IMC 1248, Appendix C

Training Requirements and Qualification Journal for Materials Exempt Distribution

License Reviewers
Issue Date: 04/19/13 C-1 1248

APPENDIX C

TRAINING REQUIREMENTS FOR MATERIALS

EXEMPT DISTRIBUTION LICENSE REVIEWERS

A. APPLICABILITY

The training described below is required for all materials license reviewers assigned to perform 

radiological safety reviews of exempt distribution license applications. 

B. TRAINING

1. Required Initial Training

a. Self Study and on-the job Training

(1) NRC Orientation

(2) Code of Federal Regulations

(3) Office Instructions 

(4) Regulatory Guidance

(5) NRC Management Directives

(6) NUDOCS/ADAMS

(7) Directed Review of Selected Licensing Case Work

b. Core Training. These courses establish minimum formal classroom training 

requirements. Refer to Section 1248-11 for exceptions to these requirements. 

(1) Health Physics Technology Course (H-201)

(2) Licensing Practices and Procedures Course (G-109)

(3) NMSS Radiation Worker Training Course (H-102)

 

c. Specialized Training. Additional courses may be required in order to gain 

knowledge necessary for specialized licensing activities. Management will make 

this determination on an individual basis. 

2. Supplemental Training. Additional training beyond that identified as Core Training. 

This training will be determined by the individual's supervisor and will depend on the 

individual's previous work experience and planned inspection or licensing activities in 

specific areas.
Issue Date: 04/19/13 C-2 1248

3. Refresher Training. Refresher training will include the following course and other 

courses as determined by management:

a. Health Physics Topical Review Course (H-401)
Issue Date: 04/19/13 C-3 1248

MATERIALS EXEMPT DISTRIBUTION LICENSE REVIEWER

NRC LICENSE REVIEWER QUALIFICATION JOURNAL

Applicability

This NRC License Reviewer Qualification Journal implements NRC Manual Chapter 1248, by 

establishing the minimum training requirements for personnel assigned to perform license 

reviews for exempt distribution applications. 

The NRC License Reviewer Qualification Journal serves as a guideline for the development of a 

Qualification Journal, and establishes the minimum training requirements consistent with NRC 

Manual Chapter 1248. The Qualification Journal must provide traceable documentation to show 

that minimum requirements are met for each license reviewer.

The NRC License Reviewer Qualification Journal consists of a series of qualification guides and 

signature cards. Each signature card is used to document task completion, as indicated by the 

appropriate signature blocks. The corresponding qualification guide establishes the minimum 

knowledge levels or areas of study that must be completed for each signature card. 

Most of the qualification guides are divided into sections. The review sections of the qualification 

guides identify references with general application to the license reviewer's qualification. The 

license reviewer is expected to have a general familiarity with these references. Other sections 

of the qualification guides identify specific references that have direct application to the license 

review discipline. The license reviewer is expected to demonstrate detailed knowledge of the 

license review specific references.

In order to support the review of upper tier documents, programs, and policies, the license

reviewer's immediate supervisor will assign specific materials licenses as reference licenses. 

The selection of reference licensees is intended to provide the license reviewer's management 

with the ability to tailor the qualification process to the experience and training level of the license 

reviewer, and to meet the needs of the NRC. The use of specific real world material will reinforce 

the qualification process.
Issue Date: 04/19/13 C-4 1248

LICENSE REVIEWER QUALIFICATION JOURNAL

Materials Exempt Distribution License Reviewer

 

Name Title Branch Section

To complete your qualification as a Materials Exempt Distribution License Reviewer you are to 

complete the following signature cards. All signoffs shall include the signature of the responsible 

reviewer and the date. Maintain these cards in a notebook along with any background or written 

material required by the program. This notebook will comprise your NRC License Reviewer 

Qualification Journal.

Signature When Complete Date

1. NRC Orientation 

First Line Supervisor

2. Code of Federal Regulations 

First Line Supervisor

3. Office Instructions 

First Line Supervisor

4. Regulatory Guidance 

First Line Supervisor

5. NRC Management Directives 

First Line Supervisor

6. NUDOCS/ADAMS 

First Line Supervisor

7. Directed Review of Selected

Licensing Case Work 

First Line Supervisor

8. Formal Training 

 First Line Supervisor
Issue Date: 04/19/13 C-5 1248

Qualification Board 

Requirements Met Second Level Supervisor 

or Board Chairman

Recommended as a qualified

exempt distribution license 

reviewer Second Level Supervisor

Certification Memo Issued 

granting signature authority Second Level Supervisor 

Signature Authority

A. SIGNATURE AUTHORITY1- License signature authority is divided into two phases with 

reviewers authorized for more routine casework first and more complex casework later. 

1. Phase I - Reviewer must demonstrate program knowledge by competent 

completion of a minimum of 5 - 10 new, renewal or amendment2licensing actions 

(at least 1 new or renewal licensing action in each category) under the supervision 

of the assigned senior reviewer in each of the following categories:

a. 32.14 (certain items)

b. 32.17 (resins)3

c. 32.18 (small quantities)

d. 32.21 (carbon-14 urea capsules)

2. Phase II - Reviewer must demonstrate program knowledge by competent 

completion of at least 1 new, renewal or amendment3licensing action in each 

category under the supervision of the assigned senior reviewer in each of the 

following categories:

a. 32.11 (exempt concentrations and items)

b. 32.22 (self-luminous products)

 

1As the reviewer completes the specific category knowledge and completed case requirements, the reviewer can 

be delegated signature authority for that specific category.

2The amendment would consist of a change of ownership, new product or device review and would be considered 

of an equivalent difficulty level as a new or renewal licensing action.

3When the reviewer meets the ''32.14 and 32.18 category requirements, signature authority for '32.17 will be 

automatically delegated.
Issue Date: 04/19/13 C-6 1248

c. 32.26 (smoke detectors)

Competency will be determined by review of completed deficiency letters and licenses, 

and an oral examination of exempt distribution licensing, conducted by the Section 

Leader or the assigned senior health physicist/exempt license reviewer. The Section 

Leader or the assigned senior health physicist\exempt license reviewer will complete 

Qualification Guide 6 for each license reviewed, and will discuss comments with the 

license reviewer-in-training.
Issue Date: 04/19/13 C-7 1248

Qualification Card 1

NRC Orientation

A. Site Orientation

Initials Date

1. New employee processing

package completed 

Employee

2. Facility tour and introduction 

First Line Supervisor 

B. NRC Organization

1. Review of NRC headquarters

and regional organization 

Employee

2. Discussion of NRC organization

 

First Line Supervisor 
Issue Date: 04/19/13 C-8 1248

Qualification Card 2

Code of Federal Regulations(CFR)

Initials Date

A. Familiarization with selected

CFR parts completed 

Employee

B. Discussion completed on CFR

parts related to the materials

license review program 

First Line Supervisor
Issue Date: 04/19/13 C-9 1248

Qualification Card 3

Office Instructions 

Initials Date

A. Familiarization with office

policies and procedures 

Employee

B. Discussion completed on

office policies and procedures 

First Line Supervisor
Issue Date: 04/19/13 C-10 1248

Qualification Card 4

Regulatory Guidance

Initials Date

A. Review of regulatory guidance

1. Regulatory Guides _________________ ______

Employee

2. Information Notices

/Bulletins

_________________ ______

Employee

3. NUREGs

_________________ ______

Employee

4. Generic Letters _________________ ______

Employee

5. Federal Register Notices

_________________ ______

Employee

6. NRC Branch Technical Positions

_________________ ______

Employee

7. Policy and Guidance Directives

_________________ ______

Employee

8. Standard Deficiency Paragraphs

_________________ ______

Employee

9. Standard License Conditions _________________ ______

Employee

10. Licensing Checklists _________________ ______

Employee

11. Standard Review Plans _________________ ______

Employee

12. Sealed Source and

Device Registry _________________ ______

Employee
Issue Date: 04/19/13 C-11 1248

13. Technical Assistance Requests _________________ ______

Employee

B. Discussion of regulatory guidance

with application to the materials

license review program _________________ ______

 First Line Supervisor 
Issue Date: 04/19/13 C-12 1248

Qualification Card 5

NRC Management Directives

Initials Date

A. Review of selected portions of

the NRC Management Directives 

completed _________________ ______

Employee

B. Discussion of the application

of the NRC Management Directives

to the materials license review

program ___________________ ______

First Line Supervisor
Issue Date: 04/19/13 C-13 1248

Qualification Card 6

NUDOCS/ADAMS

Initials Date

A. Review of selected portions of

the NUDOCS/ADAMS User's Manual and 

system access completed _______________________ ______

First Line Supervisor or 

Senior license reviewer

B. Familiarization with NUDOCS/ADAMS

station(s) and operation 

Employee 
Issue Date: 04/19/13 C-14 1248

Qualification Card 7

Directed Review of Selected Licensing Case Work

Initials Date

A. Review of selected licensing

Casework _______

 Employee

B. Completion4of Phase 1 (QG 7)/

Discussion by First Line

Supervisor of directed review of the

selected casework and its 

relation to exempt distribution

license review program _________________ _______

First Line Supervisor

C. Completion1of Phase 2 (QG 7)/

Discussion by First Line

Supervisor of directed review of the

selected casework and its relation

to the exempt distribution license

review program _____________________ _______

First Line Supervisor

 

4

As the reviewer completes the specific category knowledge and completed case requirements, the 

reviewer can be delegated signature authority for that specific category.
Issue Date: 04/19/13 C-15 1248

Qualification Card 8

Formal Training

Initials Date

A, CORE TRAINING:

1. Health Physics Technology

Course (H-201) (or classification

as a 1306) ____________________ _____

Training Coordinator

2. Licensing Practices and Procedures

Course (G-109) ____________________ _____

Training Coordinator

3. NMSS Radiation Worker Training 

Course (H-102) 

Training Coordinator

B. SPECIALIZED TRAINING:

Other specialized training courses required for license reviewers performing licensing activities in 

specific areas:

Course Title Course # Initials Initials Date

__ _ 

 Supervisor Training Coordinator 

__ _ 

 Supervisor Training Coordinator 

__ _ 

 Supervisor Training Coordinator 
Issue Date: 04/19/13 C-16 1248

Qualification Guide 1

NRC Orientation

A. Site Orientation

1. The qualifying individual should read and complete, as appropriate, the following 

forms for processing into the NRC:

a. Personnel information

b. Health insurance elections

c. Retirement plan elections

d. Savings elections (e.g. U.S. Savings Bonds, TSP, etc.)

e. Fitness for Duty requirements and physical examination

f. Any other forms which may be required by NRC Office of 

Human Resources

g. Forms for issuance of tagged, controlled NRC equipment

h. Payroll forms and time cards

i. Regulatory Information Tracking System (RITS)

2. The First Line Supervisor should orient the qualifying individual to the facility as 

follows:

a. Tour the facility and introduce the qualifying individual to the staff

b. Indicate to the qualifying individual the location of controlled documents, 

reference material, supplies, office equipment, classrooms, etc.

B. NRC Organization

1. The qualifying individual should review and become familiar with:

a. Organizational charts of division, NMSS, regions and headquarters and 

overall NRC organization (NUREG 0325)

b. Role of Headquarters in policy and interpretation of regulations

c. Role of NRC General Counsel

d. Role of NRC Inspector General

e. Role of NRC Public Affairs
Issue Date: 04/19/13 C-17 1248

f. Role of NRC Office of Investigations

g. Role of NRC Office of Enforcement

h. Physical location of NRC offices and regions

i. Role of NRC as a regulatory agency 

(1) 10 CFR Part 1 (Organization)

(2) Atomic Energy Act of 1954, as amended

(3) Energy Reorganization Act of 1974, as amended

(4) NRC Enforcement Policy (NUREG 1600)

(5) Incident Response Plan (NUREGs 0728 and 0845) 

(6) Energy Policy Act of 1992

2. The First Line Supervisor should discuss NRC organization and role with the 

qualifying individual to ensure the qualifying individual has a full understanding of 

NRC's organization and mission and the role of the license reviewer in that 

mission.
Issue Date: 04/19/13 C-18 1248

Qualification Guide 2

Code of Federal Regulations (CFR)

A. A selection of currently applicable CFR Parts should be made by the First Line Supervisor. 

The selection should include the references listed below and be documented. The 

qualifying individual should be expected to have a general knowledge of the topics 

addressed in the references. This review may be accomplished by self-study, 

study-quizzes, briefings, or discussions. 

1. 10 CFR Part 1 Statement of organization and general information

2. 10 CFR Part 2 Rules of practice for domestic licensing proceedings and 

issuance of orders

3. 10 CFR Part 9 Public Records

4. 10 CFR Part 19 Notices, instructions and reports to workers; inspections

5. 10 CFR Part 20 Standards for protection against radiation (includes 

selected Questions and Answers, Q & As)

6. 10 CFR Part 21 Reporting of defects and noncompliance

7. 10 CFR Part 30 Rules of general applicability to domestic

licensing of byproduct material

8. 10 CFR Part 31 General domestic licenses for byproduct material

9. 10 CFR Part 32 Specific domestic licenses to manufacture or transfer 

certain items containing byproduct material

10. 10 CFR Part 40 Domestic licensing of source material

11 10 CFR Part 70 Domestic licensing of special nuclear material

12. 10 CFR Part 71 Packaging and transportation of radioactive material

13. 10 CFR Part 110 Export and import of nuclear equipment and material

14. 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

15. 10 CFR Part 171 Annual fees for reactor operating 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 NRC
Issue Date: 04/19/13 C-19 1248

16. 49 CFR Part Transportation

173.421

17. 10 CFR Parts Statements of Consideration

30, 31, and 32

B. Following completion of the qualifying individual=s self study of the listed 10 CFR Parts, a 

discussion will be held with the qualifying license reviewer by the First Line Supervisor to 

test the qualifying license reviewer=s knowledge of these Parts. To the extent possible, 

recent application of various sections, new regulatory initiatives, and current industry 

issues should be emphasized.
Issue Date: 04/19/13 C-20 1248

Qualification Guide 3

Office Instructions

A. Office/Division Policies and Procedures

1. Read the Office/division Policy and Procedures Manual

2. The qualifying individual should review the Office/Division policies and 

practices on:

a. Travel, including Management Directive 14.1 Official Temporary Duty 

Travel

b. Telephone use

c. Policies on use of annual leave and sick leave and excused leave, 

including Bulletin 4135, Leave Administration.

d. Work schedule, including NRC Appendix 4136, Hours of Work and

Premium Pay

e. Use of government equipment, including computers (NUDOCS and 

ADAMS) and Management Directive 13.1, Property Management

f. Union activities, including Management Directive 10.102, 

Labor-Management Relations Program for Federal Employees

g. Communications outside NRC

h. Policies on outside employment and acceptance of gifts

i. Participation in political activities

j. Routing of mail and procedures for sending mail and materials (via U.S. 

Mail, Federal Express, etc.), including Management Directive 3.23, Mail 

Management

k. Ordering of documents (e.g., NUREGs)

l. Division emergency and evacuation procedures

m. Employee appraisal system and Individual Development Plan (IDP)

(1) Employee trial period (Management Directive 10.14 Employment 

and Staffing)

(2) Employee appraisals (Management Directive 10.67, Non-SES 

Performance Appraisal System)

o. Differing Professional Views or Opinions (Management Directive

10.159, General Personnel Management Provisions) 
Issue Date: 04/19/13 C-21 1248

B. The First Line Supervisor should discuss these policies and practices with the qualifying 

individual to ensure that the qualifying individual has a full and complete understanding.
Issue Date: 04/19/13 C-22 1248

Qualification Guide 4

Regulatory Guidance

A. A selection of currently applicable regulatory guidance should be identified by the First 

Line Supervisor. These references should include those listed below and should be 

documented. The qualifying individual should be expected to have a general knowledge of 

the topics addressed in the references. The review may be accomplished by self-study, 

study-quizzes, briefings, or discussions. Note that many Regulatory Guides reference or 

endorse industry codes and standards listed in Qualification Guide 6. Study of 

corresponding and sub-tier codes and standards is recommended. 

1. Regulatory Guides (use latest revision)

6.6 Acceptance Sampling Procedures for Exempted and Generally 

Licensed Items Containing Byproduct Material

6.9 QA Programs for Manufacture & Distribution of Sealed Sources and 

Devices Containing Byproduct Material

2. Information Notices(IN) and Bulletins(BL)

IN 94-047 Accuracy of Information Provided to NRC During the Licensing 

Process

Others as selected by the First Line Supervisor

3. NUREGs (latest revision, where applicable)

NUREG 1460 Guide to NRC Reporting and Recordkeeping Requirements

NUREG 1556 Consolidated Guidance About Materials Licenses:

Vol. 3: Applications for Sealed Source and Device Evaluation 

and Registration

Vol. 8: Program-Specific Guidance About Exempt Distribution 

Licenses

Vol. 15: Program-Specific Guidance About Changes of Control and 

About Bankruptcy Involving Byproduct, Source, or Special 

Nuclear Material Licenses 

NUREG/CR 1775 Environmental Assessment of Consumer Products 

Containing Radioactive Material

Others as selected by the First Line Supervisor
Issue Date: 04/19/13 C-23 1248

4. Generic Letters (GL)

GL 88-004 Distribution of Gems Irradiated In Research Reactors

Others as selected by the First Line Supervisor

5. Policy and Guidance Directives

6. Standard Deficiency Paragraphs

7. Standard License Conditions

8. Licensing Checklists

9. Sealed Source and Device Registry

10. Technical Assistance Requests

As selected by the First Line Supervisor 

B. The application of these guidance documents to the materials license review program 

should be studied in detail by the qualifying individual and covered by the First Line 

Supervisor in discussions, interviews, or oral quizzes. 
Issue Date: 04/19/13 C-24 1248

Qualification Guide 5

NRC Management Directives

A. A selection of currently applicable NRC Management Directive (MD)references should be 

identified by the First Line Supervisor. These references should include those listed 

below and be documented. The qualifying license reviewer should be expected to have a 

general knowledge of the topics addressed in the references. This review may be 

accomplished by self-study, study-quizzes, briefings, or discussions. The selection 

should include:

1. NRC MD 9.1 Organization Management

2. NRC MD 9.29 Organization and Function of Regional Offices

3. NUREG 0325 USNRC Functional Organization Chart

4. NRC MD 3.2 Privacy Act

5. NRC MD 3.1 Freedom of Information Act

6. NRC MD 10.131 Protection of NRC Employees Against Ionizing Radiation

7. NRC MD 14.1 Official Temporary Duty Travel

8. NRC MD 10.159 Differing Professional Views or Opinions

9. NRC MD 10.42 Hours of Work and Premium Pay

10. NRC MD 10.43 Time and Attendance Reporting

11. NRC MD 10.67 Non-SES Performance Appraisal System

12. NRC MD 10.101 Employee Grievances

13. NRC MD 8.8 Management of Allegations

B. Application of the selected NRC Management Directives to the materials license review 

program will be discussed with the qualifying individual by the First Line Supervisor to test 

the qualifying individual's knowledge.
Issue Date: 04/19/13 C-25 1248

Qualification Guide 6

NUDOCS/ADAMS

The use and training for NUDOCS/ADAMS will consist of a PDC course in using ADAMS; review 

of the NUDOCS User Manual; ADAMS USER GUIDE; knowledge of NUDOCS station(s), 

access, and operation to locate NRC (Non-ADAMS) document records; knowledge of capturing 

and retrieving ADAMS documents. 
Issue Date: 04/19/13 C-26 1248

Qualification Guide 7

Certification - Directed Review of Selected Licensing Case Work

Amendment No.: Control No.: 

Licensee Name: 

Address: 

 

License No.: Docket No.: 

Reference No.: Expiration Date: 

Action Type: New License New License/Licensee 

Renewal Product Transfer 

Amendment Termination 

Program Code/Type:

Exempt Concentrations (Gemstones) 03251/32.11 

Certain Items (Electron tubes, Watches) 03251/32.14 

Resins 03252/32.17 

Small Quantities (Check sources) 03253/32.18 

Carbon-14 urea capsules 03256/32.21 

Self Luminous Products (Watches, Gunsights) 03254/32.22 

Gas & Aerosol Detectors (Smoke detectors) 03255/32.26 

I certify that I have reviewed the licensee's request dated as supplemented by 

any letters referenced in the license and in accordance with guidance provided by the Office of 

Nuclear Material Safety and Safeguards applicable Standard Review Plans and the attached 

checklist.

 

 REVIEWER DATE

 

 PERSON SIGNING THE LICENSE DATE

GENERAL COMMENTS: 

 
Issue Date: 04/19/13 C-27 1248

Qualification Guide 8

Formal Training

The standards for each Training Course are provided in the NRC Technical Training Center 

Course Catalog and will not be duplicated in the Qualification Guide.
Issue Date: 04/19/13 Att1-1 1248

Attachment 1

Revision History for IMC 1248, Appendix C

Commitment 

Tracking 

Number

Accession 

Number

Issue Date

Change Notice

Description of Change Description of

Training Required

and Completion Date

Comment 

Resolution 

Accession Number

N/A ML112360125 

10/26/11 

CN 11-022

Revision history sheet added. 

Combined Appendix A11 with 

Appendix B11 and renamed as IMC 

1246 Appendix E6. Added “training 

requirements” section from Appendix 

A11. 

N/A ML112360165 

N/A ML12240A154

04/19/13

CN 13-011

IMC 1248 Appendix C was created to 

replace IMC 1246 Appendix E6 and 

remove FSME activities from the 

NMSS qualification journal IMC 1246 

series. The qualification was 

originally published on January 5, 

2001. No changes were made to the 

training requirements or qualification 

journal since they were published on 

January 5, 2001.

N/A N/A