilities, September 23, 2009, 

 ML092090353. 

5) NUREG-1748, “Environmental Review Guidance for Licensing Actions Associated with 

 Materials Facilities,” August 2003. 

6) DC/COL-ISG-4, “Interim Staff Guidance on the Definition of Construction and on Limited 

 Work Authorizations,” February 9, 2009, ML082970729. 

7) Inspection Manual Chapter 2815, “Construction and Preoperational Inspection of Panoramic 

 Wet-Source-Storage Gamma Irradiators,” March 27, 2001, ML010990225. 

8) Docket No. 030-36974, Final Environmental Assessment Related to the Proposed Pa’ina 

 Hawaii, LLC, Underwater Irradiator in Honolulu, Hawaii; August 10, 2007; ML071150121. 

9) Docket No. 70-7015, Environmental Assessment for an Exemption to 10 CFR Parts 30, 40, 

 and 70, Commencement of Construction Requirements, Areva Enrichment Services, Eagle 

 Rock Enrichment Facility, Bonneville County, Idaho, February 28, 2010, ML093220528. 

10) NUREG-1811, “Environmental Impact Statement for an Early Site Permit at the North Anna 

 ESP Site,” December 2006. 

11) NUREG-1947, “Final Supplemental Environmental Impact Statement for Combined License 

 (COLs) for Vogtle Electric Generating Plant Unit 3 and 4,” March 2011. 

Technical Contact: Mary T. Adams 

301-492-3113 

E-mail: Mary.Adams@nrc.gov

APPENDIX S 

SAFETY CULTURE STATEMENT OF POLICY 

S-1 

APPENDIX S SAFETY CULTURE STATEMENT OF POLICY

The safety culture policy statement was published in the Federal Register (76 FR 34773) on 

June 14, 2011 and can be found at: http://www.gpo.gov/fdsys/pkg/FR-2011-06-14/pdf/ 

2011-14656.pdf. It is also posted in the NRC’s Agencywide Documents Access and 

Management System, Accession No. ML11146A047. 

Safety Culture Policy Statement 

The purpose of this Statement of Policy is to set forth the Commission’s expectation that 

individuals and organizations establish and maintain a positive safety culture commensurate 

with the safety and security significance of their activities and the nature and complexity of their 

organizations and functions. This includes all licensees, certificate holders, permit holders, 

authorization holders, holders of quality assurance program approvals, vendors and suppliers of 

safety-related components, and applicants for a license, certificate, permit, authorization, or 

quality assurance program approval, subject to U.S. Nuclear Regulatory Commission (NRC) 

authority. The Commission encourages the Agreement States, Agreement State licensees, and 

other organizations interested in nuclear safety to support the development and maintenance of 

a positive safety culture, as articulated in this Statement of Policy. 

Nuclear Safety Culture is defined as “the core values and behaviors resulting from a collective 

commitment by leaders and individuals to emphasize safety over competing goals to ensure 

protection of people and the environment.” Individuals and organizations performing regulated 

activities bear the primary responsibility for safety and security. The performance of individuals 

and organizations can be monitored and trended and, therefore, may be used to determine 

compliance with requirements and commitments and may serve as an indicator of possible 

problem areas in an organization’s safety culture. The NRC will not monitor or trend values. 

These will be the organization’s responsibility as part of its safety culture program. 

Organizations should ensure that personnel in the safety and security sectors have an 

appreciation for the importance of each, emphasizing the need for integration and balance to 

achieve both safety and security in their activities. Safety and security activities are closely 

intertwined. While many safety and security activities complement each other, there may be 

instances in which safety and security interests create competing goals. It is important that 

consideration of these activities be integrated so as not to diminish or adversely affect either; 

thus, mechanisms should be established to identify and resolve these differences. A safety 

culture that accomplishes this would include all nuclear safety and security issues associated 

with NRC-regulated activities. 

Experience has shown that certain personal and organizational traits are present in a positive 

safety culture. A trait, in this case, is a pattern of thinking, feeling, and behaving that 

emphasizes safety, particularly in goal conflict situations, e.g., production, schedule, and the 

cost of the effort versus safety. It should be noted that although the term ‘‘security’’ is not 

expressly included in the following traits, safety and security are the primary pillars of the NRC’s 

regulatory mission. Consequently, consideration of both safety and security issues, 

commensurate with their significance, is an underlying principle of this Statement of Policy. 
S-2 

The following are traits of a positive safety culture: 

(1) Leadership Safety Values and Actions – Leaders demonstrate a commitment to safety in 

their decisions and behaviors; 

(2) Problem Identification and Resolution – Issues potentially impacting safety are promptly 

identified, fully evaluated, and promptly addressed and corrected commensurate with 

their significance; 

(3) Personal Accountability – All individuals take personal responsibility for safety; 

(4) Work Processes – The process of planning and controlling work activities is 

implemented so that safety is maintained; 

(5) Continuous Learning – Opportunities to learn about ways to ensure safety are sought 

out and implemented; 

(6) Environment for Raising Concerns – A safety-conscious work environment is maintained 

where personnel feel free to raise safety concerns without fear of retaliation, intimidation, 

harassment, or discrimination; 

(7) Effective Safety Communication – Communications maintain a focus on safety; 

(8) Respectful Work Environment – Trust and respect permeate the organization; and 

(9) Questioning Attitude – Individuals avoid complacency and continuously challenge 

existing conditions and activities in order to identify discrepancies that might result in 

error or inappropriate action. 

There may be traits not included in this Statement of Policy that are also important in a positive 

safety culture. It should be noted that these traits were not developed to be used for inspection 

purposes. 

It is the Commission’s expectation that all individuals and organizations, performing or 

overseeing regulated activities involving nuclear materials, should take the necessary steps to 

promote a positive safety culture by fostering these traits as they apply to their organizational 

environments. The Commission recognizes the diversity of these organizations and 

acknowledges that some organizations have already spent significant time and resources in 

the development of a positive safety culture. The Commission will take this into consideration 

as the regulated community addresses the Statement of Policy.



UNITED STATES

NUCLEAR REGULATORY COMMISSION

WASHINGTON, DC 20555-0001

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OFFICIAL BUSINESS
NUREG-1556, Vol. 14

Revision 1, Draft

Consolidated Guidance about Materials Licenses: Program-Specific Guidance 

about Well Logging, Tracer, and Field Flood Study Licenses