NUREG-1712

Nuclear Byproduct Material

Risk Review 

Results of Survey of NRC and Agreement 

State Materials Licensing and Inspection 

Personnel 

Final Report

U.S. Nuclear Regulatory Commission 

Office of Nuclear Material Safety and Safeguards 

Washington, DC 20555-0001

4. 0 p 4 

I- K 

., 4.
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NUREG-1712

Nuclear Byproduct Material 

Risk Review 

Results of Survey of NRC and Agreement 

State Materials Licensing and Inspection 

Personnel 

Final Report 

Manuscript Completed: February 2000 

Date Published: April 2000 

Prepared by 

D. Serig, J. Lubinski, E. Ullrich, J. Randall, N. Daugherty* 

*State of Colorado 

Department of Public Health and Environment 

8100 Lowry Boulevard 

Denver, CO 80220-6928 

Division of Industrial and Medical Nuclear Safety 

Office of Nuclear Material Safety and Safeguards 

U.S. Nuclear Regulatory Commission 

Washington, DC 20555-0001
ABSTRACT 

This project responded to NRC's Direction Setting Issue 12, Risk-Informed, Performance-Based 

Regulation. Its scope was limited to nuclear byproduct materials as defined in Section 1 1.e(l) of 

the Atomic Energy Act of 1954 and Title 10 of the Code of Federal Regulations (CFR), Section 

30.4. 10 CFR Parts 30 through 36 and 39 address regulation of those materials. The goal was to 

confirm and augment information on nuclear byproduct material systems obtained from other 

sources. The process involved (1) use of a list of nuclear byproduct material systems based on 

how the nuclear byproduct material was used, (2) a survey of NRC and Agreement State 

materials licensing and inspection personnel concerning typical annual doses to workers for the 

various systems, safety of each system under various conditions, the types and frequencies of 

incidents occurring at each system, definitions of safety, and opinions about the appropriate 

bases for regulatory decision making, and (3) summarization of the respondent's answers to 

those questions.

iff
CONTENTS 

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

1 RESPONSES TO QUESTIONS ABOUT ANNUAL WORKER DOSES, SAFETY UNDER 

VARIOUS CONDITIONS, AND EVENTS THAT OCCUR BY SYSTEM ....................... 1-1 

1.1 SYSTEM 1: RESEARCH AND DEVELOPMENT SYNTHESIS LABORATORIES ............ 1-2 

1.2 SYSTEM 2: RESEARCH AND DEVELOPMENT LABORATORIES USING CARBON, 

HYDROGEN, IODINE, PHOSPHOROUS, AND SULFUR ................................ 1-3 

1.3 SYSTEM 3: IN VITRO TESTING .................................................... 1-4 

1.4 SYSTEM 4: 10 CFR 35.100 -NUCLEAR MEDICINE AND HUMAN USE RESEARCH ...... 1-5 

1.5 SYSTEM 5: 10 CFR 35.200 - NUCLEAR MEDICINE WITH GENERATOR(S) .............. 1-6 

1.6 SYSTEM 6: 10 CFR 35.200 - NUCLEAR MEDICINE WITHOUT A GENERATOR .......... 1-7 

1.7 SYSTEM 7: 10 CFR 35.300 -NUCLEAR MEDICINE .................................. 1-8 

1.8 SYSTEM 8: BRACHYTHERAPY - USING SEEDS .................................... 1-9 

1.9 SYSTEM 9: BRACHYTHERAPY - MANUAL AFTERLOADING ....................... 1-10

1.10 

1.11 

1.12 

1.13 

1.15 

1.16 

1.17 

1.18 

1.19 

1.20 

1.21 

1.22 

1.23 

1.24 

1.25 

1.26 

1.27 

1.28 

1.29 

1.30 

1.31 

1.32 

1.33 

1.34 

1.35 

1.36 

1.37

SYSTEM 10: BRACHYTHERAPY - LOW DOSE RATE REMOTE AFTERLOADING ...... 1-11 

SYSTEM 11: BRACHYTHERAPY - HIGH DOSE RATE REMOTE AFTERLOADING ...... 1-13 

SYSTEM 12: BRACHYTHERAPY - EYE APPLICATOR ............................ 1-14 

SYSTEM 13: 10 CFR 35.400- DIAGNOSTIC DEVICES ............................. 1-15 

SYSTEM 14: TELETHERAPY DEVICES ............................................ 1-17 

SYSTEM 15: GAMMA STEREOTACTIC SURGERY .................................. 1-18 

SYSTEM 16: NUCLEAR PHARMACIES ......................................... 1-19 

SYSTEM 17: VETERINARY USE .................................................. 1-20 

SYSTEM 18: RESEARCH AND DEVELOPMENT ON ANIMALS ........................ 1-21 

SYSTEM 19: WELL-LOGGING - TRACERS AND FIELD FLOOD STUDIES ............. 1-22 

SYSTEM 20: WELL LOGGING - USING SEALED SOURCES ........................... 1-23 

SYSTEM 21: RADIOGRAPHY - PERMANENT INSTALLATION ....................... 1-24 

SYSTEM 22: RADIOGRAPHY - FIELD USE ........................................ 1-25 

SYSTEM 23: POOL IRRADIATORS ................................................ 1-27 

SYSTEM 24: SELF-SHIELDED IRRADIATORS ..................................... 1-28 

SYSTEM 25: FIXED GAUGES - GAMMA EMITTERS ................................ 1-29 

SYSTEM 26: FIXED GAUGES - BETA EMITTERS .................................. 1-30 

SYSTEM 27: PORTABLE GAUGES ................................................ 1-31 

SYSTEM 28: X-RAY FLUORESCENCE DEVICES .................................... 1-32 

SYSTEM 29: GAS CHROMATOGRAPHS ............................................ 1-33 

SYSTEM 30: OTHER MEASURING SYSTEMS ....................................... 1-34 

SYSTEM 31: SMALL SEALED SOURCES OR DEVICES ............................. 1-35 

SYSTEM 32: VERY SMALL SEALED SOURCES OR DEVICES ......................... 1-36 

SYSTEM 33: MANUFACTURING OR DISTRIBUTION OF DEVICES CONTAINING 

SEALED SOURCES ......................................................... 1-37 

SYSTEM 34: MANUFACTURING OF RADIOACTIVE SOLIDS ......................... 1-38 

SYSTEM 35: MANUFACTURING OF SOURCES CONTAINING LIQUIDS ................ 1-39 

SYSTEM 36: MANUFACTURING OF SOURCES CONTAINING GASES .................. 1-40

V
CONTENTS

1.38 SYSTEM 37: INCINERATION OF WASTE ............................................ 1-41 

1.39 SYSTEM 38: COMPACTING OF WASTE ............................................ 1-42 

1.40 SYSTEM 39: PACKAGING OF WASTE ............................................. 1-43 

1.41 SYSTEM 40: SOLIDIFICATION OF WASTE ......................................... 1-44 

1.42 SYSTEM 41A: NUCLEAR LAUNDRIES ............................................. 1-46 

1.43 SYSTEM 41B: DECONTAMINATION SERVICES .................................... 1-46 

2 RANK ORDERING OF NUCLEAR BYPRODUCT MATERIAL SYSTEMS .................... 2-1 

3 RESPONDENTS DEFINITIONS OF "SAFE" ETC .......................................... 3-1 

4 RESPONSES TO QUESTIONS ABOUT REGULATORY DECISION-MAKING ................ 4-1 

APPENDICES 

A Questionnaire .......................................................................... A -1 

B Correspondence Related to the Questionnaire ................................................. B-1 

C Responses to Comments on Draft NUREG-1712 ....................................... C-1 

TABLES 

Table 1. 1 Modal Selections on Questions Related to the Safety of Research and Development Synthesis 

Laboratories Under Various Conditions(Ns =30 to 34) ................................... 1-2 

Table 1.2 Median Selections on Questions Related to the Safety of Research and Development Synthesis 

Laboratories Under Various Conditions (Ns = 30 to 34) .................................. 1-2 

Table 1.3 Modal Selections on Questions Related to the Safety of Research and Development Laboratories 

Using Carbon, Hydrogen, Iodine, Phosphorous, and Sulfur Under Various 

Conditions (Ns = 37 to 39) ......................................................... 1-3 

Table 1.4 Median Selections on Questions Related to the Safety of Research and Development Laboratories 

Using Carbon, Hydrogen, Iodine, Phosphorous, and Sulfur Under Various 

Conditions (Ns = 37 to 39) ......................................................... 1-3 

Table 1.5 Modal Selections on Questions Related to the Safety of In Vitro Testing Under Various 

Conditions (Ns = 37 to 39) ......................................................... 1-4 

Table 1.6 Median Selections on Questions Related to the Safety of In Vitro Testing Under Various 

Conditions (Ns = 37 to 39) ......................................................... 1-4 

Table 1.7 Modal Selections on Questions Related to the Safety of 10 CFR 35.100 - Nuclear Medicine and 

Human Use Research Under Various Conditions (Ns = 35 to 38) ........................... 1-5 

Table 1.8 Median Selections on Questions Related to the Safety of 10 CFR 35.100 - Nuclear Medicine and 

Human Use Research Under Various Conditions (Ns = 35 to 38) ........................... 1-5 

Table 1.9 Modal Selections on Questions Related to the Safety of 10 CFR 35.200 - Nuclear Medicine with 

Generator(s) Under Various Conditions (Ns = 36 to 38) .................................. 1-6 

Table 1.10 Median Selections on Questions Related to the Safety of 10 CFR 35.200 - Nuclear Medicine 

with Generator(s) Under Various Conditions (Ns = 36 to 38) .............................. 1-6 

vi
CONTENTS

Table 1.12 Median Selections on Questions Related to the Safety of 10 CFR 35.200 - Nuclear Medicine 

Without a Generator Under Various Conditions (Ns = 35 to 38) ........................... 1-7 

Table 1.13 Modal Selections on Questions Related to the Safety of 10 CFR 35.300 - Nuclear Medicine 

Under Various Conditions (Ns = 35 to 38) ............................................ 1-8 

Table 1.14 Median Selections on Questions Related to the Safety of 10 CFR 35.300 - Nuclear Medicine 

Under Various Conditions (Ns = 35 to 38) ............................................ 18 

Table 1.15 Modal Selections on Questions Related to the Safety of Brachytherapy - Using Seeds Under 

Various Conditions (Ns = 36 to 37) .................................................. 1-9 

Table 1.16 Median Selections on Questions Related to the Safety of Brachytherapy - Using Seeds Under 

Various Conditions (Ns =36 to 37) ................................................. 1-10 

Table 1.17 Modal Selections on Questions Related to the Safety of Brachytherapy - Manual Afterloading 

Under Various Conditions (Ns = 33 to 34) ........................................... 1-10 

Table 1.18 Median Selections on Questions Related to the Safety of Brachytherapy - Manual Afterloading 

Under Various Conditions (Ns = 33 to 34) ........................................... 1-11 

Table 1.19 Modal Selections on Questions Related to the Safety of Brachytherapy - Low Dose Rate 

Remote Afterloading Under Various Conditions (Ns = 32 to 34) .......................... 1-12 

Table 1.20 Median Selections on Questions Related to the Safety of Brachytherapy - Low Dose Rate 

Remote Afterloading Under Various Conditions (Ns = 32 to 34) .......................... 1-12 

Table 1.21 Modal Selections on Questions Related to the Safety of Brachytherapy - High Dose Rate 

Remote Afterloading Under Various Conditions (Ns = 36 to 38) .......................... 1-13 

Table 1.22 Median Selections on Questions Related to the Safety of Brachytherapy - High Dose Rate 

Remote Afterloading Under Various Conditions (Ns = 36 to 38) .......................... 1-13 

Table 1.23 Modal Selections on Questions Related to the Safety of Brachytherapy - Eye Applicator 

Under Various Conditions (Ns = 31 to 32) ........................................... 1-14 

Table 1.24 Median Selections on Questions Related to the Safety of Brachytherapy - Eye Applicator 

Under Various Conditions (Ns = 31 to 32) ........................................... 1-14 

Table 1.25 Modal Selections on Questions Related to the Safety of 10 CFR 35.400 - Diagnostic Devices 

Under Various Conditions (Ns = 22 to 25) ........................................... 1-15 

Table 1.26 Median Selections on Questions Related to the Safety of 10 CFR 35.400 - Diagnostic Devices 

Under Various Conditions (Ns = 22 to 25) ........................................... 1-15 

Table 1.27 Modal Selections on Questions Related to the Safety of 10 CFR 35.500 - Diagnostic Devices 

Under Various Conditions (Ns = 7 to 8) ............................................. 1-16 

Table 1.28 Median Selections on Questions Related to the Safety of 10 CFR 35.500 - Diagnostic Devices 

Under Various Conditions (Ns = 7 to 8) ............................................. 1-16 

Table 1.29 Modal Selections on Questions Related to the Safety of Teletherapy Devices Under Various 

Conditions (Ns = 35 to 36) ........................................................ 1-17 

Table 1.30 Median Selections on Questions Related to the Safety of Teletherapy Devices Under Various 

Conditions (Ns = 35 to 36) ........................................................ 1-17 

Table 1.31 Modal Selections on Questions Related to the Safety of Gamma Stereotactic Surgery Under 

Various Conditions (Ns = 24 to 25) ................................................. 1-18 

Table 1.32 Median Selections on Questions Related to the Safety of Gamma Stereotactic Surgery Under 

Various Conditions (Ns = 24 to 25) ................................................. 1-18 

Table 1.33 Modal Selections on Questions Related to the Safety of Nuclear Pharmacies Under Various 

Conditions (Ns = 34 to 37) ........................................................ 1-19 

Table 1.34 Median Selections on Questions Related to the Safety of Nuclear Pharmacies Under Various 

Conditions (Ns = 34 to 37) ........................................................ 1-19

vii
CONTENTS

Table 1.34 Median Selections on Questions Related to the Safety of Nuclear Pharmacies Under Various 

Conditions (Ns = 34 to 37) ........................................................ 1-19 

Table 1.35 Modal Selections on Questions Related to the Safety of Veterinary Use Under Various 

Conditions (Ns = 28 to 33) ........................................................ 1-20 

Table 1.36 Median Selections on Questions Related to the Safety of Veterinary Use Under Various 

Conditions (Ns = 28 to 33) ........................................................ 1-20 

Table 1.37 Modal Selections on Questions Related to the Safety of Research and Development on Animals 

Under Various Conditions (Ns = 29 to 34) ........................................... 1-21 

Table 1.38 Median Selections on Questions Related to the Safety of Research and Development on Animals 

Under Various Conditions (Ns = 29 to 34) ........................................... 1-21 

Table 1.39 Modal Selections on Questions Related to the Safety of Well Logging - Tracers and Field 

Flood Studies Under Various Conditions (Ns = 27 to 28) ................................ 1-22 

Table 1.40 Median Selections on Questions Related to the Safety of Well Logging - Tracers and Field 

Flood Studies Under Various Conditions (Ns = 27 to 28) ................................ 1-22 

Table 1.41 Modal Selections on Questions Related to the Safety of Well Logging - Using Sealed Sources 

Under Various Conditions (Ns = 28 to 30) ........................................... 1-23 

Table 1.42 Median Selections on Questions Related to the Safety of Well Logging - Using Sealed Sources 

Under Various Conditions (Ns = 28 to 30) ........................................... 1-23 

Table 1.43 Modal Selections on Questions Related to the Safety of Radiography - Permanent Installation 

Under Various Conditions (Ns = 37 to 38) ........................................... 1-24 

Table 1.44 Median Selections on Questions Related to the Safety of Radiography - Permanent Installation 

Under Various Conditions (Ns = 37 to 38) ........................................... 1-25 

Table 1.45 Modal Selections on Questions Related to the Safety of Radiography - Field Use Under 

Various Conditions (Ns = 38 to 39) ................................................. 1-26 

Table 1.46 Median Selections on Questions Related to the Safety of Radiography - Field Use Under 

Various Conditions (Ns = 38 to 39) ................................................. 1-26 

Table 1.47 Modal Selections on Questions Related to the Safety of Pool Irradiators Under Various 

Conditions (Ns = 35 to 37) .............................................. 1-27 

Table 1.48 Median Selections on Questions Related to the Safety of Pool Irradiators Under Various 

Conditions (Ns = 35 to 37) ........................................................ 1-27 

Table 1.49 Modal Selections on Questions Related to the Safety of Self-shielded Irradiators Under Various 

Conditions (Ns = 34 to 38) ........................................................ 1-28 

Table 1.50 Median Selections on Questions Related to the Safety of Self-shielded Irradiators Under Various 

Conditions (Ns = 34 to 38) ........................................................ 1-28 

Table 1.51 Modal Selections on Questions Related to the Safety of Fixed Gauges - Gamma Emitters 

Under Various Conditions (Ns = 37 to 38) ........................................... 1-29 

Table 1.52 Median Selections on Questions Related to the Safety of Fixed Gauges - Gamma Emitters 

Under Various Conditions (Ns = 37 to 38) ........................................... 1-29 

Table 1.53 Modal Selections on Questions Related to the Safety of Fixed Gauges - Beta Emitters Under 

Various Conditions (Ns = 36 to 37) ................................................. 1-30 

Table 1.54 Median Selections on Questions Related to the Safety of Fixed Gauges - Beta Emitters Under 

Various Conditions (Ns = 36 to 37) ................................................. 1-30 

Table 1.55 Modal Selections on Questions Related to the Safety of Portable Gauges Under Various 

Conditions (Ns = 37 to 38) ........................................................ 1-31 

Table 1.56 Median Selections on Questions Related to the Safety of Portable Gauges Under Various 

Conditions (Ns = 37 to 38) ........................................................ 1-31 

viii
CONTENTS

Table 1.57 Modal Selections on Questions Related to the Safety of X-ray Fluorescence Devices Under 

Various Conditions (Ns = 36 to 37) .................................................. 1-32 

Table 1.58 Median Selections on Questions Related to the Safety of X-ray Fluorescence Devices Under 

Various Conditions (Ns = 36 to 37) .................................................. 1-33 

Table 1.59 Modal Selections on Questions Related to the Safety of Gas Chromatographs Under Various 

Conditions (Ns = 37 to 40) ........................................................ 1-33 

Table 1.60 Median Selections on Questions Related to the Safety of Gas Chromatographs Under Various 

Conditions (Ns = 37 to 40) ........................................................ 1-34 

Table 1.61 Modal Selections on Questions Related to the Safety of Other Measuring Systems Under 

Various Conditions (Ns = 29 to 30) ................................................. 1-34 

Table 1.62 Median Selections on Questions Related to the Safety of Other Measuring Systems Under 

Various Conditions (Ns = 29 to 30) ................................................. 1-35 

Table 1.63 Modal Selections on Questions Related to the Safety of Small Sealed Sources or Devices 

Under Various Conditions (Ns = 37 to 38) ........................................... 1-35 

Table 1.64 Median Selections on Questions Related to the Safety of Small Sealed Sources or Devices 

Under Various Conditions (Ns = 37 to 38) ........................................... 1-36 

Table 1.65 Modal Selections on Questions Related to the Safety of Very Small Sealed Sources or Devices 

Under Various Conditions (Ns = 36 to 37) ........................................... 1-36 

Table 1.66 Median Selections on Questions Related to the Safety of Very Small Sealed Sources or Devices 

Under Various Conditions (Ns = 36 to 37) ........................................... 1-37 

Table 1.67 Modal Selections on Questions Related to the Safety of Manufacturing or Distribution of 

Devices Containing Sealed Sources Under Various Conditions (Ns = 37 to 38) ............... 1-37 

Table 1.68 Median Selections on Questions Related to the Safety of Manufacturing or Distribution of 

Devices Containing Sealed Sources Under Various Conditions (Ns = 37 to 38) ............... 1-38 

Table 1.69 Modal Selections on Questions Related to the Safety of Manufacturing of Radioactive Solids 

Under Various Conditions (Ns = 23 to 26) ........................................... 1-39 

Table 1.70 Median Selections on Questions Related to the Safety of Manufacturing of Radioactive Solids 

Under Various Conditions (Ns = 23.to 26) ........................................... 1-39 

Table 1.71 Modal Selections on Questions Related to the Safety of Manufacturing of Sources Containing 

Liquids Under Various Conditions (Ns = 20 to 23) ..................................... 1-40 

Table 1.72 Median Selections on Questions Related to the Safety of Manufacturing of Sources Containing 

Liquids Under Various Conditions (Ns = 20 to 23) ..................................... 1-40 

Table 1.73 Modal Selections on Questions Related to the Safety of Manufacturing of Sources Containing 

Gases Under Various Conditions (Ns = 18 to 21) ...................................... 1-41 

Table 1.74 Median Selections on Questions Related to the Safety of Manufacturing of Sources Containing 

Gases Under Various Conditions (Ns = 18 to 21) ...................................... 1-41 

Table 1.75 Modal Selections on Questions Related to the Safety of Incineration of Waste Under Various 

Conditions (Ns = 25 to 27) ........................................................ 1-42 

Table 1.76 Median Selections on Questions Related to the Safety of Incineration of Waste Under Various 

Conditions (Ns = 25 to 27) ........................................................ 1-42 

Table 1.77 Modal Selections on Questions Related to the Safety of Compacting of Waste Under Various 

Conditions (Ns = 25 to 28) ........................................................ 1-43 

Table 1.78 Median Selections on Questions Related to the Safety of Compacting of Waste Under Various 

Conditions (Ns = 25 to 28) ........................................................ 1-43 

Table 1.79 Modal Selections on Questions Related to the Safety of Packaging of Waste Under Various 

Conditions (Ns = 24 to 28) ........................................................ 1-44

ix
CONTENTS

Table 1.80 Median Selections on Questions Related to the Safety of Packaging of Waste Under Various 

Conditions (Ns = 24 to 28) ........................................................ 1-44 

Table 1.81 Modal Selections on Questions Related to the Safety of Solidification of Waste Under Various 

Conditions (Ns = 19 to 22) ........................................................ 1-45 

Table 1.82 Median Selections on Questions Related to the Safety of Solidification of Waste Under Various 

Conditions (Ns = 19 to 22) ........................................................ 1-45 

Table 2.1 Survey Results: Nuclear Byproduct Material Systems Rank Ordered With Respect To Mean 

Annual Estimated Dose to Workers in Millirem For Comparison With Modal and Median Dose 

Estimates And With Responses Related To Perceived Safety Under Various Conditions ......... 2-1 

Table 3.1 Each Respondent's Definition of "Very Safe," "Somewhat Safe," "Somewhat Unsafe," and 

"Very Unsafe" . .......... ....................................................... 3-1 

Table 4.1 Responses to Questions Concerning About Regulatory Agencies Should Make Decisions ....... 4-1 

I I Ix
1 RESPONSES TO QUESTIONS ABOUT ANNUAL WORKER 

DOSES, SAFETY UNDER VARIOUS CONDITIONS, AND 

EVENTS THAT OCCUR BY SYSTEM 

This section summarizes the respondent's opinions about typical annual worker doses for each 

system, the safety of each system under various conditions, and the most frequent non-reportable incidents for each system. It is important to note that NUREG-1712 uses many of the same 

system categories as shown in NUREG/CR-6642, "Risk Analysis and Evaluation of Regulatory Options for Nuclear Byproduct Material Systems," Table 1.4-1, but the systems listed in this 

NUREG are not identical to those in this NUREG/CR-6642. The numbering of the systems in 

NUREG-1712 is also different from NUREG/CR-6642. Also, the results from NUREG-1712 

were not used in NUREG/CR-6642. 

Item 1, under each system, summarizes the respondent's opinions about the number of workers 

typically receiving annual doses below specific levels.(e.g., 50 mrem/yr, 500 mrem/yr, etc.). Respondents were asked to indicate what percentage of workers typically received doses in 

various ranges. They could choose a single range for all workers or distribute workers over 

several dose ranges. Respondents exercised both options. Thus, the distribution of doses over 

various ranges reflects both the individual opinions of respondents as well as the opinions of 

respondents as a group. 

Item 2, under each system, summarizes the respondent's opinions of whether a system was very safe, somewhat safe, somewhat unsafe, or very unsafe under normal operations and off-normal 

operations both with and without current regulations. "Safety" was not predefmed for the 

respondents (i.e., their opinions about the safety of systems were expected to reflect their 

personal definitions of safety). A subsequent question asked respondents for their own 

definitions of very safe, somewhat safe, somewhat unsafe, and very unsafe. Tables based on 

modal responses and median responses are both provided. Both tables frequently are the same, but for some systems the tables differ and the ability to compare the two appears to offer 

additional value. 

Item 3, under each system, summarizes the respondent's opinions about the most typical non

reportable events occurring under that system. Respondents were asked to indicate the event that 

they felt was most likely. Thus, the set of events for each system reflects the opinions of the 

respondents as a group rather than the opinions of individual respondents. The lists of events 

may be reflective of the respondents' opinions about what "off-normal" operations mean for each 

system and, thus, the safety of the various systems under off-normal conditions. The 

respondents' views about typical events may also have influenced estimates of the percentage of 

persons falling into various dose ranges. Respondents were also asked to provide an opinion about the frequency of the events that they indicated. That information is also summarized in 

Item 3.

1-1
RESPONSES TO QUESTIONS ABOUT ANNUAL WORKER DOSES, SAFETY UNDER VARIOUS 

CONDITIONS, AND EVENTS THAT OCCUR BY SYSTEM 

1.1 SYSTEM 1: RESEARCH AND DEVELOPMENT SYNTHESIS 

LABORATORIES 

1. Estimated percentage of workers receiving doses at various levels (N=29): 

* 75% < 50 mrem/yr 

* 98% < 500 mrem/yr 

* 99% < 1000 mrem/yr 

* 1%>1000mrem/yr 

2. Responses to questions about safety under various conditions.

Table 1.1 Modal Selections on Questions Related to the Safety of Research 

and Development Synthesis Laboratories Under Various Conditions 

(Ns =30 to 34)

With Current Regulations Without Current Regulations

Normal (barriers intact) Very safe,50% Somewhat safe, 45% 

Off-normal (barrier failure) Somewhat safe, 50% JSomewhat unsafe, 41% 

Table 1.2 Median Selections on Questions Related to the Safety of Research 

and Development Synthesis Laboratories Under Various Conditions 

(Ns = 30 to 34) 

With Current Regulations Without Current Regulations 

Normal (barriers intact) Very safe/somewhat safe Somewhat safe 

Off-normal (barrier failure) Somewhat safeI I I Somewhat unsafe

3. Responses to question about most frequent non-reportable event (N = 27): 

• contamination, frequency varied from 1 time per week to less often than 1 time per year 

(9 of 27) 

* spills, frequency varied from 1 time per month to 1 time per year (14 of 27) 

* spills and contamination, frequency varied from 1 timeper week to 1 time per month 

(3 of 27) 

1-2

1 1
RESPONSES TO QUESTIONS ABOUT ANNUAL WORKER DOSES, SAFETY UNDER VARIOUS 

CONDITIONS, AND EVENTS THAT OCCUR BY SYSTEM 

loss of hood containment, 1 time per month (1 of 27) 

1.2 SYSTEM 2: RESEARCH AND DEVELOPMENT LABORATORIES 

USING CARBON, HYDROGEN, IODINE, PHOSPHOROUS, AND 

SULFUR 

1. Estimated percentage of workers receiving doses at various levels (N = 36): 

* 87% < 50 mrem/yr 

* 100% < 500 mrem/yr 

2. Responses to questions about safety under various conditions. 

Table 1.3 Modal Selections on Questions Related to the Safety of Research 

and Development Laboratories Using Carbon, Hydrogen, Iodine, 

Phosphorous, and Sulfur Under Various Conditions (Ns = 37 to 39)

With Current Regulations I Without Current Regulations

Noma (ariesintact). Vry ae, 51 % Somewhat safe, 53% 

Off-normal (barrier failure) Somewhat safe, 59% Somewhat safe, 42% 

Table 1.4 Median Selections on Questions Related to the Safety of Research 

and Development Laboratories Using Carbon, Hydrogen, Iodine, 

Phosphorous, and Sulfur Under Various Conditions (Ns = 37 to 39) 

With Current Regulations J Without Current Regulations 

Normal (barriers intact) Very safe Somewhat safe 

Off-normal (barrierfailure) Somewhat safe Somewhat unsafe

3. Responses to question about most frequent non-reportable event (N = 36): 

* contamination, frequency varied from I time per week to 1 time per year (15 of 36) 

• spills, frequency varied from 1 time per week to less often than 1 time per year 

(17 of 36) 

spills and contamination, frequency varied from 1 time per week to 1 time per month 

(4 of 36)

1-3
RESPONSES TO QUESTIONS ABOUT ANNUAL WORKER DOSES, SAFETY UNDER VARIOUS 

CONDITIONS, AND EVENTS THAT OCCUR BY SYSTEM 

1.3 SYSTEM 3: IN VITRO TESTING 

1. Estimated percentage of workers receiving doses at various levels (N = 36): 

* 96% < 50 mrem/yr 

* 100% < 100 mrem/yr 

2. Responses to questions about safety under various conditions.

Table 1.5 Modal Selections on Questions Related to the Safety of In Vitro 

Testing Under Various Conditions (Ns = 37 to 39)

With Current Regulations Without Current Regulations

Normal (barriers inytact) Ver safe, 87% Very safe, 50% 

Offnormal (barrier failure)lVery safe, 51% J Somewhat safe, 42% 

Table 1.6 Median Selections on Questions Related to the Safety of In Vitro 

Testing Under Various Conditions (Ns = 37 to 39) 

1 With Current Regulations I Without Current Regulations 

Normal (barriers intact) Very safe Very safe/somewhat safe 

Off-normal (barrier failure) Very safe Somewhat safe

3. Responses to question about most frequent non-reportable event (N = 33): 

* contamination, frequency varied from 1 time per month to less often than 1 time per year 

(15 of 33) 

- spills, frequency varied from 1 time per month to less often than 1 time per year 

(12 of 33) 

* spills and contamination, frequency of 1 time per month (1 of 33) 

- loss of material, frequency varied from 1 time per year to less often than 1 time per year 

(5 of 33) 

1-4

I I
RESPONSES TO QUESTIONS ABOUT ANNUAL WORKER DOSES, SAFETY UNDER VARIOUS 

CONDITIONS, AND EVENTS THAT OCCUR BY SYSTEM 

1.4 SYSTEM 4: 10 CFR 35.100 - NUCLEAR MEDICINE AND 

HUMAN USE RESEARCH 

1. Estimated percentage of workers receiving doses at various levels (N = 31): 

* 39% < 50 mrem/yr 

* 99% < 500 mrem/yr 

* 100%<1000mrem/yr 

2. Responses to questions about safety under various conditions.

Table 1.7 Modal Selections on Questions Related to the Safety of 

10 CFR 35.100 - Nuclear Medicine and Human Use Research Under 

Various Conditions (Ns = 35 to 38)

With Current Regulations Without Current Regulations

Normal (barriers intact) Very safe, 58 Somewhat safe, 37% 

Off-normal (barrier failure) Somewhat safe, 41% Somewhat unsafe, 34% 

Table 1.8 Median Selections on Questions Related to the Safety of 

10 CFR 35.100 - Nuclear Medicine and Human Use Research Under 

Various Conditions (Ns = 35 to 38) 

With Current Regulations [ Without Current Regulations 

Normal (barriers intact) sSomewhat safe 

Off-normal (barrier failure) Somewhat safe Somewhat safe

3. Responses to question about most frequent non-reportable event (N = 27): 

"• contamination, frequency varied from 1 time per week to 1 time per year (11 of 27) 

"* spills, frequency varied from 1 time per week to less often than 1 time per year 

(15 of 27) 

"• spills and contamination, frequency of 1 time per year (1 of 27)

1-5

S......... . . ... . I
RESPONSES TO QUESTIONS ABOUT ANNUAL WORKER DOSES, SAFETY UNDER VARIOUS 

CONDITIONS, AND EVENTS THAT OCCUR BY SYSTEM 

1.5 SYSTEM 5: 10 CFR 35.200 - NUCLEAR MEDICINE WITH 

GENERATOR(S) 

1. Estimated percentage of workers receiving doses at various levels (N = 33): 

* 13% < 50mrem/yr 

- 82% < 500 mrem/yr 

* 97% < 1000 mrem/yr 

* 3% > 1000 mrem/yr 

2. Responses to questions about safety under various conditions.

Modal Selections on Questions Related to the Safety of 

10 CFR 35.200 - Nuclear Medicine with Generator(s) Under Various 

Conditions (Ns = 36 to 38)

With Current Regulations Without Current Regulations

Normal (barriers intact) Somewhat safe, 61% Somewhat safe, 36% 

Off-normal (barrier failure) Somewhat unsafe, 50% Somewhat unsafe, 39% 

Table 1.10 Median Selections on Questions Related to the Safety of 

10 CFR 35.200 - Nuclear Medicine with Generator(s) Under Various 

Conditions (Ns = 36 to 38) 

With Current Regulations I Without Current Regulations 

Normal (barriers intact) Somewhat safe J Somewhat unsafe 

Off-normal (barrier failure) Somewhat unsafe Somewhat unsafe

3. Responses to question about most frequent non-reportable event (N = 33) 

"* contamination, frequency varied from 1 time per week to 1 time per year (14 of 33) 

"* spills, frequency varied from 1 time per week to less often than 1 time per year 

(16 of 33) 

1-6

I I

Table 1.9
RESPONSES TO QUESTIONS ABOUT ANNUAL WORKER DOSES, SAFETY UNDER VARIOUS 

CONDITIONS, AND EVENTS THAT OCCUR BY SYSTEM 

" spills and contamination, frequency varied from 1 time per week to 1 time per quarter 

(2 of 33) 

" misadministration, frequency of 1 time per month (1 of 33) 

1.6 SYSTEM 6:. 10 CFR 35.200 - NUCLEAR MEDICINE WITHOUT A 

GENERATOR 

1. Estimated percentage of workers receiving doses at various levels (N = 36): 

- 28% < 50 mrem/yr 

* 95% < 500 mrem/yr 

- 100% < 1000 mrem/yr 

2. Responses to questions about safety under various conditions.

Table 1.11 Modal Selections on Questions Related to the Safety of 

10 CFR 35.200 - Nuclear Medicine Without a Generator Under 

Various Conditions (Ns = 35 to 38)

With Current Regulations I Without Current Regulations

Normal (barriers intact) Veysf,5%Somewhat safe, 49% 

Off-normal (barrier failure) Somewhat safe, 40% Somewhat unsafe, 39% 

Table 1.12 Median Selections on Questions Related to the Safety of 

10 CFR 35.200 - Nuclear Medicine Without a Generator Under 

Various Conditions (Ns = 35 to 38) 

With Current Regulations I Without Current Regulations 

Normal (barriers intact) Very safe Somewhat safe 

Off-normal (barrier failure) Somewhat safe Somewhat unsafe

1-7
RESPONSES TO QUESTIONS ABOUT ANNUAL WORKER DOSES, SAFETY UNDER VARIOUS 

CONDITIONS, AND EVENTS THAT OCCUR BY SYSTEM 

3. Responses to question about most frequent non-reportable event (N = 33) 

"* contamination, frequency varied from 1 time per week to 1 time per year (17 of 33) 

"* spills, frequency varied from 1 time per week to less often than 1 time per year 

(14 of 33) 

"* spills and contamination, frequency of 1 time per quarter (1 of 33) 

"* misadministration, frequency of 1 time per month (1 of 33) 

1.7 SYSTEM 7: 10 CFR 35.300 - NUCLEAR MEDICINE 

1. Estimated percentage of workers receiving doses at various levels (N = 29): 

* 22% <.50 mrem/yr 

* 92% < 500 mrem/yr 

* 98% < 1000 mrem/yr 

* 2% > 1000 mrem/yr 

2. Responses to questions about safety under various conditions. 

Table 1.13 Modal Selections on Questions Related to the Safety of 

10 CFR 35.300 - Nuclear Medicine Under Various Conditions 

(Ns = 35 to 38)

With Current Regulations I Without Current Regulations

Normal (barriers intact) Somewhat safe, 45% Somewhat unsafe, 40% 

Off-normal (barrier failure) Somewhat unsafe, 46% I Somewhat unsafe, 47% 

Table 1.14 Median Selections on Questions Related to the Safety of 

10 CFR 35.300 - Nuclear Medicine Under Various Conditions 

(Ns = 35 to 38) 

With Current Regulations I Without Current Regulations 

Normal (barriers intact) Somewhat safe Somewhat unsafe 

Off-normal (barrier failure) -Somewhat unsafe Somewhat unsafe

1-8

1 1
RESPONSES TO QUESTIONS ABOUT ANNUAL WORKER DOSES, SAFETY UNDER VARIOUS 

CONDITIONS, AND EVENTS THAT OCCUR BY SYSTEM 

3. Responses to question about most frequent non-reportable event (N = 29) 

" contamination, frequency varied from 1 time per week to less often than 1 time per year 

(17 of 29) 

"* spills, frequency varied from I time per week to time per year (9 of 29) 

"* misadministration, frequency varied from 1 time per year to less often than 1 time per 

year (2 of 29) 

" loss of material, of I time per quarter (1 of 29) 

1.8 SYSTEM 8: BRACHYTHERAPY - USING SEEDS 

I. Estimated percentage of workers receiving doses at various levels (N = 28): 

* 30% < 50 mrem/yr 

* 93% < 500 mrem/yr 

- 99% < 1000 mrem/yr 

* 1% > 1000mrem/yr 

2. Responses to questions about safety under various conditions.

Table 1.15 Modal Selections on Questions Related to the Safety of 

Brachytherapy - Using Seeds Under Various Conditions 

(Ns = 36 to 37)

With Current Regulations [ Without Current Regulations 

Normal (barriers intact) Somewhat safe, 51% Somewhat unsafe, 42% 

Off-normal (barrier failure) Somewhat unsafe, 54% Very unsafe, 47%

1-9
RESPONSES TO QUESTIONS ABOUT ANNUAL WORKER DOSES, SAFETY UNDER VARIOUS 

CONDITIONS, AND EVENTS THAT OCCUR BY SYSTEM 

Table 1.16 Median Selections on Questions Related to the Safety of 

Brachytherapy - Using Seeds Under Various Conditions 

(Ns = 36 to 37) 

With Current Regulations [ Without Current Regulations 

Normal (barriers intact) Somewhat safu-e }Somewhat unsafe 

Off-normal (barrier failure) Somewhat unsafe Very unsafe 

3. Responses to question about most frequent non-reportable event (N = 26) 

* loss of material, frequency varied from 1 time per year to less often than 1 time per year 

(24 of 26) 

* misadministration, frequency of less often than 1 time per year (1 of 26) 

* drop and survey, frequency of 1 time per year (1 of 26) 

1.9 SYSTEM 9: BRACHYTHERAPY - MANUAL AFTERLOADING 

1. Estimated percentage of workers receiving doses at various levels (N = 22): 

* 35% < 50 mrem/yr 

* 87% < 500 mrem/yr 

* 94% < 1000 mrem/yr 

* 6% > 1000 mrem/yr 

2. Responses to questions about safety under various conditions.

Table 1.17 Modal Selections on Questions Related to the Safety of 

Brachytherapy - Manual Afterloading Under Various Conditions 

(Ns = 33 to 34)

With Current Regulations I Without Current Regulations 

Normal (barriers intact) Somewhat safe, 44% Very unsafe, 41% 

Off-normal (barrier failure) Somewhat unsafe, 47% Very unsafe, 64%

1-10

1 1
RESPONSES TO QUESTIONS ABOUT ANNUAL WORKER DOSES, SAFETY UNDER VARIOUS 

CONDITIONS, AND EVENTS THAT OCCUR BY SYSTEM 

Table 1.18 Median Selections on Questions Related to the Safety of 

Brachytherapy - Manual Afterloading Under Various Conditions 

(Ns = 33 to 34) 

With Current Regulations JWithout Current Regulations 

Normal (barriers intact) Somewhat safe Very unsafe 

Off-normal (barrier failure) lsomewhat unsafe Very unsafe 

3. Responses to question about most frequent non-reportable event (N = 17) 

"* inadequate shielding, frequency of less often than 1 time per year (1 of 17) 

"* loss of material, frequency varied from 1 time per year to less often than 1 time per year 

(7 of 17) 

" misadministration, frequency varied from 1 time per year to less often than 1 time per 

year (7 of 17) 

" recordable incident, frequency varied from 1 time per year to less often than 1 time per 

year (2 of 17) 

1.10 SYSTEM 10: BRACHYTHERAPY LOW DOSE RATE REMOTE 

AFTERLOADING 

1. Estimated percentage of workers receiving doses at various levels (N = 19): 

* 65% < 50 mrem/yr 

• 9 5% < 100 mrem/yr 

* 100% < 1000 mrem/yr 

2. Responses to questions about safety under various conditions.

1-11
RESPONSES TO QUESTIONS ABOUT ANNUAL WORKER DOSES, SAFETY UNDER VARIOUS 

CONDITIONS, AND EVENTS THAT OCCUR BY SYSTEM

Modal Selections on Questions Related to the Safety of 

Brachytherapy - Low Dose Rate Remote Afterloading Under 

Various Conditions (Ns = 32 to 34)

With Current Regulations Without Current Regulations

Normal (barriers intact Somewhat safe, 53% Somewhat unsafe, 44% 

Off'normal(barrier failure) Somewhat unsafe, 41% Very unsafe, 50% 

Table 1.20 Median Selections on Questions Related to the Safety of 

Brachytherapy - Low Dose Rate Remote Afterloading Under 

Various Conditions (Ns = 32 to 34) 

With Current Regulations I Without Current Regulations 

Normal (barriers intact) Somewhat safe- Somewhat unsafe 

Off-normal (barrier failure) Somewhat unsafe Somewhat unsafe/very unsafe

3. Responses to question about most frequent non-reportable event (N = 12) 

"• interruption of treatment, frequency varied from 1 time per quarter to 1 time per year 

(2 of 12) 

"* loss of material, frequency of lees than 1 time per year (lof 12) 

"* misadministration, frequency varied from 1 time per year to less often than 1 time per 

year (4 of 12) 

"* device malfunction/failure, frequency of less often than 1 time per year (2 of 12) 

"* recordable incident, frequency varied from 1 time per quarter to less often than 1 time 

per year (2 of 12) 

"* stuck source, frequency of less often than 1 time per year (1 of 12) 

1-12

I I

Table 1.19
RESPONSES TO QUESTIONS ABOUT ANNUAL WORKER DOSES, SAFETY UNDER VARIOUS 

CONDITIONS, AND EVENTS THAT OCCUR BY SYSTEM 

1.11 SYSTEM 11: BRACHYTHERAPY - HIGH DOSE RATE REMOTE 

AFTERLOADING 

1. Estimated percentage of workers receiving doses at various levels (N = 27): 

* 68% < 50 mrem/yr 

* 96% < 500 mrem/yr 

* 100% < 1000 mrem/yr 

2. Responses to questions about safety under various conditions. 

Table 1.21 Modal Selections on Questions Related to the Safety of 

Brachytherapy - High Dose Rate Remote Afterloading Under 

Various Conditions (Ns = 36 to 38)

With Current Reeulations I Without Current Re-muinlnnQ

Noml(bariersin~tact) Somewhat safe, 59% JVery unsafe, 39% 

Off-normal (barrier failure) Very unsafe, 45% Very unsafe, 64% 

Table 1.22 Median Selections on Questions Related to the Safety of 

Brachytherapy - High Dose Rate Remote Afterloading Under 

Various Conditions (Ns = 36 to 38) 

With Current Regulations I Without Current Regulations 

Normal (barriers intact) Somewhat safe Somewhat unsafe 

Off-normal (barrier failure) Somewhat unsafe [ Very unsafe

3. Responses to question about most frequent non-reportable event (N = 16) 

"• interruption of treatment, frequency of 1 time per quarter (lof 16) 

"• loss of material, frequency of less often than 1 time per year (lof 16) 

"• misadministration, frequency of 1 time per month (5 of 16) 

"* device malfunction/failure, frequency varied from 1 time per year to less often than 

1 time per year (4 of 16)

1-13
RESPONSES TO QUESTIONS ABOUT ANNUAL WORKER DOSES, SAFETY UNDER VARIOUS 

CONDITIONS, AND EVENTS THAT OCCUR BY SYSTEM 

"* recordable incident, frequency varied from I time per quarter to 1 time per year (2 of 16) 

"* stuck source, frequency of less often than I time per year (3 of 16) 

1.12 SYSTEM 12: BRACHYTHERAPY - EYE APPLICATOR 

I. Estimated percentage of workers receiving doses at various levels (N = 23): 

* 82% < 50 mrem/yr 

* 100% < 500 mrem/yr 

2. Responses to questions about safety under various conditions. 

Table 1.23 - Modal Selections on Questions Related to the Safety of 

Brachytherapy - Eye Applicator Under Various Conditions 

(Ns = 31 to 32)

With Current Regulations Without Current Regulations

Normal (barriers intact) Very safe, 49% Somewhat safe/very unsafe, 

___ ___ ___ ___ ___ ___ _ _ ___ ___ ___ ___ ___ __ 29% each 

Off-normal (barrier failure) Somewhat unsafe, 42% [Somewhat unsafe, 41% 

Table 1.24 Median Selections on Questions Related to the Safety of 

Brachytherapy - Eye Applicator Under Various Conditions 

(Ns = 31 to 32) 

With Current Regulations 1 Without Current Regulations 

Normal (barriers intact) Somewhat safe Somewhat unsafe 

Off-normal (barrier failure) Somewhat unsafe Somewhat unsafe

3. Responses to question about most frequent non-reportable event (N = 11) 

"* exposure, frequency of less often than 1 time per year (1 of 11) 

"* loss of material, frequency varied from 1 time per year to less often than I time per year 

(6 of 11) 

"* misadministration, frequency varied from 1 time per quarter to less often than I time per 

year (4 of 11) 

1-14

I I
RESPONSES TO QUESTIONS ABOUT ANNUAL WORKER DOSES, SAFETY UNDER VARIOUS 

CONDITIONS, AND EVENTS THAT OCCUR BY SYSTEM 

1.13 SYSTEM 13: 10 CFR 35.400 - DIAGNOSTIC DEVICES1 

1. Estimated percentage of workers receiving doses at various levels (N = 19): 

* 8 4% < 50 mrem/yr 

* 9 9% < 500 mrem/yr 

* 100% < 1000 mrem/yr 

2. Responses to questions about safety under various conditions.

Table 1.25 Modal Selections on Questions Related to the Safety of 

10 CFR 35.400 - Diagnostic Devices Under Various Conditions 

(Ns = 22 to 25)

With Current Regulations I Without Current Retulatinnq

Normal1(barriersiitat n[ertafe~, 68% Somewhat safe, 46% 

Off-normal (barrier failure) Somewhat safe, 58% Somewhat safe, 48% 

Table 1.26 Median Selections on Questions Related to the Safety of 

10 CFR 35.400 - Diagnostic Devices Under Various Conditions 

(Ns = 22 to 25) 

With Current Regulations. Without Current Regulations 

Normal (barriers intact) Very safe Somewhat safe 

Off-normal (barrier failure) Somewhat safe Somewhat safe/somewhat 

____ ____ ___ ___ ___ _ _ ___ ____ ___ ___ ___ ___ unsafe

3. Responses to question about most frequent non-reportable event (N = 4) 

* Loss of material, frequency of less often than 1 time per year (2 of 4) 

* Not secured, frequency of less often than 1 time per year (1 of 4) 

* spill, frequency of 1 time quarter (1 of 4) 

This system is the result of an error in the survey form. The form read "10 CFR 400 - Diagnostic Devices" instead of"10 CFR 500 - Diagnostic Devices" as it should have. Some respondents noted the error in the 

survey form. Their responses are recorded under system 13a. The responses of those who did not note the error 

were recorded under this system (13).

1-15
RESPONSES TO QUESTIONS ABOUT ANNUAL WORKER DOSES, SAFETY UNDER VARIOUS 

CONDITIONS, AND EVENTS THAT OCCUR BY SYSTEM 

1.14 SYSTEM 13A: 10 CFR 35.500 - DIAGNOSTIC DEVICES 

1. Estimated percentage of workers receiving doses at various levels (N = 7): 

• 84% < 50 mrem/yr 

* 100% < 100 mrem/yr 

2. Responses to questions about safety under various conditions. 

Table 1.27 Modal Selections on Questions Related to the Safety of 

10 CFR 35.500 - Diagnostic Devices Under Various Conditions 

(Ns = 7 to 8) 

With Current Regulations I Without Current Regulations

Normal (barriers intact) Very safe,88% Somewhat safe, 38% 

Off-normal (arrer failure) Somewhat safe, 50% IVery safe, 43% 

Table 1.28 Median Selections on Questions Related to the Safety of 

10 CFR 35.500 - Diagnostic Devices Under Various Conditions 

(Ns = 7 to 8) 

With Current Regulations I Without Current Regulations 

Normal (barriers intact) Very safe Somewhat safe 

Off-normal (barrier failure) Somewhat safe Somewhat safe

3. Responses to question about most frequent non-reportable event (N = 2) 

"* exposure, frequency of less often than 1 time per year (1 of 2) 

"* loss of material, frequency of less often than I time per year (1 of 2) 

1-16

1 1
RESPONSES TO QUESTIONS ABOUT ANNUAL WORKER DOSES, SAFETY UNDER VARIOUS 

CONDITIONS, AND EVENTS THAT OCCUR BY SYSTEM 

1.15 SYSTEM 14: TELETHERAPY DEVICES 

1. Estimated percentage of workers receiving doses at various levels (N = 29): 

- 81% < 50 mrem/yr 

* 96% < 500 mrem/yr 

* 99% < 1000 mrem/yr 

* I% > 1000 mrem/yr 

2. Responses to questions about safety under various conditions. 

Table 1.29 Modal Selections on Questions Related to the Safety of Teletherapy 

Devices Under Various Conditions (Ns = 35 to 36) 

With Current Regulations PWithout Current Regulations 

Normal (barriers intact) Somewhat safe, 44% Somewhat unsafe, 37% 

Off-normal (barrier. failure) Very unsafe, 50% Very unsafe, 63% 

Table 1.30 Median Selections on Questions Related to the Safety of Teletherapy 

Devices Under Various Conditions (Ns = 35 to 36) 

With Current Regulations I Without Current Regulations 

Normal (barriers intact) Somewhat safe Somewhat unsafe 

Off-normal (barrier failure) Somewhat unsafe/very Very unsafe 

unsafe 

3. Responses to question about most frequent non-reportable event (N = 17) 

"* loss of material, frequency of less often than 1 time per year (1 of 17) 

"* misadministration, frequency varied from 1 time per year to less often than 1 time per 

year (5 of 17) 

"* device malfunction/failure, frequency of 1 time per month (1 of 17) 

"* loss of material, frequency of less often than 1 time per year (2 of 17)

.1-17
RESPONSES TO QUESTIONS ABOUT ANNUAL WORKER DOSES, SAFETY UNDER VARIOUS 

CONDITIONS, AND EVENTS THAT OCCUR BY SYSTEM 

"• recordable incident, frequency varied from 1 time per quarter to 1 time per year (2 of 17) 

"* stuck source, frequency varied from 1 time per quarter to less often than 1 time per year 

(7 of 17) 

1.16 SYSTEM 15: GAMMA STEREOTACTIC SURGERY 

1. Estimated percentage of workers receiving doses at various levels (N = 29): 

- 68% < 50 mrem/yr 

* 93% < 500 mrem/yr 

* 99% < 1000 mrem/yr 

* 1% > 1000 mrem/yr 

2. Responses to questions about safety under various conditions.

Table 1.31 Modal Selections on Questions Related to the Safety of Gamma 

Stereotactic Surgery Under Various Conditions (Ns = 24 to 25)

With Current Regulations Without Current Regulations

Normal (barriers intact) Very safe/somewhat safe, S somewhat unsafe, 36% 

40% each I 

Off-normal (barrier failure) Very unsafe, 50% Very unsafe, 64% 

Table 1.32 Median Selections on Questions Related to the Safety of Gamma 

Stereotactic Surgery Under Various Conditions (Ns =-24 to 25) 

With Current Regulations J Without Current Regulations 

Normal (barriers intact) Somewhat safe Somewhat unsafe 

Off-normal (barrier failure) Somewhat unsafe/very Very unsafe 

unsafe

1-18

1 1
RESPONSES TO QUESTIONS ABOUT ANNUAL WORKER DOSES, SAFETY UNDER VARIOUS 

CONDITIONS, AND EVENTS THAT OCCUR BY SYSTEM 

3. Responses to question about most frequent non-reportable event (N = 7) 

• misadministration, frequency of less often than 1 time per year (4 of 7) 

* device malfunction/failure, frequency of less often than 1 time per year (3 of 4) 

1.17 SYSTEM 16: NUCLEAR PHARMACIES 

1. Estimated percentage of workers receiving doses at various levels (N = 34): 

* 15% < 50 mrem/yr 

* 7 5% < 500 mrem/yr 

* 95% < 1000 mrem/yr 

* 5%>1000mrem/yr 

2. Responses to questions about safety under various conditions. 

Table 1.33 Modal Selections on Questions Related to the Safety of Nuclear 

Pharmacies Under Various Conditions (Ns = 34 to 37) 

With Current Regulations [Without Current Regulations

Normal (barriers intact).- Somewhat safe, 61 % Somewhat unsafe, 49% 

Off-normal (barrier failure) I Somewhat unsafe, 44% (Very unsafe, 50% 

Table 1.34 Median Selections on Questions Related to the Safety of Nuclear 

Pharmacies Under Various Conditions (Ns = 34 to 37) 

With. Current Regulations (Without Current Regulations 

Normal (barriers intact) Somewhat safe Somewhat unsafe 

Off-normal (barrier failure) Somewhat unsafe Somewhat unsafe/very unsafe

3. Responses to question about most frequent non-reportable event (N = 33) 

* contamination, frequency varied from 1 time per week to less often than 1 time per year 

(18 of 33) 

- loss of material, frequency varied of 1 time per year (I of 33)

1-19
RESPONSES TO QUESTIONS ABOUT ANNUAL WORKER DOSES, SAFETY UNDER VARIOUS 

CONDITIONS, AND EVENTS THAT OCCUR BY SYSTEM 

- spill, frequency varied from I time per week to 1 time per year (9 of 33) 

- spill and contamination, frequency varied from 1 time per week to 1 time per quarter 

(3 of 33) 

* wrong label, frequency varied from 1 time per quarter to less often than 1 time per year 

(2 of 33) 

1.18 SYSTEM 17: VETERINARY USE 

1. Estimated percentage of workers receiving doses at various levels (N = 22): 

* 49% < 50 mrem/yr 

* 96% < 500 mrem/yr 

* 97% < 1000 mrem/yr 

* 3% > 1000 mrem/yr 

2. Responses to questions about safety under various conditions. 

Table 1.35 Modal Selections on Questions Related to the Safety of Veterinary 

Use Under Various Conditions (Ns = 28 to 33) 

With Current Regulations I Without Current Regulations 

Normal (barriers intact) Somewhat safe, 52% Somewhat safe, 46% 

Off-normal (barrier failure) Somewhat safe, 64% Somewhat unsafe, 48% 

Table 1.36 Median Selections on Questions Related to the Safety of Veterinary 

Use Under Various Conditions (Ns = 28 to 33) 

With Current Regulations I Without Current Regulations 

Normal (barriers intact) Somewhat safe Somewhat safe 

Off-normal (barrier failure) Somewhat safe Somewhat unsafe 

3. Responses to question about most frequent non-reportable event (N = 20) 

* contamination, frequency varied from 1 time per week to less often than 1 time per year 

(14 of 20) 

1-20

I I
RESPONSES TO QUESTIONS ABOUT ANNUAL WORKER DOSES, SAFETY UNDER VARIOUS 

CONDITIONS, AND EVENTS THAT OCCUR BY SYSTEM 

"* contaminated animal waste, frequency of 1 time per week (1 of 20) 

"* Early release of animal, frequency of less often than 1 time per year (1 of 20) 

0 Spill, frequency varied from 1 time per quarter to less often than 1 time per year 

(4 of 20) 

1.19 SYSTEM 18: RESEARCH AND DEVELOPMENT ON ANIMALS 

1. Estimated percentage of workers receiving doses at various levels (N = 22): 

- 7 1% < 50 mrem/yr 

* 100% < 500 mrem/yr 

2. Responses to questions about safety under various conditions. 

Table 1.37 Modal Selections on Questions Related to the Safety of Research 

and Development on Animals Under Various Conditions 

(Ns = 29 to 34)

With Current Reiaulations

* Normal (barriers intact) Very safe/somewhat safe, Somewhat safe, 39% 

47% each 

Off-normal (barrier failure) Somewhat safe, 62% Somewhat safe, 50% 

Table 1.38 Median Selections on Questions Related to the Safety of Research 

and Development on Animals Under Various Conditions 

(Ns = 29 to 34) 

With Current Regulations I Without Current Regulations 

Normal (barriers intact) Somewhat safe Somewhat safe 

Off-normal (barrier failure) Somewhat safe Somewhat safe/somewhat 

unsafe

3. Responses to question about most frequent non-reportable event (N = 25) 

contamination, frequency varied from 1 time per week to less often than 1 time per year 

(20 of 25)

1-21
RESPONSES TO QUESTIONS ABOUT ANNUAL WORKER DOSES, SAFETY UNDER VARIOUS 

CONDITIONS, AND EVENTS THAT OCCUR BY SYSTEM 

"* contaminated animal waste, frequency varied from 1 time per month to 1 time per 

quarter (2 of 25) 

"* spill, frequency varied from 1 time per month to 1 time per quarter (3 of 25) 

1.20 SYSTEM 19: WELL-LOGGING - TRACERS AND FIELD FLOOD 

STUDIES 

1 Estimated percentage of workers receiving doses at various levels (N = 15): 

- 36% < 50 mrem/yr 

- 96% < 500 mrem/yr 

* 99% < 1000 mrem/yr 

* 1%>1000mrem/yr 

2. Responses to questions about safety under various conditions. 

Table 1.39 Modal Selections on Questions Related to the Safety of Well Logging 

- Tracers and Field Flood Studies Under Various Conditions 

(Ns =,27 to 28)

With Current Regulations Without Current Regulations

Normal (barriers intact) Somewhat safe, 50% Somewhat safe/somewhat 

unsafe, 33% each 

Off-normal (barrier failure) Somewhat safe/somewhat Somewhat unsafe, 39% 

Iunsafe, 35% each 

Table 1.40 Median Selections on Questions Related to the Safety of Well 

Logging - Tracers and Field Flood Studies Under Various 

Conditions (Ns = 27 to 28) 

With Current Regulations I Without Current Regulations 

Normal (barriers intact) Somewhat safe Somewhat unsafe 

Off-normal (barrier failure) Somewhat unsafe Somewhat unsafe

1-22

I I
RESPONSES TO QUESTIONS ABOUT ANNUAL WORKER DOSES, SAFETY UNDER VARIOUS 

CONDITIONS, AND EVENTS THAT OCCUR BY SYSTEM 

3. Responses to question about most frequent non-reportable event (N = 15) 

" contamination, frequency varied from 1 time per week to less often than I time per year 

(10 of 15) 

" spills, frequency varied from 1 time per quarter to less often than I time per year 

(4of 15) 

" spills and contamination, frequency of 1 time per year (1 of 15) 

1.21 SYSTEM 20: WELL LOGGING - USING SEALED SOURCES 

1. Estimated percentage of workers receiving doses at various levels (N = 18): 

* 48% < 50 mrem/yr 

- 9 3% < 500 mrem/yr 

• 99% < 1000 mrem/yr 

0 1% > 1000 mrem/yr 

2. Responses to questions about safety under various conditions. 

Table 1.41 Modal Selections on Questions Related to the Safety of Well 

Logging - Using Sealed Sources Under Various Conditions 

(Ns = 28 to 30)

With Current Regulations I Without Current Regulations

Normal (barriers intact) Somewhat safe, 61% Somewhat unsafe, 45% 

Off-normal (barrier failure) Somewhat safe, 40% Very unsafe, 41% 

Table 1.42 Median Selections on Questions Related to the Safety of Well 

Logging - Using Sealed Sources Under Various Conditions 

(Ns = 28 to 30) 

With Current Regulations7 Without Current Regulations 

Normal (barriers intact) Somewhat safe Somewhat unsafe 

Off-normal (barrier failure) Somewhat unsafe Somewhat unsafe

1-23
RESPONSES TO QUESTIONS ABOUT ANNUAL WORKER DOSES, SAFETY UNDER VARIOUS 

CONDITIONS, AND EVENTS THAT OCCUR BY SYSTEM 

3. Responses to question about most frequent non-reportable event (N = 16) 

"* source disconnect, frequency of less often than 1 time per year (1 of 16) 

* exposure, frequency of less often than 1 time per year (1 of 16) 

"• loss/damage of source, frequency of less often than 1 time per year (1 of 16) 

"* loss of material, frequency varied from 1 time per year to less often than 1 time per year 

(10 of 16) 

"* failure to survey, frequency of 1 time per month (1 of 16) 

"* stuck source, frequency of 1 time per year (2 Of 16) 

1.22 SYSTEM 21: RADIOGRAPHY - PERMANENT INSTALLATION 

1. Estimated percentage of workers receiving doses at various levels (N = 3 1): 

- 32% < 50 mrem/yr 

* 86% < 500 mrem/yr 

* 92% < 1000 mrem/yr 

* 8% > 1000 mrem/yr 

2. Responses to questions about safety under various conditions. 

Table 1.43 Modal Selections on Questions Related to the Safety of 

Radiography - Permanent Installation Under Various Conditions 

(Ns = 37 to 38) 

With Current Regulations I Without Current Regulations 

Normal (barriers intact) Somewhat safe, 50% Somewhat unsafe, 57% 

Off-normal (barrier failure) -Somewhat unsafe, 44% Very unsafe, 54%

1-24

1 1
RESPONSES TO QUESTIONS ABOUT ANNUAL WORKER DOSES, SAFETY UNDER VARIOUS 

CONDITIONS, AND EVENTS THAT OCCUR BY SYSTEM 

Table 1.44 Median Selections on Questions Related to the Safety of 

Radiography - Permanent Installation Under Various Conditions 

(Ns = 37 to 38) 

With Current Regulations Without Current Regulations 

Normal (barriers intact) Somewhat safe Somewhat unsafe 

Offo-normal (a er failure). Somewhat unsafe Very unsafe 

3. Responses to question about most frequent non-reportable event (N = 21) 

• source disconnect, frequency of less often than 1 time per year (1 of 21) 

* exposure, frequency varied from I time per week to less often than 1 time per year 

(5 of 21) 

* failed warning device, frequency of I time per year (1 of 21) 

* source not shielded, frequency of I time per year (1 of 21) 

• loss of material, frequency of less often than 1 time per year (3 of 21) 

• device malfunction/failure, frequency varied from 1 time per quarter to less often than 1 

time per year (5 of 21) 

* failure to survey, frequency of I time per month (1 of 21) 

* failure to secure, frequency of 1 time per quarter (1 of 21) 

• stuck source, frequency varied from 1 time per quarter to less often than 1 time per year 

(3 of 16) 

1.23 SYSTEM 22: RADIOGRAPHY - FIELD USE 

1. Estimated percentage of workers receiving doses at various levels (N = 36): 

* 9% < 50 mrem/yr 

* 65% < 500 mrem/yr 

* 8 7%<1000mrem/yr 

* 13%>1000mrem/yr

1-25
RESPONSES TO QUESTIONS ABOUT ANNUAL WORKER DOSES, SAFETY UNDER VARIOUS 

CONDITIONS, AND EVENTS THAT OCCUR BY SYSTEM 

2. Responses to questions about safety under various conditions. 

Table 1.45 Modal Selections on Questions Related to the Safety of 

Radiography - Field Use Under Various Conditions (Ns =38 to 39) 

.With Current Regulations I Without Current Regulations

Normal(brrersntct Somewhat safe, 44% Very unsa-fe, 58% 

Of-norma (rrir fiue)I Very unsafe, 79% 

Table 1.46 Median Selections on Questions Related to the Safety of 

Radiography - Field Use Under Various Conditions (Ns = 38 to 39) 

With Current Regulations Without Current Regulations 

Normal (barriers intact) Somewhat safe Very unsafe 

Off-normal (barrier failure) i Very unsafe

3. Responses to question about most frequent non-reportable event (N = 27) 

"• source disconnect, frequency varied from 1 time per year to less often than 1 time per 

year (6 of 26) 

"* exposure, frequency varied from 1 time per week to 1 time per year (5 of 26) 

"* personnel inattention, frequency of less often than 1 time per year (1 of 26) 

"* source not shielded, frequency of 1 time per year (1 of 26) 

"• loss of material, frequency varied from 1 time per year to less often than I time per year 

(3 of 26) 

"* device malfunction/failure, frequency of 1 time per quarter (2 of 26) 

"* failure to survey, frequency of 1 time per month (1 of 26) 

"* failure to secure, frequency of 1 time per month (1 of 26) 

"* restricted area/boundary violation, frequency of 1 time per month (3 of 26) 

"* stuck source, frequency of 1 time per year (1 of 26) 

"* untrained user, frequency of less often than 1 time per year (1 of 26) 

"* unauthorized user, frequency of 1 time per year (1 of 26) 

1-26

I I
RESPONSES TO QUESTIONS ABOUT ANNUAL WORKER DOSES, SAFETY UNDER VARIOUS 

CONDITIONS, AND EVENTS THAT OCCUR BY SYSTEM 

1.24 SYSTEM 23: POOL IRRADIATORS 

1. Estimated percentage of workers receiving doses at various levels (N = 29): 

* 77% < 50 mrem/yr 

* 98% < 500 mrem/yr 

* 100% < 1000 mrem/yr 

2. Responses to questions about safety under various conditions. 

Table 1.47 Modal Selections on Questions Related to the Safety of Pool 

Irradiators Under Various Conditions (Ns = 35 to 37) 

With Current RegulationsT Without Current Regulations.

Nomal (barlriers intact) Ve safe, 40% Very unsafe, 43% 

Off-normal (barrier failure) V[ unsafe, 49% Very unsafe, 64% 

Table 1.48 Median Selections on Questions Related to the Safety of Pool 

Irradiators Under Various Conditions (Ns = 35 to 37) 

With Current Regulations J Without Current Regulations 

Normal (barriers intact) Somewhat safe Somewhat unsafe 

Off-normal (barrier failure) Somewhat unsafe Very unsafe

3. Responses to question about most frequent non-reportable event (N = 20) 

* contamination, frequency varied from 1 time per year to less often than 1 time per year 

(2 of 20) 

* exposure, frequency of less often than I time per year (1 of 20) 

• loss of material, frequency of less often than I time per year (1 of 20) 

* device malfunction/failure, frequency varied from 1 time per week to less often than 1 

time per year (8 of 20) 

* failure to secure, frequency of 1 time per year (1 of 20) 

* restricted area/boundary violation, frequency of less often than 1 time per year (1 of 20)

1-27
RESPONSES TO QUESTIONS ABOUT ANNUAL WORKER DOSES, SAFETY UNDER VARIOUS 

CONDITIONS, AND EVENTS THAT OCCUR BY SYSTEM 

stuck source, frequency varied from 1 time per year to less often than 1 time per year 

(6 of 20) 

1.25 SYSTEM 24: SELF-SHIELDED IRRADIATORS 

1. Estimated percentage of workers receiving doses at various levels (N = 32): 

* 96% < 50 mrem/yr 

* 100% < 500 mrem/yr 

2. Responses to questions about safety under various conditions.

Modal Selections on Questions Related to the Safety of Self-shielded 

Irradiators Under Various Conditions (Ns = 34 to 38)

With Current Regulations Without Current Regulations

Normal (barriers intact) [ afe,79% Somewhat safe, 47% 

Off-normal (barrierfailure) Somewhat safe, 58°/% I Somewhat safe,38% 

Table 1.50 Median Selections on Questions Related to the Safety of 

Self-shielded Irradiators Under Various Conditions (Ns = 34 to 38) 

With Current Regulations I Without Current Regulations 

Normal (barriers intact) Very safe Somewhat safe 

Off-normal (barrier failure) Somewhat safe Somewhat safe

3. Responses to question about most frequent non-reportable event (N = 16) 

• exposure, frequency varied from 1 time per year to less often than 1 time per year 

(3 of 16) 

• device falls on your foot, frequency of less often than 1 time per year (1 of 16) 

• loss of material, frequency of less often than I time per year (1 of 16) 

"• device malfunction/failure, frequency varied from 1 time per year to less often than I 

time per year (6 of 16) 

"• failure to secure, frequency of 1 time per year (1 of 16) 

1-28

1 1

Table 1.49
RESPONSES TO QUESTIONS ABOUT ANNUAL WORKER DOSES, SAFETY UNDER VARIOUS 

CONDITIONS, AND EVENTS THAT OCCUR BY SYSTEM 

"* restricted area/boundary violation, frequency of less often than 1 time per year (1 of 20) 

"* stuck source, frequency of 1 time per quarter (1 of 20) 

"* unauthorized user/uses, frequency of 1 time per quarter (2 of 16) 

1.26 SYSTEM 25: FIXED GAUGES - GAMMA EMITTERS 

1. Estimated percentage of workers receiving doses at various levels (N = 38): 

- 96% < 50 mrem/yr 

* 100% < 500 mrern/yr 

2. Responses to questions about safety under various conditions. 

Table 1.51 Modal Selections on Questions Related to the Safety of Fixed 

Gauges - Gamma Emitters Under Various Conditions (Ns = 37 to 38)

With Current Regulations I Without Current Remulations

Noma (brir1nat) Vr ae5 Somewhat safe, 57% 

Off-normal(barrier failure) Somewhat safe, 58% Somewhat safe, 38% 

Table 1.52 Median Selections on Questions Related to the Safety of Fixed 

Gauges - Gamma Emitters Under Various Conditions (Ns = 37 to 38) 

With Current Regulations - Without Current Regulations 

Normal (barriers intact) Very safe Somewhat safe 

Off-normal (barrier failure) Somewhat safe Somewhat unsafe

3. Responses to question about most frequent non-reportable event (N = 27) 

"* damaged gauge, frequency of less often than 1 time per year (2 of 27) 

"* exposure, frequency of less often than 1 time per year (lof 27) 

"* failure to close shutter and working close by, frequency of 1 time per month (1 of 27) 

"* loss of material, frequency varied from 1 time per year to less often than 1 time per year 

(10 of 27)

1-29
RESPONSES TO QUESTIONS ABOUT ANNUAL WORKER DOSES, SAFETY UNDER VARIOUS 

CONDITIONS, AND EVENTS THAT OCCUR BY SYSTEM 

"* device malfunction/failure, frequency varied'from 1 time per year to less often than 1 

time per year (7 of 27) 

"* maintenance problem, frequency of less often than 1 time per year (1 of 27) 

"• failure to secure, frequency of 1 time per year (1 of 27) 

"* unauthorized maintenance, frequency of 1 time per year (lof 27) 

"* untrained maintenance worker, frequency of less often than 1 time per year (2 of 27) 

"* unauthorized removal, frequency of 1 time per year (1 of 27) 

1.27 SYSTEM 26: FIXED GAUGES - BETA EMITTERS 

1. Estimated percentage of workers receiving doses at various levels (N = 35): 

a 96% < 50 mrem/yr 

* 100% < 500 mrem/yr 

2. Responses to questions about safety under various conditions. 

Table 1.53 Modal Selections on Questions Related to the Safety of Fixed 

Gauges - Beta Emitters Under Various Conditions (Ns = 36 to 37) 

With Current Regulations I Without Current Regulations 

Normal (barriers intact) Very safe, 70% Somewhat safe, 58% 

Off-normal (barrier failure) Somewhat safe, 81% [Somewhat safe, 47% 

Table 1.54 Median Selections on Questions Related to the Safety of Fixed 

Gauges - Beta Emitters Under Various Conditions (Ns = 36 to 37) 

With Current Regulations I Without Current Regulations 

Normal (barriers intact) Very safe Somewhat safe 

Off-normal (barrier failure) Somewhat safe Somewhat safe 

3. Responses to question about most frequent non-reportable event (N = 22) 

"* device damaged, frequency of less often than 1 time per year (2 of 22) 

"• exposure, frequency of less often than I time per year (lof 21) 

1-30

I I
RESPONSES TO QUESTIONS ABOUT ANNUAL WORKER DOSES, SAFETY UNDER VARIOUS 

CONDITIONS, AND EVENTS THAT OCCUR BY SYSTEM 

" loss of material, frequency varied from 1 time per year to less often than 1 time per year 

(8 of 22) 

" device malfunction/failure, frequency varied from 1 time per year to less often than 1 

time per year (7 of 22) 

"• failure to secure, frequency of 1 time per year (1 of 22) 

"* unauthorized maintenance, frequency of I time per year (lof 22) 

"* untrained maintenance worker, frequency of less often than 1 time per year (I. of 22) 

"* unauthorized removal, frequency of less often than 1 time per year (1 of 22) 

1.28 SYSTEM 27:'PORTABLE GAUGES 

I Estimated percentage of workers receiving doses at various levels (N = 38): 

• 71%<50mrem/yr 

* 99% < 500 mrem/yr 

* 100% < 1000 mrem/yr 

2. Responses to questions about safety under various conditions.

Modal Selections on Questions Related to the Safety of Portable 

Gauges Under Various Conditions (Ns = 37 to 38)

With Current Regulations

Normal (barriers intact) Very safe/somewhat Somewhat safe, 43% 

safe, 50% 

Off-normal (barrier failure) Somewhat safe, 59% Somewhat unsafe, 43% 

Table 1.56 Median Selections on Questions Related to the Safety of Portable 

Gauges Under Various Conditions (Ns = 37 to 38) 

With Current Regulations j Without Current Regulations 

Normal (barriers intact) Very safe/somewhat safe Somewhat safe 

Off-normal (barrier failure) Somewhat safe Somewhat unsafe

1-31

Table 1.55

SWithout Current Regulations e
RESPONSES TO QUESTIONS ABOUT ANNUAL WORKER DOSES, SAFETY UNDER VARIOUS 

CONDITIONS, AND EVENTS THAT OCCUR BY SYSTEM 

3. Responses to question about most frequent non-reportable event (N = 28) 

"* device damaged, frequency varied from 1 time per year to less often than 1 time per year 

(12 of 28) 

"* exposure, frequency of less often than 1 time per year (2 of 28) 

"* loss of material, frequency varied from 1 time per year to less often than 1 time per year 

(9 of 28) 

"* device malfunction/failure, frequency of 1 time per quarter (lof 28) 

"• maintenance problem, frequency of 1 time per year (1 of 28) 

"* failure to secure, frequency varied from 1 time per month to I time per quarter (2 of 28) 

"* unauthorized user/uses, frequency of 1 time per year (1 of 28) 

1.29 SYSTEM 28: X-RAY FLUORESCENCE DEVICES 

1. Estimated percentage of workers receiving doses at various levels (N = 33): 

* 84% < 50 mrem/yr 

* 100% < 500 mrem/yr 

2. Responses to questions about safety under various conditions. 

Table 1.57 Modal Selections on Questions Related to the Safety of X-ray 

Fluorescence Devices Under Various Conditions (Ns = 36 to 37) 

With Current Regulations I Without Current Regulations 

Normal (barriers intact) Very safe, 81% Somewhat safe, 38% 

Off-normal (barrier failure) Somewhat safe, 51% Very safe/somewhat safe, 33% 

each

1-32

1 1
RESPONSES TO QUESTIONS ABOUT ANNUAL WORKER DOSES, SAFETY UNDER VARIOUS 

CONDITIONS, AND EVENTS THAT OCCUR BY SYSTEM 

Table 1.58 Median Selections on Questions Related to the Safety of X-ray 

Fluorescence Devices Under Various Conditions (Ns = 36 to 37) 

With Current Regulations Without Current Regulations 

Normal (barriers intact) [Very safe Somewhat safe 

Off-normal (barrier failure) I Somewhat safe Somewhat safe 

3. Responses to question about most frequent non-reportable event (N = 11) 

"* exposure, frequency of 1 time per year (2 of 11) 

"* source not shielded, frequency of less often than 1 time per year (1 of 11) 

"* loss of material, frequency varied from 1 time per year to less often than 1 time per year 

(3 of 11) 

"• leaking source, frequency of less often than 1 time per year (2 of 11) 

"• failure to secure, frequency varied from 1 time per month to 1 time per year (2 of 11) 

"* stuck source, frequency of 1 time per year (lof 11) 

1.30 SYSTEM 29: GAS CHROMATOGRAPHS 

1. Estimated percentage of workers receiving doses at various levels (N 40): 

* 100%<50mrem/yr 

2. Responses to questions about safety under various conditions. 

Table 1.59 Modal Selections on Questions Related to the Safety of Gas 

Chromatographs Under Various Conditions (Ns = 37 to 40) 

With Current Regulations [ Without Current Regulations 

Normal (barriers intact) [eysf,90% Very safe, 58% 

Off-normal (barrier failure) safe, 59% [Very safe, 54%

1-33
RESPONSES TO QUESTIONS ABOUT ANNUAL WORKER DOSES, SAFETY UNDER VARIOUS 

CONDITIONS, AND EVENTS THAT OCCUR BY SYSTEM 

Table 1.60 Median Selections on Questions Related to the Safety of Gas 

Chromatographs Under Various Conditions (Ns = 37 to 40) 

With Current Regulations Without Current Regulations 

Normal (barriers intact) Very safe Very safe 

Off-normal (arer failure)ie safe Very safe 

3. Responses to question about most frequent non-reportable event (N = 20) 

"* contamination, frequency of 1 time per year (lof 20) 

"* exposure, frequency of less often than 1 time per year (1 of 20) 

"* loss of material, frequency of less often than 1 time per year (13 of 20) 

"* leaking source, frequency of less often than 1 time per year (1 of 20) 

"* device malfunction/failure, frequency of less often than 1 time per year (1 of 20) 

"* maintenance problem, frequency of less often than 1 time per year (1 of 20) 

"* failure to secure, frequency of 1 time per quarter (1 of 20) 

"* Failure to vent for H-3, frequency of less often than 1 time per year (1 of 20) 

1.31' SYSTEM 30: OTHER MEASURING SYSTEMS 

1. Estimated percentage of workers receiving doses at various levels (N = 27): 

- 99% < 50 mrem/yr 

• 100% < 500 mremn/yr 

2. Responses to questions about safety under various conditions. 

Table 1.61 Modal Selections on Questions Related to the Safety of Other 

Measuring Systems Under Various Conditions (Ns = 29 to 30) 

With Current Regulations I Without Current Regulations 

Normal (barriers intact) Very safe, 76% Somewhat safe, 53% 

Off-normal (barrier failure) Somewhat safe, 55% Somewhat safe, 38%

1-34

I I
RESPONSES TO QUESTIONS ABOUT ANNUAL WORKER DOSES, SAFETY UNDER VARIOUS 

CONDITIONS, AND EVENTS THAT OCCUR BY SYSTEM 

Table 1.62 Median Selections on Questions Related to the Safety of Other 

Measuring Systems Under Various Conditions (Ns = 29 to 30) 

With Current Regulations J Without Current Regulations 

Normal (barriers intact) Very safe Somewhat safe

O0ff-normal (barrier failure). [ Somewhat safe .: [Somewhat safe 

3. Responses to question about most frequent non-reportable event (N = 12) 

"* device damage, frequency of less often than 1 time per year (lof 12) 

"* exposure, frequency of 1 time per year (1 of 12) 

"* loss of material, frequency of less often than 1 time per year (8 of 20) 

"* device malfunction/failure, frequency of 1 time per year (1 of 12) 

"* failure to secure, frequency of 1 time per quarter (1 of 20) 

"* Failure to vent for H-3, frequency of 1 time per year (1 of 12) 

1.32 SYSTEM 31: SMALL SEALED SOURCES OR DEVICES 

(e.g., Those Used Under a General License) 

1. Estimated percentage of workers receiving doses at various levels (N = 29): 

* 97% < 50 mrem/yr 

* 99% < 500 mrem/yr 

* 100% < 1000 mrem/yr 

3. Responses to questions about safety under various conditions. 

Table 1.63 Modal Selections on Questions Related to the Safety of Small Sealed 

Sources or Devices Under Various Conditions (Ns = 37 to 38) 

With Current Regulations I Without Current Regulations 

Normal (barriers intact) Very safe, 66% Very safe, 35% 

Off-normal (barrier failure) Somewhat safe, 45% Very safe, 32%

1-35
RESPONSES TO QUESTIONS ABOUT ANNUAL WORKER DOSES, SAFETY UNDER VARIOUS 

CONDITIONS, AND EVENTS THAT OCCUR BY SYSTEM 

Table 1.64 Median Selections on Questions Related to the Safety of Small 

Sealed Sources or Devices Under Various Conditions (Ns = 37 to 38) 

With Current Regulations Without Current Regulations 

Normal (barriers intact) Very safe Somewhat safe 

Off-normal (barrier failure)[ Somewhat safe 1 1 Somewhat safe 

3. Responses to question about most frequent non-reportable event (N = 23) 

" loss of material, frequency varied from 1 time per month to less often than 1 time per 

year (21 of 23) 

"* maintenance problem, frequency of 1 time per month (1 of 23) 

"* failure to secure, frequency of 1 time per month (1 of 23) 

1.33 SYSTEM 32: VERY SMALL SEALED SOURCES OR DEVICES 

(e.g., Those Used Under Exemption) 

1. Estimated percentage of workers receiving doses at various levels (N = 26): 

* 100%<50mrem/yr 

2. Responses to questions about safety under various conditions. 

Table 1.65 Modal Selections on Questions Related to the Safety of Very Small 

Sealed Sources or Devices Under Various Conditions (Ns = 36 to 37) 

With Current Regulations [Without Current Regulations 

Normal (barriers intact) Very safe, 89% Very safe, 60% 

Off-normal (barrier failure) Very safe, 51I% Very safe, 56%

1-36

1 1
RESPONSES TO QUESTIONS ABOUT ANNUAL WORKER DOSES, SAFETY UNDER VARIOUS 

CONDITIONS, AND EVENTS THAT OCCUR BY SYSTEM 

Table 1.66 Median Selections on Questions Related to the Safety of Very Small 

Sealed Sources or Devices Under Various Conditions (Ns = 36 to 37) 

With Current Regulations Without Current Regulations 

Normal (barriers intact) [Vrs 7 Very safe 

Off-normal barer faflure)7s Very safe 

3. Responses to question about most frequent non-reportable event (N = 20) 

"* fire, frequency varied of less often than 1 time per year (1 of 20) 

"* loss of material, frequency varied from 1 time per year to less often than 1 time per year 

(19 of 20) 

1.34 SYSTEM 33: MANUFACTURING OR DISTRIBUTION OF 

DEVICES CONTAINING SEALED SOURCES 

1. Estimated percentage of workers receiving doses at various levels (N = 26): 

* 55% < 50 mrem/yr 

- 9 1% < 500 mrem/yr 

* 9 5% < 1000 mrem/yr 

• 5% > 1000 mrem/yr 

2. Responses to questions about safety under various conditions. 

Table 1.67 Modal Selections on Questions Related to the Safety of 

Manufacturing or Distribution of Devices Containing Sealed Sources 

Under Various Conditions (Ns = 37 to 38) 

With Current Regulations I Without Current Regulations 

Normal (barriers intact) Somewhat safe, 53% Somewhat safe, 35% 

Off-normal (barrier failure) Somewhat unsafe, 38% Very unsafe, 41%

1-37
RESPONSES TO QUESTIONS ABOUT ANNUAL WORKER DOSES, SAFETY UNDER VARIOUS 

CONDITIONS, AND EVENTS THAT OCCUR BY SYSTEM 

Table 1.68 Median Selections on Questions Related to the Safety of 

Manufacturing or Distribution of Devices Containing Sealed Sources 

Under Various Conditions (Ns = 37 to 38) 

With Current Regulations I Without Current Regulations 

Normal (barriers intact) Somewhat safe Somewhat unsafe 

Off-normal (bamer faure) Somewhat unsafe Somewhat unsafe 

3. Responses to question about most frequent non-reportable event (N = 18) 

"* contamination, frequency varied from 1 time per week to less often than 1 time per year 

(6 of 18) 

"* defective merchandise, frequency of 1 time per quarter (1 of 18) 

"* handling failure, frequency of 1 time per year (1 of 18) 

"* loss of material, frequency varied from 1 time per year to less often than 1 time per year 

(9 of 18) 

"* Leaking source, frequency of less often than 1 time per year (1 of 18) 

1.35 SYSTEM 34: MANUFACTURING OF RADIOACTIVE SOLIDS 

1. Estimated percentage of workers receiving doses at various levels (N = 13): 

* 36% < 50 mrem/yr 

* 74% < 500 mrem/yr 

* 88% < 1000 mrem/yr 

* 12%>l1000mrem/yr 

2. Responses to questions about safety under various conditions. 

1-38

1 1
RESPONSES TO QUESTIONS ABOUT ANNUAL WORKER DOSES, SAFETY UNDER VARIOUS 

CONDITIONS, AND EVENTS THAT OCCUR BY SYSTEM

Table 1.69 Modal Selections on Questions Related to the Safety of 

Manufacturing of Radioactive Solids Under Various Conditions 

(Ns = 23 to 26)

With Current Regulations I Without Current Re2ulations

Normal (barriers intact) Somewhat safe, 48% Very unsafe, 42% 

Off-normal (barrier failure) Very unsafe, 39% Very unsafe, 46% 

Table 1.70 Median Selections on Questions Related to the Safety of 

Manufacturing of Radioactive Solids Under Various Conditions 

(Ns = 23 to 26) 

With Current Regulations. Without Current Regulations 

Normal (barriers intact) Somewhat safe/somewhat Somewhat unsafe 

unsafe 

Off-normal (barrier failure) Somewhat unsafe Somewhat unsafe

3. Responses to question about most frequent non-reportable event (N = 18) 

* contamination, frequency varied from 1 time per week to less often than 1 time per year 

(13 of 18) 

- loss of material, frequency varied from 1 time per year to less often than 1 time per year 

(2 of 18) 

* leaking source, frequency of less often than 1 time per year (1 of 18) 

* spill, frequency less often than 1 time per year (2 of 18) 

1.36 SYSTEM 35: MANUFACTURING OF SOURCES CONTAINING

LIQUIDS 

l. Estimated percentage of workers receiving doses at various levels (N = 10): 

* 4 9% < 50 mrem/yr 

* 84% < 500 mrem/yr 

* 97% < 1000 mrem/yr 

* 3% > 1000 mrem/yr

1-39
RESPONSES TO QUESTIONS ABOUT ANNUAL WORKER DOSES, SAFETY UNDER VARIOUS 

CONDITIONS, AND EVENTS THAT OCCUR BY SYSTEM 

2. Responses to questions about safety under various conditions. 

Table 1.71 Modal Selections on Questions Related to the Safety of 

Manufacturing of Sources Containing Liquids Under Various 

Conditions (Ns = 20 to 23)

With Current Regulations I Without Current Regulations

Normal (barriers intact) So sVery unsafe, 39% 

Off-normal (barner failure) Ve unafe, 40% 1 Somewhat unsafe, 48% 

Table 1.72 Median Selections on Questions Related to the Safety of 

Manufacturing of Sources Containing Liquids Under Various 

Conditions (Ns = 20 to 23) 

With Current Regulations I Without Current Regulations 

Normal (barriers intact) Somewhat safie Somewhat unsafe 

Off-normal (barrier failure) Somewhat unsafe Somewhat unsafe

3. Responses to question about most frequent non-reportable event (N = 17) 

"• contamination, frequency unknown (11 of 17) 

"* loss of material, frequency unknown (I of 17) 

"* spills, frequency unknown (5 of 17) 

1.37 SYSTEM 36: MANUFACTURING OF SOURCES CONTAINING 

GASES 

1. Estimated percentage of workers receiving doses at various levels (N = 6): 

* 54% < 50 mrem/yr 

* 87% < 500 mrem/yr 

* 95% < 1000 mrem/yi 

* 5%>1000mrem/yr

1-40

1 1
RESPONSES TO QUESTIONS ABOUT ANNUAL WORKER DOSES, SAFETY UNDER VARIOUS 

CONDITIONS, AND EVENTS THAT OCCUR BY SYSTEM 

2. Responses to questions about safety under various conditions. 

Table 1.73 Modal Selections on Questions Related to the Safety of 

Manufacturing of Sources Containing Gases Under Various 

Conditions (Ns = 18 to 21)

With Current Regulations *1

Normal (barriers intact) Somewhat safe, 63% J Somewhat safe, 48% 

Off-normal (barrier failure) Somewhat safe, 44% Very unsafe, 38% 

Table 1.74 Median Selections on Questions Related to the Safety of 

Manufacturing of Sources Containing Gases Under Various 

Conditions (Ns = 18 to 21) 

With Current Regulations JWithout Current Regulations 

Normal (barriers intact) Somewhat safe J Somewhat unsafe 

Off-normal (barrier failure) Somewhat safe/somewhat Somewhat unsafe 

unsafe j

3. Responses to question about most frequent non-reportable event (N = 10) 

" contamination, frequency varied from 1 time per year to less often than 1 time per year 

(4 of 10) 

"• leak, frequency varied from 1 time per quarter to less often than 1 time per year (3 of 10) 

"* loss of material, frequency of 1 time per year (1 of 10) 

"* spill, frequency of less often than 1 time per year (1 of 10) 

"* uptake, frequency of 1 time per year (1 of 10) 

1.38 SYSTEM 37: INCINERATION OF WASTE 

1. Estimated percentage of workers receiving doses at various levels (N = 19): 

* 70% < 50 mrem/yr 

* 100%<500nmrem/yr

1-41
RESPONSES TO QUESTIONS ABOUT ANNUAL WORKER DOSES, SAFETY UNDER VARIOUS 

CONDITIONS, AND EVENTS THAT OCCUR BY SYSTEM 

2. Responses to questions about safety under various conditions.

Table 1.75 Modal Selections on Questions Related to the Safety of Incineration 

of Waste Under Various Conditions (Ns = 25 to 27)

With Current Regulations I Without Current Regulations

Normal (barriers intact) Somewhat safe, 48% Somewhat safe, 42% 

Off-normal (barer failure) Somewhat safe, 48% Somewhat unsafe, 39% 

Table 1.76 Median Selections on Questions Related to the Safety of Incineration 

of Waste Under Various Conditions (Ns =25 to 27) 

With Current Regulations Without Current Regulations 

Normal (barriers intact) Somewhat safe Somewhat safe 

Off-normal(barrierfailure) Somewhat safe Somewhat unsafe

3. Responses to question about most frequent non-reportable event (N = 13) 

"* contamination, frequency varied from 1 time per week to 1 time per year (5 of 13) 

"* leak, frequency of 1 time per year (1 of 13) 

"* loss of material, frequency of less often than 1 time per year (1 of 13) 

"* device malfunction/failure, frequency varied from 1 time per year to less often than 1 

time per year (2 of 13) 

"* wrong material, frequency varied from 1 time per month to less often than 1 time per 

year (4 of 13) 

1.39 SYSTEM 38: COMPACTING OF WASTE 

1. Estimated percentage of workers receiving doses at various levels (N = 21): 

* 50% < 50 mrem/yr 

* 99% < 500 mrem/yr 

* 100% < 1000 mremlyr

1-42

1 1
RESPONSES TO QUESTIONS ABOUT ANNUAL WORKER DOSES, SAFETY UNDER VARIOUS 

CONDITIONS, AND EVENTS THAT OCCUR BY SYSTEM 

2. Responses to questions about safety under various conditions. 

Table 1.77 Modal Selections on Questions Related to the Safety of Compacting 

of Waste Under Various Conditions (Ns =25 to 28) 

With Current Regulations [ Without Current Regulations 

Normal (barriers intact) somewhat safe, 57%J Somewhat unsafe, 44% 

Off-normal (arrier failure) Somewhat safe, 48% ].Somewhat safe, 48% 

Table 1.78 Median Selections on Questions Related to the Safety of Compacting 

of Waste Under Various Conditions (Ns = 25 to 28) 

With Current Regulations Without Current Regulations 

Normal (barriers intact) Somewhat safe Somewhat unsafe 

Off-normal (barrier failure) [Somewhatsafe Somewhat unsafe 

3. Responses to question about most frequent non-reportable event (N = 16) 

"* contamination, frequency varied from 1 time per week to 1 time per year (9 of 16) 

"* exposure, frequency of 1 time per year (1 of 16) 

"* leak, frequency varied from 1 time per year to less often than 1 time per year (3 of 16) 

"* spill, frequency varied from 1 time per quarter to 1 time per year (2 of 16) 

"* uptake, frequency of I time per year (1 of 16) 

1.40 SYSTEM 39: PACKAGING OF WASTE 

1. Estimated percentage of workers receiving doses at various levels (N 29): 

* 4 5% < 50 mrem/yr 

* 96% < 500 mrem/yr 

* 99% < 1000 mrem/yr 

* 1%>l1000mrem/yr 

2. Responses to questions about safety under various conditions.

1-43
RESPONSES TO QUESTIONS ABOUT ANNUAL WORKER DOSES, SAFETY UNDER VARIOUS 

CONDITIONS, AND EVENTS THAT OCCUR BY SYSTEM

Table 1.79 Modal Selections on Questions Related to the Safety of Packaging of 

Waste Under Various Conditions (Ns = 24 to 28)

With Current Regulations I Without Current Regulations 

Normal (barriers intact) Somewhat safe, 46% Somewhat safe, 48% 

Off-normal (arer failure) Somewhat safe, 58% Somewhat unsafe, 44% 

Table 1.80 Median Selections on Questions Related to the Safety of Packaging 

of Waste Under Various Conditions (Ns = 24 to 28) 

With Current Regulations J Without Current Regulations 

Normal (barriers intact) Somewhat safe- Somewhat safe 

Off-normal (barrier failure) Somewhat safe.I Somewhat unsafe 

3. Responses to question about most frequent non-reportable event (N = 14) 

"* contamination, frequency varied from I time per week to 1 time per year (11 of 14) 

"* spills, frequency varied from 1 time per quarter to 1 time per year (2 of 14) 

"* transportation incident, frequency of less often than 1 time per year (1 of 14) 

1.41 SYSTEM 40: SOLIDIFICATION OF WASTE 

1. Estimated percentage of workers receiving doses at various levels (N 7): 

- 34% < 50 mrem/yr 

* 100% < 500 mrem/yr 

2. Responses to questions about safety under various conditions. 

1-44

1 1
RESPONSES TO QUESTIONS ABOUT ANNUAL WORKER DOSES, SAFETY UNDER VARIOUS 

CONDITIONS, AND EVENTS THAT OCCUR BY SYSTEM 

Table 1.81 Modal Selections on Questions Related to the Safety of Solidification 

of Waste Under Various Conditions (Ns = 19 to 22)

With Current Regulations I Without Current Regulations

Normal (barriers intact) Very safe, 46% Somewhat safe, 53% 

Off-normal ( ier failure) Somewhat safe, 45% Somewhat unsafe, 50% 

Table 1.82 Median Selections on Questions Related to the Safety of 

Solidification of Waste Under Various Conditions (Ns = 19 to 22) 

With Current Regulations ] Without Current Regulations 

Normal (barriers intact) Somewhat safe Somewhat safe 

Off-normal (barrier failure) Somewhat safe/somewhat Somewhat unsafe 

unsafe

3. Responses to question about most frequent non-reportable event (N = 8) 

"* contamination, frequency varied from 1 time per week to 1 time per year (5 of 8) 

"* device malfunction/failure, frequency of 1 time per year (1 of 8) 

"* spill, frequency varied from 1 time per quarter to 1 time per year (2 of 8)

1-45
RESPONSES TO QUESTIONS ABOUT ANNUAL WORKER DOSES, SAFETY UNDER VARIOUS 

CONDITIONS, AND EVENTS THAT OCCUR BY SYSTEM 

1.42 SYSTEM 41A: NUCLEAR LAUNDRIES 

1. Estimated percentage of workers receiving doses at various levels (N = 1): 

* 0 % < 50 mrem/yr 

* 100% < 500 mrem/yr 

1.43 SYSTEM 41B: DECONTAMINATION SERVICES 

1. Estimated percentage of workers receiving doses at various levels (N 1): 

* 0% < 50 mrem/yr 

- 10%<500mrem/yr 

0 80% < 1000 mrem/yr 

* 10% > 1000 mrem/yr 

1-46

I I
2 RANK ORDERING OF NUCLEAR BYPRODUCT MATERIAL 

SYSTEMS

Survey Results: Nuclear Byproduct Material Systems Rank Ordered 

With Respect To Mean Annual Estimated Dose to Workers in Millirem 

For Comparison With Modal and Median Dose Estimates And With 

Responses Related To Perceived Safety Under Various Conditions.

"Safety" Modal Selection "Safety" Median 

Selection

System ,; .2 2 .2 .2 .2 .2 . o o o o = " " 

Number Operation E r= Cr = C.. 0. 

41b decontamination services 785 501-1000 501-1000 

22 radiography - field use 482 1201-500 201-500 ss vu vu vu ss vu vu vu 

34 manufacturing of sources 362 ND-50 101-200 ss vu vu vu ss su su su 

containing solids 

16 nuclear pharmacies 355 101-200 101-200 ss su su vu ss su su su/vu 

5 10 CFR 35.200 - nuclear 294 201-500 101-200 ss su ss su ss su su su medicine with ggenerator(s) 

21 radiography - permanent 1262 1ND-50 101-200 ss su su vu ss su su vu 

installation11 

35 manufacturing of sources 236 ND-50 51-100 ss vu vu su ss su su su containing liquids 

9 brachytherapy - manual 231 ND-50 51-100 ss su vu vu ss su su vu 

Safterloading 

36 manufacturing of sources 223 ND-50 ND-50 ss ss :ss vu ss ss/su su su 

containing gases11 

7 10 CFR 35.300 - nuclear 211 101-200 101-200 ss su su su ss su su su 

medicine 

!41a nuclear laundries 210 101-200 101-200 

19 well logging - tracers and 171 201-500 51-100 ss ss/su ss/su su ss su su su 

field flood studies 

33 manufacturing or distribution 167 <ND ND-50 ss su ss vu ss ,su su su of devices containing sealed 

sourcesI 

6 10 CFR 35.200 - nuclear 155 101-200 '101-200 vs Iss ss su vs ss ss su 

medicine without a generator1 

8 brachytherapy using seeds 154 51-100 51-100 ss su su vu ss su su su I

Table 2.1

Question 1

2-1
RANK ORDERING OF NUCLEAR BYPRODUCT MATERIAL SYSTEMS

"Safety" Modal Selection 1*

"Safety" Median 

Selection

'E 

4) 

o44 0 0 00 

System-• • ... z= Z; V.. 

Number Operation EE • - o. • - • - • 

20 well logging - using sealed 135 ND-50 51-100 ss ss su vu ss su su su 

sources 

i39 packaging of waste 129 ND-50 51-100 ss ss ss su ss ss ss su 

17 veterinary use 125 ND-50 51-100 ss ss ss su ss ss ss su 

40 solidification of waste III ND-50 51-100 vs ss ss su ss ss/su ss su 

410 CFR 35. 100 - nuclear 102 101-200 51-100 vs ss ss su vs ss ss ss 

medicine and human use 

researchIII 

10 brachytherapy - low dose rate 91 ND-50 ND-50 ss su su vu ss so su sw'vu 

remote afterloadingI1 

38 compacting of waste 89 ND-50 ND-50 / ss ss ss su ss ss ss su 

51-10011 

15 gamma stereotactic surgery 88 ND-50 ND-50 vs/ss vu su vu ss su/vu su vu 

11 Ibrachytherapy - high dose 76 !ND-50 ND-50 ss vu vu vu ss su SIX vu 

irate remote aflerloadingII 

IR&D synthesis laboratories 66 <ND ND-50 vs ss ss su vs/ss ss ss su 

23 pool irradiators 65 ND-50 ND-50 vs vu vu vu ss su su vu 

18g R&D on animals 63 ND-50 ND-50 vs/ss ss ss ss :ss ss ss Iss/su 

27 portable gauges 58 ND-50 ND-50 vs/ss ss- ss su vs/ss ss ss !su 

12 brachytherapy - eye 56 ND-50 ND-50 vs su ss/vu su ss su su su 

applicator 

14 teletherapy devices 56 <ND ND-50 ss vu su vu ss su/Vu su vu 

37 incineration of waste 44 ND-50 ND-50 ss ss ss su ss ss ,ss su 

13 10 CFR 3 5.400 - diagnostic 42 <ND ND-50 vs ss ss ss vs ss ss ss 

devices 

28 x-ray fluorescence devices 27 <ND <ND vs ss ss vs/ss vs ss ss ss 

2 R&D laboratories using 26 <ND ND-50 vs ss ss ss vs ss ss su 

carbon, hydrogen, iodine, 

phosphorus, and sulfur 

13a 10 CFR. 35.500 - diagnostic 25 ND-50 ND-50 vs ss ss • vs vs ss ss ss 

I I ~devicesII I

2-2

I I

Question 1
RANK ORDERING OF NUCLEAR BYPRODUCT MATERIAL SYSTEMS

Question 1 "Safety" Modal Selection "Safety" Median 

Selection

E 

System

Number Operation E •E • g - g 

31 small sealed sources or 21 <ND <ND vs ]ss vs vs vs ss ss ss 

devices (e.g., those used under a general license) 

25 fixed gauges - gamma 20 <ND <ND vs ss ss ss vs ss ss su 

emittersI 

.24 self-shielded irradiators 13 <ND <ND vs ss ss ss vs ss ss ss 

26 fixed gauges - beta emitters I11 <ND <ND vs ss ss ss vs ss ss ss 

30 other measuring devices I11 <ND <ND !vs ss ss ss vs ss ss ss 

3 in vitro laboratory testing 9 <ND <ND vs vs vs ss vs vs vs/ss ss 

29 gas chromatographs 6 <ND <ND vs vs vs vs vs- vs vs ]vs 

32 very small sealed sources of 5 <ND <ND vs !vs vs vs ]vs vs vs vs 

devices (e.g., those used 

under an exemption)

Question 3: Normal operating conditions, current regulations. 

Question 4: Off-normal operating conditions, current regulations. 

Question 5: Normal operating conditions, without current regulations. 

Question 6: Off-normal operating conditions, without current regulations 

Codes: vs = very safe 

ss = somewhat safe 

su = somewhat unsafe 

vu = very unsafe 

*The review group recognized that, in calculating means using the unequal class intervals for 

dose provided to the respondents, low dose estimates received less weight than high dose 

estimates.

2-3
RANK ORDERING OF NUCLEAR BYPRODUCT MATERIAL SYSTEMS

While this was recognized as reducing the value of the mean as an indicator of the annual dose to 

workers, it was judged to be "close enough" for developing a "ballpark" ranking of systems for 

comparison with other survey results. 

2-4

I I
3 RESPONDENTS DEFINITIONS OF "SAFE" ETC.

Table 3.1 Each Respondent's Definition of "Very Safe," "Somewhat Safe," 

"Somewhat Unsafe," and "Very Unsafe"

Respondent J Very Safe J Somewhat Safe ] Somewhat Unsafe Very Unsafe Number,! 

I Individual probably Individual probably Individual will receive Prob. of overexposure 

will not receive will receive recordable 2.5 R - 5R is high 

recordable dose dose - 2.5 R 

2 No harm possible No Not life threatening Life threatening 

permanent/noticeable 

harmn 

3 Can be unregulated Not much danger to Possibility of Possibility of injuries 

users overexposures and to personnel 

personnel 

contamination 

4 Inherently safe, little Need to exercise some Can significantly Very dependent on 

need for regulation, controls, can receive expose however safety strict compliance with 

worst case scenario regulatory significant systems in place rather safety procedures to 

nothing to lose sleep exposure but operator than depend on human provide safety, when 

over would have to have to compliance with deviations from 

completely drop the procedures compliance occur, 

,ball actual potential for 

significant exposures, 

__including death 

5 No harm to public or Public is safe but puts Both public and Harm to both public employees as long as employees at risk employees are at risk and employees 

procedures are 

followed 

6 No exposure Some exposure More exposure Over exposure 

7 <ND <ND to 20 mRem 21 mRem to 50 mRem > 50 mRem 

8 0 - Low probability of Low to medium medium to high High + probability of 

biological risk to probability of probability of biological risk to 

occupational workers biological risk to biological risk to occupational workers 

and/or general public occupational workers occupational workers and/or general public 

and/or general public and/or general public 

9 Within occupational Small potential to Could exceed exposure Exceeds exposure radiation exposure possibility of adverse limits, lack of limits, lack of control 

limit, adequately health effects, supervision, lack of of radioactive material, 

trained employees, substantial compliance training loss of material, no 

strong oversite, with reg, within training of personnel 

compliance with all occupational exposure 

regs limits

3-1
RESPONDENTS DEFINITIONS OF "SAFE" ETC.

Respondent Very Safe SomewhatUnsafe VeryUnsafe Number.. 

10 Very low doses & little A greater possibility of Likely to have higher High probability of 

contamination, I exposure to workers exposures/contaminatio contamination or 

considered the health but still unlikely n but only if licensee exposure 

risk to be minimal does not follow 

procedures 

11 No health effect Minimal health effect Possible minor health Possible major health 

effect effect 

12 no definition provided no definition provided no definition provided no definition provided 

13 With minimal exposure Low probability of any Possibility of an Moderate to high 

to any individual unusual or high unnecessary or high probability of an 

exposures to any exposure to any unnecessary of high 

individual individual exposure to any 

individual 

14 Fool proof Not likely to result in May cause high Likely to receive 

health impacts, low exposure up to 2 rem exposures or uptakes 

exposure, less than above 2 rem 

500 mR 

15 Very little threat to A small threat to Threat to occupational A threat to 

public health & safety, occupational safety, safety, somewhat of a occupational safety, a 

very little threat to very little threat to (or a possible) threat to threat to public health 

occupational safety public health & safety public health & safety and safety 

16 Exposures to workers Potential for public Potential for workers to Potential for injury to 

& public not likely to member to receive a receive a dose of > 500 worker and/or public 

be> 100 mrem/year dose> 100 mrem/year mrem/yr. (rad. bums, death, 

under normal injury) if significant 

operations controls not in place 

17 Little or no chance of Exposure between 50 - Exposure between 100 Exposure > 500 mrem 

exposure > 50 mrem 100 mrem - 500 mrem public damage to property 

exposure potential public exposure 

injury potential injury and/or 

death 

18 Very little potential of Potential of exposure Potential of exposure > Potential of > 5000 

radiation exposure < 200 mrem/year 200 mrem/year (W.B) mrem/yr. (W.B.) 

(W.B.)

3-2

I 1
RESPONDENTS DEFINITIONS OF "SAFE" ETC.

Respondent 1 Very Safe Somewhat Safe Somewhat Unsafe j Very Unsafe 

19 Exposures to workers Potential for public Potential for worker Potential for harm 

and public not exposure to exceed exposures to exceed 5 (radiation bums, organ normally likely to 100 mrem/year if not rem/year absent proper impairment, etc.) from 

exceed 100 mrem/year controlled projects - controls radiation exposure if 

under normal workers normally significant controls not 

circumstances required to be implemented 

monitored for 

exposure (i.e. > 500 

tmrem/year likely) 

20 No impact on worker As above [to the left] Potential for dose to Highly probable that 

safety, even in accident except during accident workers during normal worker could receive 

situation, very unlikely situation worker could operations & certainly dose during normal 

workers or public to possibly receive small during accident operations & potential receive dose doses [with] no effect situations for exposure to public 

to public if operations are not _ _strictly controlled 

21 Very safe if there is no Somewhat safe if there Somewhat unsafe if Very unsafe if it is 

chance of significant is only a small chance there is a moderate likely that significant exposure/contaminatio of significant chance of significant exposure/contaminatio 

n occurring exposure/contaminatio exposure/contamination n may occur 

n occurring occurring 

22 Little or no rad. Some chance of Chance of significant lethal 

exposure above exposure, but below acute effects (e.g., loss 

background threshold for acute of fingers in some 

effects radiography exposures) 

23 Little or no Radiological dose Radiological dose Radiological dose 

radiological dose to measurable but greater than public limit approaches or 

individuals probably less than 100 but less than worker exceeding worker limit 

mrem limit (*from a risk 

standpoint, none of the 

operations would pose 

a significant risk) 

24 No significant or likely Some potential likely greater potential could Significant safety safety consequence not significant be significant consequence high little to no potential for potential of occurrence 

occurrence 

25 Would cause no one to Would cause one Would cause one or Would cause several 

receive a dose in person to receive a two people per year to people per year to 

excess of 5 rem to the dose in excess of 5 receive doses in excess receive doses in excess 

whole body, 50 rem to rem every few years of 5 rem of 5 rem 

an extremity, etc.

3-3
RESPONDENTS DEFINITIONS OF "SAFE" ETC.

Respondentj SNumber Very Safe j Somewhat Safe Somewhat Unsafe Very Unsafe. 

26 Adequate controls in Have adequate Inadequate procedures, None of the above [to 

place to keep procedures, meet inadequate controls, left] 

exposures ALARA, intent of regs meet intent of regs 

meet below public dose 

limits, meet and follow 

regs, have procedures 

in place that are 

adequate to protect 

public health and 

safety 

27 Minimum chance of Slight to moderate Moderate to high High probability of 

any radiation exposure probability of some probability of some excessive radiation 

under any radiation exposure; but exposure to radiation exposure; slight to high 

circumstance not exceeding slight chance of possibility of life 

regulatory limits exceeding regulatory threatening or 

limits damaging radiation 

exposure 

28 No risk of radiation Slight potential for greater potential for high risk for exposure 

exposure exposure or exposure 

contamination 

29 No risk of radiation Limited risk of Minimal risk of Unnecessary risk of 

exposure if device or radiation exposure if radiation exposure if radiation exposure if 

RAM is used correctly device or RAM is used device or RAM is used device or RAM is used 

(to operator, user or correctly (operator, correctly (operator, user correctly (operator, 

public) user or public) or public) user or public) 

30 Chance of incident low Mod. to low chance of Real probability to High chance for inc., 

to non-existent, lowest inc., small act./exp., mod., medium high actJexp. (Ci

of activities, exposure minimal handling activity/exp. (mCi-Ci), MCi), daily handling 

rates, minimal to no daily handling w/ daily handling 

handling tools only 

considerations 

31 Safe "no matter what Could result in loss of Could result in loss of If control of material is 

happens" material control w/ material control with lost would probably. 

very low consequence minor consequence result in real public 

hazard 

32 No or little chance of Consequences of event Consequences of event Consequences of event 

radiological not likely to result in likely to significantly to likely to 

consequences exposure in excess of result in exposure 

part 20 limits sufficient to result in 

some physiological 

damage (i.e., 

chromosomal)

3-4

I I
RESPONDENTS DEFINITIONS OF "SAFE" ETC.

Respondent Very Safe Somewhat Safe: Somewhat Unsafe Very Unsafe Number I - I 

33 Very little chance of Safe during normal Safe during normal Operations unsafe at 

exposure or operations, small operations, but any any level. 

contamination during chance of change in procedures or 

operations, even with exposure/contaminatio error by operator can 

error by operator/user n, User can create create hazard, 

hazard by not safeguards not in place 

following procedures of poor 

or bypassing safety 

features - even with 

this, operator not 

likely to be seriously 

hurt 

34 Virtually no dose to Less that 100 mrem to Greater than doses nonstochastic effects 

users or public public annually, less above [to the left] possible 

than 500 mrem to in "b" 

users annually 

35 no definition provided no definition provided no definition provided no definition provided 

36 Whole body Annual exposures to Reasonable potential High probability of an 

exposure/internal personnel do not for exceeding an overexposure occurring exposure/exposure to exceed 25% of any exposure limit if if situation is not 

lens of eye, etc. <10% limit situation is not corrected very quickly of established limits corrected in a timely (within an hour) 

fashion 

37 In a worst case In the case of an In the case of an In the case of and 

scenario the possibility incident or accident incident or accident an incident or accident an 

of injury or adverse the possibility of an injury or adverse health injury or adverse health 

health effects are injury or adverse effects are possible. effects are likely and 

remote. health effects aye without normal 

unlikely. operating conditions 

and regulatory controls 

injury and adverse 

health effects are possible. 

38 no definition provided no definition provided no definition provided no definition provided 

39 No or very little chance Chance for exposure Excessive radiation Personnel exposures for radiation exposure, to personnel that is or exposure that can or that can cause or does 

internal nor external in can be 2 to 5 times will cause physical cause physical effects 

excess of 50 mR over normal background. effects but are from radiation 

normal background. undetectable. exposure.

3-5
RESPONDENTS DEFINITIONS OF "SAFE" ETC.

Respondent Number Very Safe ( Somewhat Safe Somewhat Unsafe Very Unsafe I wa nae eyUsf 

40 small chance of failure, middling chance of process/equipment Personnel 

low significance of failures of process, failure whether from uncooperative, 

exposure, well chance of exposure design or abuse, lack of cavalier, equipment 

controlled program <500mRem per concern by employees, contains large sources 

incident, controlled no real management which can be exposed 

program- support. to personnel. no 

management support 

for safety. Bottom line 

-get the job done. 

41 Even: without good With good controls in material amount or use Inherently dangerous 

controls in place and place and good work could be dangerous due to amount/material 

work practices the practices without close attention unless controls & 

material use is safe contamination or dose to practices & controls. practices are rigorously 

could occur through implemented & 

carelessness or enforced. 

accident.

3-6

1 1
4 RESPONSES TO QUESTIONS ABOUT REGULATORY 

DECISION-MAKING

Table 4.1 Responses to Questions Concerning About Regulatory Agencies 

Should Make Decisions

0 

SZ 

Consensus Opinion of the Public 0 12 115 9 

Financial Burden of Regulation to the Licensee 1 23 19 3 

Financial Burden of Regulation to the Public 2 19 13 2 

Evaluation of Radiological Risk 36 0 t0 0 

Benefit of the Use of Material to Society 18 18 1 0 

Other (supplied by respondents): 

Opinion of Licensees, Their Societies and Standards Organizations 0 1 0 0 

Historical Data (licensee compliance) 10 1 0 0 

NRC Efficiency/Capability @ Task (considers limited resources -0 1 0 0 

personnel, budget) 0111 

Generation of Long-lived Waste 0 1 0 0 

Generation of Mixed Waste 0 1 0 0 

Manpower of Regulator 0 0 1 0 

Burden Imposed vs Risk Averted (risk of harm & financial risk) 1 0 0 0 

Public Participation - to the extent that public feels that they are being 1 0 0 0 

adequately protected, because in reality the are being adequately 

protected 01

4-1
Appendix A 

Questionnaire
APPENDIX A

Questionnaire 

The survey administered to the NRC and agreement States materials licensing and inspection 

personnel appears on the following pages.

A-I
APPENDIX A

o• UNITED STATES 

"NUCLEAR REGULATORY COMMISSION 

WASHINGTON. D.C. 2*55U•O 

MEMORANDUM TO: A. Randolph Blough. Director 

Division of Nuclear Materials Safety, Region I 

Douglas M. Collins, Director 

Division of Nuclear Materials Safety, Region II 

Cynthia D. Pederson, Director 

Division of Nuclear Materials Safety, Region III 

Ross A. Scarano, Director 

Division of Nuclear Materials Safety, Region IV 

FROM: Frederick C. Combs. Acting Director 

Division of Industrial and 

Medical Nuclear Safety, NMSS 

SUBJECT: SURVEY BY THE NUCLEAR BYPRODUCT 

MATERIAL RISK REVIEW GROUP 

As you are aware, the Division of Industrial and Medical Nuclear Safety has formed a nuclear 

byproduct material risk review working group composed of NRC employees and an employee 

of the State of Colorado. The group's goals are to identify and document the technical basis for 

a risk-informed approach to nuclear byproduct material regulation and to develop plans for a 

graded approach to regulation of that material based on risk information. The working group 

has obtained the services of a contractor, SCIENTECH, Inc., to perform the majority of the 

technical work necessary to meet those goals. 

The information resources available to SCIENTECH have been largely limited to published 

reports, the experience and training of its own staff and consultants, and the responses of 

members of the regulated community to a web page survey. In addition, the review group 

believes that information beyond that available to SCIENTECH will be valuable in meeting its 

goals and that, collectively, nuclear material licensing and inspection personnel have an 

unparalleled breadth and depth of knowledge about the systems of interest. As a result, the 

working group has developed a survey for distribution to NRC and Agreement State personnel 

involved in licensing and inspection of materials regulated under 10 CFR Parts 30 through 39 or 

equivalent state regulations. The intent is to capture the 'corporate knowledge" of those 

personnel and to augment and confirm information provided by SCIENTECH. 

CONTACT: Dennis Serig, NMSS/IMNS 

(301) 415-7901

A-2
APPENDIX A

A. Randolph Blough, et al -2

We ask that you distribute copies of the attached survey to several (e.g.. 5 or 6) of your 

experienced licensing and inspection personnel. A test of the survey indicated that it takes on 

the order of 1.5 to 3 hours to complete. The selected respondents should return the completed 

survey by August 14, 1998, to Dennis Serig at mail stop T8F5. Time for completing the survey 

should be charged against regional or headquarters FTE allocated to RITS code 222BA, TAC 

Number L21136, Risk Assessment. 

Attachment: Survey of Licensing and Inspection Personnel

A-3
APPENDIX A

SURVEY OF LICENSING AND INSPECTION PERSONNEL 

BACKGROUND. The Nudear Regulatory Commission's (NRC's) Office of Nuclear Material 

Safety and Safeguards (NMSS) has established a Nuclear Byproduct Material Risk Review 

Group, composed of representatives from the NRC and an Agreement State. The group's 

goals are: (1) to identify and document a technical basis for a risk-informed approach to the 

regulation of nuclear byproduct material, and (2) to develop plans for a graded approach to 

nuclear byproduct material regulation based on risk information. The effort encompasses 

byproduct materials that are currently defined in Section I1.e(1) of the Atomic Energy Act of 

1954, and Title 10 of the Code of Federal Regulations (CFR) Section 30.4 and addressed by 10 

CFR Parts 30-36 and 39, or the equivalent regulations of an Agreement State. 

NRC has contracted SCIENTECH, Inc. to assist the group in its effort. The attached survey 

was developed to confirmand augment information gathered by Scientech and to assist in 

development of plans for a graded approach to nuclear byproduct material regulation informed 

by risk. The survey is designed to be completed by NRC and Agreement State licensing and 

inspection personnel. and it has been discussed with NRC Regional Management, NRC's 

Office of State Programs, and the Executive Council of the Organization of Agreement States. 

It asks about the typical radionuclides and quantities of material possessed and used by certain 

types of regulated entities (e.g., research and development synthesis laboratories, fixed gauge 

users, owners of exempt products), types and frequency of incidents that occur at various 

facilities (e.g., non-reportable incidents such as spills, contamination), typical annual doses 

received by various personnel, and the respondent's perception of the risk associated with 

various regulated activities. 

INSTRUCTIONS. Please limit your answers to byproduct materials (see paragraph 1). Please 

answer based on your memory of experience in licensing and inspection activities. Do not 

review license files, inspection reports, etc. and do not consult with other staff. If you do not 

have experience or information about a particular subject or question, indicate that fact in the 

space provided. Partial responses may. however, be valuable. If you can answer parts of a 

question, but not all, please answer what you can. It should take approximately 1.5 to 3.0 

hours to complete the survey. When complete, please return the survey to: 

Dennis Serig 

NMSS 

Mail Stop: T8F5 

FOR NRC PERSONNEL: Charge time expended completing the survey to the following RITS 

code: 

222FB L21136 RISK ASSESSMENT

A-4
APPENDIX A

UNITED STATES 

NUCLEAR REGULATORY COMMISSION 

WA,,INGTON. D.C. UU6-COm 

",S*PI July 23, 1998 

ALL AGREEMENTS STATES 

OHIO, OKLAHOMA, PENNSYLVANIA 

TRANSMITTAL OF STATE AGREEMENTS PROGRAM INFORMATION (SP-98-065) 

Your attention is invited to the enclosed correspondence which contains: 

INCIDENT AND EVENT INFORMATION ............. 

PROGRAM MANAGEMENT INFORMATION ...... 

TRAINING COURSE INFORMATION .................. 

TECHNICAL INFORMATION ............................... 

OTHER INFORMATION ....................................... XX REQUESTED RESPONSE 

TO SURVEY 

Supplementarv Information: As you were informed by SP-98-028, the U.S. Nuclear Regulatory Commission's Office of Nuclear Material Safety and Safeguards has formed a nuclear byproduct material risk review working group composed of NRC employees and an employee of the State of Colorado. The group's goals are to identify and document the technical basis for a risk-informed approach to nuclear byproduct material regulation and to develop plans for a graded approach to regulation of that material based on risk information. The effort 

encompasses byproduct materials that are currently defined in Section 11 .e(1) of the Atomic Energy Act of 1954, and Title 10 of the Code of Federal Regulations (CFR) Section 30.4 and addressed by 10 CFR Parts 30-36 and 39, or the equivalent regulations of an Agreement State. The working group has obtained the services of a contractor, SCIENTECH, Inc., to perform the majority of the technical work necessary to meet its goals. 

The information resources available to SCIENTECH have been largely limited to published reports, the experience and training of its own staff and consultants; and the responses of members of the regulated community to a web page survey. The review group believes that information beyond that available to SCIENTECH will be valuable in meeting its goals and that, collectively, nuclear material licensing and inspection personnel have an unparalleled breadth and depth of knowledge about the systems of interest. As a result, the working group has developed a survey for distribution to NRC and Agreement State personnel involved in licensing and inspection of materials within the scope of its review (enclosed). The intent is to capture the "corporate knowledge" of those personnel and to augment and confirm information provided by SCIENTECH. 

Agreement States are asked to participate by distributing copies of the survey to several (e.g.. 2 or 3) of your experienced licensing and inspection personnel. A test of the survey indicated that it takes on the order of 1.5 to 3 hours to complete. The selected respondents should return the

A-5
APPENDIX A

SP-98-065 -2. 

completed survey by August 14, 1998, to the individual named below. Any questions 

concerning the survey may be directed to Dr. Serig. 

U.S. Nuclear Regulatory Commission 

ATTN: Dennis I. Serig 

Mail Stop T8F5 

Washington, D.C. 20555-0001 

Phone: 301-415-7901 

Fax: 301-415-5 36 9 

E-Mail: dis@nrc.gov 

This information request has been approved by OMB 3150-0029, expiration April 30, 2001. 

The estimated burden per response to comply with this voluntary collection is 1.5-3.0 hours. 

Forward any comments regarding the burden estimate to the Information and Records 

Management Branch (T-6 F33), U.S. Nuclear Regulatory Commission, Washington, DC 20555

0001, and-to the Paperwork Reduction Project (3150-0029). Office of Management and Budget. 

Washington, DC 20503. If a document does not display a currently valid OMB control number, 

the NRC may not conduct or sponsor, and a person i ot required to respond to a collection of 

information. 

Paul H. Lohaus, Deputy Director 

Office of State Programs 

Enclosure: 

As stated

A-6
APPENDIX A

SURVEY OF LICENSING AND INSPECTION PERSONNEL 

BACKGROUND. The Nuclear Regulatory Commission's (NRC's) Office of Nuclear Material 

Safety and Safeguards (NMSS) has established a Nuclear Byproduct Material Risk Review 

Group, composed of representatives from the NRC and an Agreement State. The group's 

goals are: (1) to identify and document a technical basis for a risk-informed approach to the 

regulation of nuclear byproduct material, and (2) to develop plans for a graded approach to 

nuclear byproduct material regulation based on risk information. The effort encompasses 

byproduct materials that are currently defined in Section 11 .e(1) of the Atomic Energy Act of 

1954, and Title 10 of the Code of Federal Regulations (CFR) Section 30.4 and addressed by 10 

CFR Parts 30-36 and 39, or the equivalent regulations of an Agreement State. 

NRC has contracted SCIENTECH, Inc. to assist the group in its effort. The attached survey was developed to confirm and augment information gathered by Scientech and to assist in 

development of plans for a graded approach to nuclear byproduct material regulation informed 

by risk. The survey is designed to be completed by NRC and Agreement State licensing and 

inspection personnel, and it has been discussed with NRC Regional Management, NRC's 

Office of State Programs, and the Executive Committee of the Organization of Agreement 

States. It asks about the typical radionuclides and quantities of material possessed and used 

by certain types of regulated entities (e.g.. research and development synthesis laboratories, 

fixed gauge users, owners of exempt products), types and frequency of incidents that occur at 

various facilities (e.g., non-reportable incidents such as spills, contamination), typical annual 

doses received by various personnel, and the respondent's perception of the risk associated 

with various regulated activities. However, when responding to the survey, please do not 

consider doses, intended or unintended, to patients during medical diagnosis or treatment. 

Specifically, doses to patients is outside the scope of the Nuclear Material Risk Review Group. 

INSTRUCTIONS. Please limit your answers to byproduct materials (see paragraph 1). Please answer based on your memory of experience in licensing and inspection activities. Do not 

reView license files, inspection reports, etc. and do not consult with other staff. If you do not 

have experience or information about a particular subject or question, indicate that fact in the 

space provided. Partial responses may, however, be valuable. If you can answer parts of a question, but not all, please answer what you can. It should take approximately 1.5 to 3.0 

hours to complete the survey. When complete, please return the survey to: 

U.S. Nuclear Regulatory Commission 

'ATTN: Dennis Serig 

Mail Stop: T8F5 

Washington, DC 20555-0001 

E-Mail: dis@nrc.gov 

Fax: 301-415-5369

A-7
APPENDIX A

Section 1 - Questions About All Types of Operations 

1. Based on your experience, indicate the percentage of workers that typically receive annual 

whole-body doses in the indicated ranges for each type of operation listed below under 

current regulations and policies for licensing and inspection. Percentages in each row 

should sum to 100. Mark an X in the "don't know" column if you're unfamiliar with the 

operation. 

ND = NON-DETECTABLE 

Operation <ND ND to 51 to 101 to 201 to 501 to > 1000 don't 

50 mrem 100 200 500 1000 mrem know 

mrem mrem mrem mrem 

R&D synthesis laboratories 

R&D laboratories using carbon, 

hydrogen, iodine, phosphorus, and 

sulfur 

in vitro laboratory testing 

10 CFR 35.100 - nuclear medicine 

and human use research 

10 CFR 35.200 - nuclear medicine 

with generator(s) 

10 CFR 35.200 - nuclear medicine 

without a generator 

10 CFR 35.300 - nuclear medicine 

brachytherapy - using seeds 

brachytherapy - manual afterloading 

brachytherapy - low dose rate remote 

afterloading 

brachytherapy - high dose rate 

remote alterloading 

brachytherapy - eye applicator 

10 CFR 35.400 - diagnostic devices 

teletherapy devices 

gamma stereotactic surgery 

nuclear pharmacies 

veterinary use 

R&D on animals 

well logging - tracers and field flood 

studies 

well logging - using sealed sources 

radiography - permanent installation 

radiography - field use

A-8

1 1
APPENDIX A

A-9

Operation < ND ND to 51 to 101 to 201 to 501 to > 1000 don't 

50 mrern 100 200 500 1000 mrem know mrem mrem mrem mrem 

pool irradiators 

self-shielded irradiators 

fixed gauges - gamma emitters 

fixed gauges - beta emitters 

portable gauges 

x-ray fluorescence devices 

gas chromatographs 

other measuring devices 

small sealed sources or devices (e.g. 

those used under a general license) 

very small sealed sources or devices 

(e.g., those used under an 

exemption) 

manufacturing or distribution of 

devices containing sealed sources 

manufacturing of radioactive solids 

manufacturing of radioactive liquids 

manufacturing of radioactive gases 

incineration of waste 

compacting of waste 

packaging of waste 

solidification of waste 

other Part 30 operation 

(describe each):
APPENDIX A

2. Based on your experience, specify in the space provided what you believe to be the 

non-reportable incident (e.g., spill, contamination, loss of material) that is most frequent for 

each type of operation listed below under current regulations and policies for licensing and 

inspection. Once you have specified an incident, mark an X in the column that is your best 

estimate of the frequency of that incident per licensee. Mark an X in the "don't know" 

column if you're unfamiliar with the operation. 

Operation Most I time I time I time I time less don't 

Frequent /week /month /quarter /year often know 

Type of 

Incident 

R&D synthesis laboratories 

R&D laboratories using carbon, hydrogen, 

iodine, phosphorus, and sulfur 

in vitro laboratory testing 

10 CFR 35.100 - nuclear medicine and human 

use research 

10 CFR 35.200 - nuclear medicine with 

generator(s) 

10 CFR 35.200 - nuclear medicine without a 

generator 

10 CFR 35.300 - nuclear medicine 

brachytherapy - using seeds 

brachytherapy - manual afterloading 

brachytherapy - low dose rate remote 

afterloading 

brachytherapy - high dose rate remote 

aftertoading 

brachytherapy - eye applicator 

10 CFR 35.400 - diagnostic devices 

teletherapy devices 

gamma stereotactic surgery 

nuclear pharmacies 

veterinary use 

R&D on animals 

well logging - tracers and field flood studies 

well logging - using sealed sources 

radiography - permanent installation 

radiography -field use 

pool irradiators 

self-shielded irradiators

A-10

1 1
APPENDIX A

A-I I

Operation Most I time I time 1 time I time less don't 

Frequent Iweek /month /quarter /year often know 

Type of 

Incident 

fixed gauges - gamma emitters 

fixed gauges - beta emitters 

portable gauges 

x-ray fluorescence devices 

gas chromatographs 

other measuring devices 

small sealed sources or devices (e.g. those 

used under a general license) 

very small sealed sources or devices 

(e.g., those used under an exemption) 

manufacturing or distribution of devices 

containing sealed sources 

manufacturing of radioactive solids 

manufacturing of radioactive liquids 

manufacturing of radioactive gases 

incineration of waste 

compacting of waste 

packaging of waste 

solidification of waste 

other Part 30 operation 

(describe each):
APPENDIX A

3. Based on your experience, indicate what you believe to be the radiological safety of each 

type of operation listed below under normal operating conditions and current 

regulations and policies for licensing and inspection. Mark an X in the column that is your 

best estimate. Mark an X in the "don't know" column if you're unfamiliar with the 

operation. 

Operation very safe somewhat somewhat very don't 

safe unsafe unsafe know 

R&D synthesis laboratories 

R&D laboratories using carbon, hydrogen, iodine, 

phosphorus, and sulfur 

in vitro laboratory testing 

10 CFR 35.100 - nuclear medicine and human use research 

10 CFR 35.200 - nuclear medicine with generator(s) 

10 CFR 35.200 - nuclear medicine without a generator 

10 CFR 35.300 - nuclear medicine 

brachytherapy - using seeds 

brachytherapy - manual afterloading 

brachytherapy - low dose rate remote afterloading 

brachytherapy - high dose rate remote afterloading 

brachytherapy - eye applicator 

10 CFR 35.400 - diagnostic devices 

teletherapy devices 

gamma stereotactic surgery 

nuclear pharmacies 

veterinary use 

R&D on animals 

well logging - tracers and field flood studies 

well logging - using sealed sources 

radiography - permanent installation 

radiography - field use 

pool irradiators 

self-shielded irradiators 

fixed gauges - gamma emitters 

fixed gauges - beta emitters 

portable gauges 

x-ray fluorescence devices 

gas chromatographs

A-12

I 1
"APPENDIX A

Operation very safe somewhat somewhat very don't. 

safe unsafe unsafe know 

other measuring devices 

small sealed sources or devices (e.g. those used under a 

general license) 

very small sealed sources or devices (e.g., those used 

under an exemption) 

manufacturing or distribution of devices containing sealed 

sources 

manufacturing of radioactive solids 

manufacturing of radioactive liquids 

manufacturing of radioactive gases 

incineration of waste 

compacting of waste 

packaging of waste 

solidification of waste 

other Part 30 operation (describe each):

A-13
APPENDIX A

4. Based on your experience, indicate what you believe to be the radiological safety of each 

type of operation listed below under off-normal operating conditions (e.g., incidents, 

accidents, failure of administrative controls) and current regulations and policies for 

licensing and inspection. Mark an X in the column that is your best estimate. Mark an X 

in the "don't know" column if you're unfamiliar with the operation. 

Operation very safe somewhat somewhat very don't 

safe unsafe unsafe know 

R&D synthesis laboratories 

R&D laboratories using carbon, hydrogen, iodine, 

phosphorus, and sulfur 

in vitro laboratory testing 

10 CFR 35.100 - nuclear medicine and human use research 

10 CFR 35.200 - nuclear medicine with generator(s) 

10 CFR 35.200 - nuclear medicine without a generator 

10 CFR 35.300 - nuclear medicine 

brachytherapy - using seeds 

brachytherapy - manual afterloading 

brachytherapy - low dose rate remote afterloading 

brachytherapy - high dose rate remote afterloading 

brachytherapy - eye applicator 

10 CFR 35.400 - diagnostic devices 

teletherapy devices 

gamma stereotactic surgery 

nuclear pharmacies 

veterinary use 

R&D on animals 

well logging - tracers and field flood studies 

well logging - using sealed sources 

radiography - permanent installation 

radiography - field use 

pool irradiators 

self-shielded irradiators 

fixed gauges - gamma emitters 

fixed gauges - beta emitters 

portable gauges 

x-ray fluorescence devices 

gas chromatographs

A- 14

1 1
APPENDIX A

Operation very safe somewhat somewhat very don't 

safe unsafe unsafe know 

other measuring devices 

small sealed sources or devices (e.g. those used under a general license) 

very small sealed sources or devices (e.g., those used 

under an exemption) 

manufacturing or distribution of devices containing sealed sources 

manufacturing of radioactive solids 

manufacturing of radioactive liquids 

manufacturing of radioactive gases 

incineration of waste 

compacting of waste 

packaging of waste 

solidification of waste 

other Part 30 operation (describe each):

A-15
APPENDIX A

5. Based on your experience, indicate what you believe to be the radiological safety of each 

type of operation listed below under normal operating conditions, but without current 

regulations and policies for licensing and inspection. Mark an X in the column that is your 

best estimate. Mark an X in the "don't know" column if you're unfamiliar with the 

operation. 

Operation very safe somewhat somewhat very don't 

safe unsafe unsafe know 

R&D synthesis laboratories 

R&D laboratories using carbon, hydrogen, iodine, 

phosphorus, and sulfur 

in vitro laboratory testing 

10 CFR 35.100 - nuclear medicine and human use research 

10 CFR 35.200 - nuclear medicine with generator(s) 

10 CFR 35.200 - nuclear medicine without a generator 

10 CFR 35.300 - nuclear medicine 

brachytherapy - using seeds 

brachytherapy - manual afterloading 

brachytherapy - low dose rate remote afterloading 

brachytherapy - high dose rate remote afterloading 

brachytherapy - eye applicator 

10 CFR 35.400 - diagnostic devices 

teletherapy devices 

gamma stereotactic surgery 

nuclear pharmacies 

veterinary use 

R&D on animals 

well logging - tracers and field flood studies 

well logging - using sealed sources 

radiography - permanent installation 

radiography - field use 

pool irradiators 

self-shielded irradiators 

fixed gauges - gamma emitters 

fixed gauges - beta emitters 

portable gauges 

x-ray fluorescence devices 

gas chromatographs

A-16
APPENDIX A

Operation very safe somewhat somewhat very don't 

safe unsafe unsafe know 

other measuring devices 

small sealed sources or devices (e.g. those used under a general license) 

very small sealed sources or devices (e.g., those used 

under an exemption) 

manufacturing or distribution of devices containing sealed 

sources 

manufacturing of radioactive solids 

manufacturing of radioactive liquids 

manufacturing of radioactive gases 

incineration of waste 

compacting of waste 

packaging of waste 

solidification of waste 

other Part 30 operation (describe each):

A-17
APPENDIX A

6. Based on your experience, indicate what you believe to be the radiological safety of each 

type of operation listed below under off-normal operating conditions (e.g., incidents, 

accidents, failure of administrative controls) but without current regulations and policies 

for licensing and inspection. Mark an X in the column that is your best estimate. Mark an 

X in the "don't know" column if you're unfamiliar with the operation. 

Operation very safe somewhat somewhat very don't 

safe unsafe unsafe know 

R&D synthesis laboratories 

R&D laboratories using carbon, hydrogen, iodine, 

phosphorus, and sulfur 

in vitro laboratory testing 

10 CFR 35.100 - nuclear medicine and human use research 

10 CFR 35.200 - nuclear medicine with generator(s) 

10 CFR 35.200 - nuclear medicine without a generator 

10 CFR 35.300 - nuclear medicine 

brachytherapy - using seeds 

brachytherapy - manual afterloading 

brachytherapy - low dose rate remote afterloading 

brachytherapy - high dose rate remote afterdoading 

brachytherapy - eye applicator 

10 CFR 35.400 - diagnostic devices 

teletherapy devices 

gamma stereotactic surgery 

nuclear pharmacies 

veterinary use 

R&D on animals 

well logging - tracers and field flood studies 

well logging - using sealed sources 

radiography - permanent installation 

radiography - field use 

pool irradiators 

self-shielded irradiators 

fixed gauges - gamma emitters 

fixed gauges - beta emitters 

portable gauges 

x-ray fluorescence devices 

gas chromatographs

A-18
APPENDIX A

A-19

Operation 

other measuring devices 

small sealed sources or devices (e.g. those used under a general license) 

very small sealed sources or devices (e.g., those used 

under an exemption) 

manufacturing or distribution of devices containing sealed sources 

manufacturing of radioactive solids 

manufacturing of radioactive liquids 

manufacturing of radioactive gases 

incineration of waste 

compacting of waste 

packaging of waste 

solidification of waste 

other Part 30 operation (describe each):
APPENDIX A 

7. Describe your criteria for the following terms as used in the above questions: 

a. "very safe" 

b. "somewhat safe" 

c. "somewhat unsafe" 

d. "very unsafe"

A-20
APPENDIX A

Section 2 - Questions Concerning Specific Operations 

8. Questions 8.1 through 8.4 pertain to gamma emitting byproduct material in fixed gauges and small calibrators. If you are not familiar with the use of these types of devices, mark 

an X in the box below and skip to question 9. 

0 Not familiar 

8.1 The following table lists isotopes and ranges of quantities that might be used in fixed 

gamma gauges and small calibrators. Please mark an X in the appropriate column indicating whether, based on your knowledge, you agree or disagree that the information 

is correct. If you disagree, please indicate why in the comment area. If you believe 

additional isotopes should be considered, please add them to the table with their 

appropriate quantity range. 

Isotope Range of Agree Disagree Comment 

Quantity 

Am-241 12 mCi to 6 Ci 

Ba-133 10 mCi to 125 mCi 

Cd-109 50 mCi to 300 mCi 

Co-60 30 /Ci to 100 Ci 

Cs-137 10/.Ci to 110 Ci 

Fe-55 2 mCi to 350 mCi 

8.2 Please rate the importance of the following barriers to worker and public dose as they apply to fixed gamma gauges and small calibrators (I is the most important and 4 is the 

least important). 

Barrier Rating 

Training, knowledge, and experience of personnel in radiation safety principles. 

Training, knowledge, and experience of personnel in handling and use of the gauge or 

calibrator. 

Limits on the quantity of byproduct material that is incorporated in gauges and calibrators. 

Inherent safety features in the design of the gauges or calibrators. 

Typical installation of gauges in locations that are not usually accessible to workers or the 

public. 

8.3 Many licensees implement "good practices" when using and handling byproduct material. "Good practices" are actions that are not specifically required by the regulations but may

A-21
APPENDIX A

be included as license conditions or performed voluntarily to reduce exposures or the 

likelihood of accidents. Based on your experience, indicate the percentage (0 to 100) of 

all users of fixed gamma gauges and small calibrators that you believe follow the "good 

practices" indicated below. Mark every box. Use an X if you are unsure of a percentage. 

Good Practice Percentage 

Posting signs indicating the presence of radioactive material and advising people not to 

frequent the area. 

Restricting access to the gauge or calibrator by use of locks or other physical barriers. 

Training workers in the importance of appropriate handling of the gauge or calibrator. 

Auditing workers and operations to ensure activities are carried out in an appropriate 

manner. 

Performing periodic inventories to verify accountability of the gauge or calibrator. 

Other (please specify): 

8.4 Please rate the importance of the following regulatory controls as they are, or could be, 

used to regulate fixed gamma gauges and small calibrators. Consider exposures during 

normal operations, incidents (including both the probability of occurrence and 

consequences of those incidents), and costs of regulation to NRC/Agreement States and 

licensees in your rating (1 is the most important and 4 is the least important).

Regulatory Controls

Preapproval review of licensee's knowledge and training and experience of personnel.

Preapproval of licensee's radiation safety program.

Preapproval of procedures for the safe use of the material.

Preapproval of facilities and operations.

Preapproval of the equipment (sealed sources and devices) used during operations.

On-site inspections of the licensees facility and operations to verify safety and compliance 

at the following frequency (mark your recommended frequency below and rate the 

importance of your selection in the box at the right):

o every year o every 2 years o every 3 years o every 5 years

A-22

I I U ý_l kopu
APPENDIX A

Regulatory Controls Rating 

Mail or telephone inspections to verify safety and compliance at the following frequency (mark your recommended frequency below and rate the importance of your selection in 

the box at the right): 

n every year o every 2 years o every 3 years o every 5 years 

o other (specify): 

Periodic on-site inspections to verify accountability of radioactive material at the following frequency (mark your recommended frequency below and rate the importance of your selection in the box at the right): 

o every year o every 2 years o every 3 years o every 5 years 

o other (specify): 

Periodic mail inspections to verify accountability of radioactive material at the following frequency (mark your recommended frequency below and rate the importance of your selection in the box at the right): 

0 every year o every 2 years o every 3 years o every 5 years 

o other (specify): 

Periodic telephone inspections verify accountability of radioactive material at the following frequency (mark your recommended frequency below and rate the importance of your selection in the box at the right): 

O every year o every 2 years o every 3 years o every 5 years 

o other (specify): 

NRC/Agreement State maintenance of an independent inventory on-site inspections of users' material and NRC/Agreement State cross check of the 

inventory with users by performing periodic (rate each selection mail inspections in the box to if's right): telephone inspections 

Vendor maintenance of an independent inventory of users' on-site inspections material and vendor cross check of the inventory with users by mail inspections performing periodic (rate each selection in the box to if's right): rmailinspections 

telephone inspections 

No regulatory controls should be placed on fixed gamma gauges and small calibrators. 

Other (please specify):

A-23
APPENDIX A

9. Questions 9.1 through 9.4 pertain to byproduct material in portable gauges. If you are not 

familiar with the use of these types of devices, mark an X in the box below and skip to 

question 10. 

El Not familiar 

9.1 The following table lists isotopes that might be used in portable gauges. Please indicate 

what you believe to be the typical quantity, or range of quantities, of each used in 

portable gauges. If, based on your experience, you disagree that a particular isotope is 

actually used in portable gauges, mark an X in the "disagree" column and indicate why in 

the comment area. If you believe additional isotopes should be considered, please add 

them to the table with their appropriate quantity or range of quantities. 

Isotope Typical Disagree Comment 

Quantity 

Am-241 

Ba-133 

Cd-109 

Co-60 

Cs-137 

Fe-55 

Gd-153 

1-125 

9.2 Please rate the importance of the following barriers to worker and public dose as they 

apply to portable gauges (1 is the most important and 4 is the least important). 

Barrier Rating 

Training, knowledge, and experience of personnel in radiation safety principles. 

Training, knowledge, and experience of personnel in handling and use of the portable 

gauge. 

Limits on the quantity of byproduct material that is incorporated in portable gauges. 

Inherent safety features in the design of portable gauges. 

Securing of portable gauges in locked areas when not in use or maintaining constant 

surveillance of portable gauges. 

9.3 Many licensees implement "good practices" when using and handling byproduct material. 

"Good practices" are actions that are not specifically required by the regulations but may

A-24
APPENDIX A

be included as license conditions or performed voluntarily to reduce exposures or the 

likelihood of accidents. Based on your experience, indicate the percentage (0 to 100) of 

all users of portable gauges that you believe implement the "good practices" indicated 

below. Mark every box. Use an X if you are unsure of a percentage. 

Good Practice Percentage 

Posting signs indicating the presence of radioactive material and advising people not to 

frequent the area. 

Restricting access to the portable gauge by use of locks or other physical barriers. 

Training workers in the importance of appropriate handling of the portable gauge. 

Auditing workers and operations to ensure activities are carried out in an appropriate 

manner. 

Performing periodic inventories to verify accountability of the portable gauge. 

Other (please specify): 

9.4 Please rate the importance of the following regulatory controls as they are, or could be, 

used to regulate portable gauges. Consider exposures during normal operations, incidents 

(including both the probability of occurrence and consequences of those incidents), and 

costs of regulation to NRC/Agreement States and licensees in your rating (1 is the most 

important and 4 is the least important). 

Regulatory Controls Rating 

Preapproval review of licensee's knowledge and training and experience of personnel. 

Preapproval of licensee's radiation safety program. 

Preapproval of procedures for the safe use of the material. 

Preapproval of facilities and operations.. 

Preapproval of the equipment (sealed sources and devices) used during operations. 

On-site inspections of the licensees facility and operations to verify safety and compliance 

at the following frequency (mark your recommended frequency below and rate the 

importance of your selection in the box at the right): 

o every year 0 every 2 years 0. every 3 years 0 every 5 years 

0 other (specify):

A-25
APPENDIX A

Regulatory Controls Rating 

Mail or telephone inspections to verify safety and compliance at the following frequency 

(mark your recommended frequency below and rate the importance of your selection in 

the box at the right): 

o every year o every 2 years o every 3 years o every 5 years 

o other (specify): 

Periodic on-site inspections to verify accountability of radioactive material at the following 

frequency (mark your recommended frequency below and rate the importance of your 

selection in the box at the right): 

o every year o every 2 years o every 3 years o every 5 years 

o other (specify): 

Periodic mail inspections to verify accountability of radioactive material at the following 

frequency (mark your recommended frequency below and rate the importance of your 

selection in the box at the right): 

0 every year o every 2 years o every 3 years o every 5 years 

0 other (specify): 

Periodic telephone inspections to verify accountability of radioactive material at the 

following frequency (mark your recommended frequency below and rate the importance of 

your selection in the box at the right): 

o every year o every 2 years o every 3 years n every 5 years 

o other (specify): 

NRC/Agreement State maintenance of an independent inventory on-site inspections 

of users' material and NRC/Agreement State cross check of the 

inventory with users by performing periodic (rate each selection 

in the box to it's right): telephone inspections 

Vendor maintenance of an independent inventory of usersý on-site inspections 

material and vendor cross check of the inventory with users by mail inspections 

performing periodic (rate each selection in the box to it's right): maiispcton 

telephone inspections 

No regulatory controls should be placed on portable gauges. 

Other (please specify):

A-26

1 1
APPENDIX A 

10. Questions 10.1 through 10.4 pertain to laboratory operations using unsealed byproduct material. If you are not familiar with such operations, mark an X in the box below and 

skip to question 11. 

o Not familiar. 

10.1 The following table lists isotopes and typical quantities that might be used in laboratory operations using unsealed byproduct material. Please mark an X in the appropriate column indicating whether, based on your knowledge, you agree or disagree that the information is correct. If you disagree, please indicate why in the comment area. If you believe additional isotopes should be considered, please add them to the table with their 

appropriate quantity. 

Isotope Typical Agree Disagree Comment 

Quantity 

C-14 5 mCi 

Ca-45 1 mCi 

Cr-51 10 mCi 

Fe-59 1 mCi 

H-3 25 mCi 

1-125 10 mCi 

P-32 10 mCi 

P-33 10 mCi 

S-35 15 mCi 

10.2 Please rate the importance of the following barriers to worker and public dose as they apply to laboratory operations using unsealed materials (1 is the most important and 4 is 

the least important). 

Barrier Rating Training, knowledge, and experience of personnel in radiation safety principals. 

Training, knowledge, and experience of personnel in handling and use of unsealed 

radioactive materials in a laboratory setting. 

Most laboratory use of unsealed byproduct material is with low-energy beta-emitters such 

as C-14, H-3, P-32, and S-35, and sometime other radionuclides, which are easily shielded. 

Most laboratory use of unsealed byproduct material involves small quantities (microcuries to a few millicuries) that is usually in a non-volatile form. 

A-27
APPENDIX A

10.3 Many licensees implement "good practices" when using and handling byproduct material. 

"Good practices" are actions that are not specifically required by the regulations but may 

be included as license conditions or performed voluntarily to reduce exposures or the 

likelihood of accidents. Based on your experience, indicate the percentage (0 to 100) of 

all persons performing laboratory operations using unsealed material that you believe 

implement the "good practices" indicated below. Mark every box. Use an X if unsure of 

a percentage. 

Good Practice Percentage 

Wearing protective gloves, laboratory coats, or other protective clothing. 

Using shielding (e.g., around stock vials and storage areas, portable shields in work 

areas). 

Using hoods or glove boxes if potentially volatile materials are handled. 

Perform surveys for radiation and contamination after each use or the end of each day of 

use. 

Maintaining an inventory of unsealed byproduct material in the laboratory. 

Auditing work areas and maintenance of records by Radiation Safety Officer or 

management. 

Other (please specify): 

10.4 Please rate the importance of the following regulatory controls as they are, or could be, 

used to regulate laboratory operations using unsealed material. Consider exposures 

during normal operations, incidents (including both the probability of occurrence and 

consequences of those incidents), and costs of regulation to NRC/Agreement States and 

licensees in your rating (1 is the most important and 4 is the least important). 

Regulatory Controls Rating 

Preapproval review of licensee's knowledge and training and experience of personnel. 

Preapproval of licensee's radiation safety program. 

Preapproval of procedures for the safe use of the material. 

Preapproval of facilities and operations.

A-28

Persons handling unsealed byproduct material in laboratories usually wear protective 

gloves and laboratory coats. 

Access to the unsealed byproduct material is controlled by physical security, or by 

maintaining visual oversight.
APPENDIX A

Regulatory Controls Rating 

Preapproval of the equipment (sealed sources and devices) used during operations. 

On-site inspections of the licensees facility and operations to verify safety and compliance 

at the following frequency (mark your recommended frequency below and rate the 

importance of your selection in the box at the right): 

o every year 0 every 2 years 0 every 3 years o every 5 years 

o other (specify): 

Mail or telephone inspections to verify safety and compliance at the following frequency 

(mark your recommended frequency below and rate the importance of your selection in 

the box at the right): 

o every year 0 every 2 years on every 3 years 0 every 5 years 

on other (specify): 

Periodic on-site inspections to verify the persons' accountability of radioactive material at 

the following frequency (mark your recommended frequency below and rate the 

importance of your selection in the box at the right): 

o every year 0n every 2 years [] every 3 years on every 5 years 

on other (specify): 

Periodic mail inspections to verify the persons' accountability of radioactive material at the 

following frequency (mark your recommended frequency below and rate the importance of 

your selection in the box at the right): 

o] every year on every 2 years [] every 3 years on every 5 years 

o] other (specify): 

Periodic telephone inspections to verify accountability of radioactive material at the 

following frequency (mark your recommended frequency below and rate the importance of 

your selection in the box at the right): 

"[] every year on every 2 years on every 3 years -n every 5 years 

"o other. (specify): 

NRC/Agreement States maintenance of an independent inventory on-site inspections 

of the users' material and NRC/Agreement State cross check of 

the inventory with users by performing periodic (rate each mail inspections 

selection in the box to it's right): telephone inspections 

Vendor maintenance of an independent inventory of the users' on-site inspections 

material and the vendor cross check of the inventory with users 

by performinq periodic (rate each selection in the box to it's right): mail inspections

A-29
APPENDIX A

Regulatory Controls Rating 

telephone inspections 

No regulatory controls should be placed on laboratory operations using unsealed material. 

Other (please specify): 

11. Questions 11.1 through 11.4 pertain to packaging byproduct material waste. If you are 

not familiar with such operations, mark an X in the box below and skip to question 12. 

E] Not familiar. 

11.1 The following table lists isotopes that might be involved in packaging byproduct material 

waste. Please indicate what you believe to be the typical quantity of each in the 

packaging of byproduct material waste. If, based on your experience, you disagree that a 

particular isotope is actually involved in the packaging of byproduct material waste, 

mark an X in the "disagree" column and indicate why in the comment area. If you 

believe additional isotopes should be considered, please add them to the table with their 

appropriate quantity. 

Isotope Typical Disagree Comment 

Quantity 

Ac-225 

Ag-11Om 

Am-241 

Au-1 95 

Ba-133 

Ba-140 

C-14 

Ca-45 

Cd-109 

Cf-252 

Ce-141 

Ce-14 

CI-36 

Co-58

A-30

1 1
APPENDIX A

Isotope Typical Disagree Comment 

Quantity 

Co-60 

Cr-51 

Cs-1 34 

Cs-137 

Eu-152 

Fe-55 

Fe-59 

Gd-153 

H-3 

1-125 

1-129 

1-131 

Ir-192 

Kr-85 

La-140 

Mn-54 

Nb-95 

Ni-59 

Ni-63 

P-32 

P-33 

Pa-234 

Pb-210 

Pm-147 

Po-21 0 

Rb-86 

Ru-1 03 

Ru-106 

S-35 

Sb-124

A-31
APPENDIX A

Isotope. Typical Disagree Comment 

Quantity 

Sb-125 

Sc-46 

Se-75 

Sn-113 

Sr-85 

Sr-89 

Sr-90 

Tc-99 

Tc-99m 

TI-204 

Xe-131m 

Xe- 133 

Y-90 

Zn-65 

Zr-95 

11.2 Please rate the importance of the following barriers to worker and public dose as they 

apply to packaging byproduct material waste (1 is the most important and 4 is the least 

important). 

Barrier Rating 

Training, knowledge, and experience of personnel in radiation safety principals. 

Limiting operations to sealed sources. 

Limiting operations to small quantities of byproduct material. 

Wearing protective gloves and other types of protective clothing when handling unsealed 

byproduct material. 

Controlling access to byproduct material through physical security or by maintaining visual 

oversight. 

11.3 Many licensees implement "good practices" when using and handling byproduct material. 

"Good practices" are actions that are not specifically required by the regulations but may 

be included as license conditions or performed voluntarily to reduce exposures or the 

likelihood of accidents. Based on your experience, indicate the percentage (0 to 100) of 

A-32

1 1
APPENDIX A

all packagers of byproduct material waste that you believe implement the "good practices" indicated below. Mark every box. Use an X if unsure of a percentage. 

Good Practice Percentage 

Wearing protective gloves or other protective clothing. 

.Using shielding (e.g., around stock vials and storage areas, portable shields in work 

areas). 

Using hoods or glove boxes if potentially volatile materials are handled. 

Performing surveys for radiation and contamination after handling unsealed material or at 

the end of each work day. 

Performing periodic inventories of all byproduct material at the facility. 

Auditing work areas and maintenance of records by Radiation Safety Officer or 

management. 

Other (please specify): 

11.4 Please rate the importance of the following regulatory controls as they are, or could be, used to regulate packaging byproduct material waste. Consider exposures during normal 

operations, incidents (including both the probability of occurrence and consequences of 

those incidents), and costs of regulation to NRC/Agreement States and licensees in your rating. (1 is the most important and 4 is the least important). 

Regulatory Controls Rating 

Preapproval review of licensee's knowledge and training and experience of personnel. 

Preapproval of licensee's radiation safety program. 

Preapproval of procedures for the safe use of the material. 

Preapproval of facilities and operations. 

Preapproval of the equipment (sealed sources and devices) used during operations. 

On-site inspections of the licensees facility and operations to verify safety and compliance at the following frequency (mark your recommended frequency below and rate the importance of your selection in the box at the right): 

o every year o every 2 years o every 3 years o every 5 years 

o other (specify):

A-33
APPENDIX A

Mail or telephone inspections to verify safety and compliance at the following frequency 

(mark your recommended frequency below and rate the impoftance of your selection in 

the box at the right): 

o every year o every 2 years oi every 3 years ci every 5 years 

o other (specify): 

Periodic on-site inspections to verify the persons' accountability of radioactive material at 

the following frequency (mark your recommended frequency below and rate the 

importance of your selection in the box at the right): 

"o every year o every 2 years [] every 3 years [] every 5 years 

"o other (specify): 

Periodic mail inspections to verify the persons' accountability of radioactive material at the 

following frequency (mark your recommended frequency below and rate the importance of 

your selection in the box at the right): 

"o every year oi every 2 years [] every 3 years oi every 5 years 

"o other (specify): 

Periodic telephone inspections to verify the persons' accountability of radioactive material 

at the following frequency (mark your recommended frequency below and rate the 

importance of your selection in the box at the right): 

"o every year o] every 2 years [] every 3 years oi every 5 years 

"o other (specify): 

NRC/Agreement State maintenance of an independent inventory on-site inspections 

of users' material and NRC/Agreement State cross check of the 

inventory with users by performing periodic (rate each selection mail inspections 

in the box to it's right): telephone inspections 

Vendor maintenance of an independent inventory of the users' on-site inspections 

material and vendor cross check of the inventory with users by mail inspections 

performing periodic (rate each selection in the box to it's right): 

telephone inspections 

No regulatory controls should be placed on packaging byproduct material waste. 

Other (please specify): 

12. Questions 12.1 through 12.4 pertain to use of byproduct material in a nuclear medicine 

department. If you are not familiar with such operations, mark an X in the box below and 

skip to question 13. 

A-34

1 1
APPENDIX A

0 Not familiar. 

12.1 The following table lists isotopes and typical quantities that might be used in a nuclear 

medicine department. Please mark an X in the appropriate column indicating whether, based on your knowledge, you agree or disagree that the information is correct. If you disagree, please indicate why in the comment area. In cases where a quantity is not 

stated, please indicate what you believe to be the typical quantity used in a nuclear 

medicine department. If you believe additional isotopes should be considered, please add 

them to the table with their appropriate quantity. 

Isotope Range of Agree Disagree Comment 

Quantity 

Au-198 100 to 140 mCi 

Dy-165 

Er-169 

Ho-166 

1-131 3 to 300 mCi 

Mo-99 2 Ci 

P-32 2.3 to 22.3 mCi 

Pd-1 09 

Re-1 86 25 to 35 rnCi 

Sm-153 

Sn-1 17m 

Sr-89 1 to 10.8 mCi 

Tc-99m 50 mCi to 2 Ci 

Xe-133 10 to 100 mCi 

Y-90 

12.2 Please rate the importance of the following barriers to worker and public dose as they apply to use of byproduct material in a nuclear medicine department (1 is the most 

important and 4 is the. least important). 

Barrier Rating 

Training, knowledge, and experience of personnel in radiation safety principals.

A-35
APPENDIX A

Training, knowledge, and experience of personnel in handling and use of byproduct 

material in a nuclear medicine department that may include use of a generator. 

Most byproduct material used in a nuclear medicine department that may include use of a 

generator have short half-lives. 

Most byproduct material, used in a nuclear medicine department that may include use of 

a generator is in a non-volatile form, in quantities ranging.from microcuries to tens of 

millicuries. 

Persons handling byproduct material in a nuclear medicine department that may include 

use of a generator usually wear protective gloves and laboratory coats. 

Access to the byproduct material in a nuclear medicine department that may include use 

of a generator is controlled by physical security, or by maintaining visual oversight. 

12.3 Many licensees implement "good practices" when using and handling byproduct material. 

"Good practices" are actions that are not specifically required by the regulations but may 

be included as license conditions or performed voluntarily to reduce exposures or the 

likelihood of accidents. Based on your experience, indicate the percentage (0 to 100) of 

all persons performing nuclear medicine operations that you believe implement the "good 

practices" indicated below. Mark-every box. Use an X if unsure of a percentage. 

Good Practice Percentage 

Wearing protective gloves, laboratory coats, or other protective clothing. 

Using shielding (syringe shields, L-blocks, etcetera). 

Using hoods or glove boxes if potentially volatile materials are handled. 

Using long-handled tools when handling large-activity vials. 

Performing surveys for radiation and contamination after each use or at the end of each 

day of use. 

Maintaining an inventory of byproduct material in the nuclear medicine department that 

may include use of a generator. 

Isolating injected patients from other patients and members of the public. 

Auditing work areas and maintenance of records by Radiation Safety Officer or 

management. 

Other (please specify): 

12.4 Please rate the importance of the following regulatory controls as they are, or could be, 

used to regulate nuclear medicine departments. Consider exposures during normal 

operations, incidents (including both the probability of occurrence and consequences of

A-36
APPENDIX A

those incidents), and costs of regulation to NRC/Agreement States and licensees in your rating (1 is the most important and 4 is the least important). 

Regulatory Controls Rating 

Preapproval review of licensee's knowledge and training and experience of personnel. 

Preapproval of licensee's radiation safety program. 

Preapproval of procedures for the safe use of the material. 

Preapproval of facilities and operations. 

Preapproval of the equipment (sealed sources and devices) used during operations. 

On-site inspections of the licensees facility and operations to verify safety and compliance at the following frequency (mark your recommended frequency below and rate the importance of your selection in the box at the right): 

o every year o every 2 years 0 every 3 years o every 5 years 

o other (specify): 

Mail or telephone inspections to verify safety and compliance at the following frequency (mark your recommended frequency below and rate the importance of your selection in 

the box at the right): 

o every year o every 2 years o every 3 years 0 every 5 years 

0 other (specify): 

Periodic on-site inspections to verify the person's accountability of radioactive material at the following frequency (mark your recommended frequency below and rate the importance of your selection in the box at the right): 

o every year o every 2 years o every 3 years o every 5 years 

o other (specify): 

Periodic mail inspections to verify the persons' accountability of radioactive material at the following frequency (mark your recommended frequency below and rate the importance of 

your selection in the box at the right): 

o every year o every 2 years o every 3 years o every 5 years 

o other (specify): 

Periodic telephone inspections to verify the persons' accountability of radioactive material 

at the following frequency (mark your recommended frequency below and rate the importance of your selection in -the box at the right): 

o every year o every 2 years o every 3 years o every 5 years 

o other (specify):

A-37
APPENDIX A

Regulatory Controls Rating 

NRC/Agreement State maintenance of an independent inventory on-site inspections 

of users' material and NRC/Agreement State cross check of the 

inventory with users by performing periodic (rate each selection mail inspections 

in the box to it's right): telephone inspections 

Vendor maintenance of an independent inventory of users' on-site inspections 

material and vendor cross check of the inventory with users by 

performing periodic (rate each selection in the box to it's right): mail inspections 

telephone inspections 

No regulatory controls should be placed on nuclear medicine departments that may 

include use of a generator. 

Other (please specify): 

13. Questions 13.1 through 13.4 pertain to manufacturers or distributors of gaseous sources 

containing byproduct material. If you are not familiar with such operations, mark an X in 

the box below and skip to question 14. 

0 Not familiar. 

13.1 The following table lists isotopes and typical quantities that might be used by 

manufacturers or distributors of gaseous sources containing byproduct material. Please 

mark an X in the appropriate column indicating whether, based on your knowledge, you 

agree or disagree that the information is correct. If you disagree, please indicate why in 

the comment area. In cases where a quantity is not stated, please indicate what you 

believe to be the typical quantity used by manufacturers/distributors of gaseous sources 

containing byproduct material. If you believe additional isotopes should be considered, 

please add them to the table with their appropriate quantity. 

Isotope Quantity Agree Disagree Comment 

Br-82 

H-3 1 to 25 Ci 

Kr-85 up to 

25/jCi 

Xe-133 

13.2 Please rate the importance of the following barriers to worker and public dose as they 

apply to manufacturers or distributors of gaseous sources (1 is the most important and 4 is 

the least important).

A-38
APPENDIX A

Barrier Rating 

Training, knowledge, and experience of personnel in radiation safety principals. 

Training, knowledge, and experience of personnel in manufacture of gaseous sources of 

byproduct material. 

Most manufacturers/distributors of gaseous sources of byproduct material handle H-3, a 

low-energy beta-emitter or noble gases such as Kr-85 and Xe-1 33. 

Using remote handling systems for transfer of gaseous byproduct material during the 

manufacture of gaseous sources of byproduct material. 

Air monitoring in facilities which manufacture gaseous sources of byproduct material. 

Controlling access to the byproduct material in a facility which manufactures gaseous 

sources of byproduct material by physical security, or by maintaining visual oversight. 

13.3 Many licensees implement "good practices" when using and handling byproduct material. 

"Good practices" are actions that are not specifically required by the regulations but may be included as license conditions or performed voluntarily to reduce exposures or the likelihood of accidents. Based on your experience, indicate the percentage (0 to 100) of all manufacturers or distributors of gaseous sources that you believe implement the "good practices" indicated below. Mark every box. Use an X if unsure of a percentage. 

Good Practice Percentage 

Wearing protective gloves, laboratory coats, or other protective clothing. 

Using shielding (e.g., around storage areas, or portable shields in work areas). 

Using hoods, glove boxes, hot cells, or other remote-handling systems during handling of 

gaseous byproduct material. 

Performing surveys for radiation and airborne byproduct material during each day of use. 

Maintaining an inventory of unsealed byproduct material in the laboratory. 

Auditing work areas and maintenance of records by Radiation Safety Officer or 

management.

A-39
13.4 Please rate the importance of the following regulatory controls as they are, or could be, 

used to regulate manufacturers or distributors of gaseous sources containing byproduct 

material. Consider exposures during normal operations, incidents (including both the 

probability of occurrence and consequences of those incidents), and costs of regulation to 

NRC/Agreement States and licensees in your rating. (1 is the most important and 4 is the 

least important). 

Regulatory Controls Rating 

Preapproval review of licensee's knowledge and training and experience of personnel. 

Preapproval of licensee's radiation safety program. 

Preapproval of procedures for the safe use of the material. 

Preapproval of facilities and operations. 

Preapproval of the equipment (sealed sources and devices) used during operations. 

On-site inspections of the licensees facility and operations to verify safety and compliance 

at the following frequency (mark your recommended frequency below and rate the 

importance of your selection in the box at the right): 

o every year o every 2 years o every 3 years o every 5 years 

O other (specify): 

Mail or telephone inspections to verify safety and compliance at the following frequency 

(mark your recommended frequency below and rate the importance of your selection in 

the box at the right): 

o every year o every 2 years o every 3 years o every 5 years 

o other (specify): 

Periodic on-site inspections to verify the persons' accountability of radioactive material at 

the following frequency (mark your recommended frequency below and rate the 

importance of your selection in the box at the right): 

o every year o every 2 years o every 3 years o every 5 years 

0 other (specify):

A-40
APPENDIX A

Periodic mail inspections to verify the persons' accountability of radioactive material at the 

following frequency (mark your recommended frequency below and rate the importance of 

your selection in the box at the right): 

o every year o every 2 years o every 3 years o every 5 years 

0 other (specify): 

Periodic telephone inspections to verify the persons' accountability of radioactive material 

at the following frequency (mark your recommended frequency below and rate the 

importance of your selection in the box at the right): 

o every year o every 2 years o every 3 years 0 every 5 years 

o other (specify): 

NRC/Agreement State maintenance of an independent inventory on-site inspections of users' material and NRC/Agreement State cross check of the 

inventory with users by performing periodic (rate each selection mail inspections 

in the box to it's right): telephone inspections 

Vendor maintenance of an independent inventory of users' on-site inspections material and vendor cross check of the inventory with users by mail inspections performing periodic (rate each selection in the box to it's right): 

telephone inspections 

No regulatory controls should be placed manufacturers or distributors of gaseous sources. 

Other (please specify): 

Section 3 - Questions Concerning How You Think Regulatory Agencies Should Make 

Decisions 

14. Indicate what you believe is the level of importance of the factors that might be 

considered in regulating manufacturing, distribution, receipt, possession, use, handling, transfer, and disposal of radioactive materials. Rank each factor according to the 

following scale: 1 - very important; 2 - important; 3 - not important; 4 - should not be 

considered. Please list under "other" any additional factors that should be considered. 

Regulation of Persons Possessing Material Should Be Based On: Rating 

Consensus opinion of the public 

Financial burden of regulation to the licensee 

Financial -burden of regulation to the public 

Evaluation of radiological risk

A-41
APPENDIX A

Benefit of the use of material to society 

Other considerations (describe any other considerations): 

Section 4 - Information About Yourself 

The following information is optional, but your response would be helpful to the survey: 

15. My information regarding safe operations with radioactive materials is based on:

[] performing operations with radioactive materials 

El R&D/laboratory use 

El industrial use (gauges, radiography, etc.) 

El medical use 

El manufacturing 

El reactor (power or non-power) 

El Other (please specify):

years

El performing radiation safety oversight of operations by others years 

El R&D/laboratory use 

El industrial use (gauges, radiography, etc.) 

El medical use 

El manufacturing 

El reactor (power or non-power) 

El Other (please specify):

performing licensing of radioactive materials 

performing inspection of radioactive materials

years 

years

A-42

1 1

El 

El
APPENDIX A

El performing other regulatory review of radioactive materials 

use 

El formal education in health physics or radiation science 

Degree: BA/BS MA/MS 

El work-related training courses 

il1 Other (please specify):

years 

Ph.D.

A-43
Appendix B 

Correspondence Related to the 

Questionnaire
APPENDIX B

Correspondence Related to the Questionnaire 

Correspondence related to the Questionnaire appears on the following pages.

B-1
APPENDIX B

STATE 1 (W I'NNESSF.I

DEPARTMENT OF ENVIRONMENT AND CONSERVATION 

Division of Radiological Health 

3rd Floor. L & C Annex 

401 Church Street 

Nashville, TN 37243-1532 

615-532-0360 

INTERNET. mmobteW@mail.tat*M.t.b, 

August 14. 1998 

U.S. Nuclear Regulatory Commission 

ATTN: Dennis I. Serig 

Mail Stop T8F5 

Washington. D.C. 20555-0001 

Dear Mr. Serig: 

The survey contained in transmittal SP-98-065 was provided to members of our staff 

having experience in licensing and inspections. It is our feeling that a response to this 

survey will require a period of time significantly longer than the 1.5 to 3 hours of your 

estimation- by each respondent. Given the response time requested. sufficient time to 

formulate the response was not available. 

Among our concerns regarding any response to this is the necessity for each respondent to 

create individual definitions to terms such as "verv safe. somewhat safe.. .etc". How will 

the different definitions which will result be reconciled with one another? Also. it is 

almost certain that any response by each individual would be more appropriate, and 

considerably different, if given an opportunity for file review. There. again, time 

investment would be considerable. 

We must regretfully defer response to your survey at the present time. Hopefully. some of 

these issues can be resolved and another opportunity to participate provided. 

Sincerely. 

Michael H. Mobley 

Director

B-2
APPENDIX B

STATE OF NEW YORK 

DEPARTMENT OF LABOR 

DIVISION OF SAFETY AND HEALTH 

Radiological Heat Unit RO V 

Building #12, Room 134-A j.,. AnJs.5 

State Office Building Campus 

Albany, NY 12240 # 

August 24, 1998 

Mr. Paul Lohaus 

Deputy Director 

Office of State Programs 

United States Nuclear Regulatory Commission 

Washington, D.C. 20555 

Dear Mr. Lohaus: 

I have completed the survey referred to in your letter SP-98-065 and returned it to Dennis 

Serig. However, this survey instrument was seriously flawed and I do not see how the responses 

received could be used as indicated in your letter to capture the "corporate knowledge' of 

regulatory personnel. 

It is unclear what pieces of the data gathered through this survey will be treated as factual 

and what will be treated as opinion. Since participants were instructed not to review files or 

other sources, and not to consult with other staff, it would appear that all of the responses should 

be regarded as anecdotal. It is also apparent that responses should not be regarded as the 

professional opinions of the respondents, since they are responses to carefully framed questions 

with a limited choice of answers. 

I would be very interested in knowing how the survey responses will be used to "augment 

and confirm information provided by Scientech." What information has Scientech providedand 

how will responses to this survey augment or confirm them? 

-.5 

Sincerely, , -p 

Rita Aldrich 

Principal Radiophysicist 

RA:jmp 

Telephone: 518-457-1202 FAX- 518-485-7406 

. - A a- 4

B-3
APPENDIX B

iOe Ser°g -6- Page 1 

August 25, 1998 

TO: R. Bangart 

FROM: A. Godwin 

SUBJECT: Bias in the questionnaire (SP-98-065) 

I offer the following as comments indicating a possible biasing in the subject document. 

I. The context of the document is to better establish risk based regulations. The document 

appears to be poorly phrased. For example, question 4, does not clarify "off-normal." Does 

this mean, slightly delaying surveys or totally not doing surveys. The document attempts to 

correct this by letting the writer define "safe....etc." Even with the writer's definitions, the 

questioner cannot know what type of accident or "off-normal" condition was envisioned by 

the responder. Without that knowledge, the reviewer has to assume the conditions to match 

up the responses. Thus if one responder is envisioning an "off-normal" nuclear pharmacy 

condition as a failure to survey the sink one night. While the reviewer may be thinking of a 

leaking and contaminated shipment being made off-site. 

2. Even worse is question 6. The responses to this are pure speculation, since most regulators 

responding do not have any experience of how things would operate without regulations. A 

mere glance at the conditions exiting in x-ray departments prior to state regulation would 

show that one cannot adequately envision the possible problems. For example, we found 

fluoroscopic units with an output of> 30R/min. twenty years after the recommendation was 

to be less than 10 R/min. Because the regulations have existed, we do not have a concept of 

what conditions may occur if they did not exist. 

3. Questions 8.1 and 8.2 play against each other. Inherent safety features are very important 

around a 100 Ci cobalt 60 fixed gauge, yet not very important with a 30 microcurie one. 

4. Similarly, 8.1 verses 8.4, the quantity being considered radically changes the response. 

5. Questions 9.1, 9.2, 9.4, 10.1, 10.2, 10.4, 11.1, 11.2, and 11.4 are somewhat better in that the 

responder indicates what quantity to which they are responding. 

These are examples of what I felt were questions that could lead to some false conclusions be the 

reviewers. Since they were a significant portion of the total questionnaire, I would be concerned 

about the validity of the conclusions reached.

B-4
APPENDIX B

UNITE STATES NUCLEAR REGULATORY COMMISSION 

October 21, 1998 

Ms. Rita Aldrich, 

Radiological Heath UniC 

D0son of Safety and Health New York State Department of Labor State Office Building Campus Building 1Z Room 134A Albany, New York 12240 

Dear Ms. Adrich: 

This is in response to your letter of August 24, 1998, which referenced the risk review working group's nuclear byproduct material survey (SP-98.065, dated July 23, 1998). You asked what information NRC's contractor, Scientech, has provided and how the survey responses augments or confirms that information. Presently, NRC is awaiting receipt of Scientech's final report to which the survey results will be compared. 

As way of background, the survey of Licensing and inspection personnel was designed to assist the risk review working group in identifying and documenting a techical basis for a risk. informed approach to nuclear byproduct mateuria regulation and in development of plans for a graded approach to regulation Of such material based on risk information. The survey asked inspection and licensing personnel about typical doses, typical events and trequencies, perceptions of safety, materials and quantities tpical to various systems, the existence and 

value of various barriers to dose, and the value of particular regulatory options. Scientech's report will address most of those same areas. The working group received 41 responses to its survey of ficensing and inspection pemonel. Data from the responses have been entered into a spread sheet for analysis. The spread sheet was modified as data entry progressed in order to accommodate the fullest possible range of responses (e.g., to expand coding of data to 

include responses that were not consistent with instructions but that appeared to be useful). Comments that could not be entered 

analysis, were noted. 

into the spread sheet, but that could affect the data 

Based on the review to date, respondents appear to have provided informaton in which they 

had confidence, to admit that they were unfamirlar with some systems and that they cul not provide information about them with confidence, and to indicate when they belioved that response altematives were too limited. The review group believes that each individual respondent answers reflect their own professional opinions based on their experience in licensing andtor inspection (i.e., their exposure to facts). The review group does, however, recognize that some questions could not be answered solely on the basis of experience. Such situations vid be kept in mind dunng analysis of survey responses, The review group 

understands the limitations of the survey, but believes that there will be useful information that 

reflects the licensing and inspection community's informed opinions, knowledge. i.e., its corporate 

B-5

APPENDIX B
APPENDIX B

Ri Aldrich -2- &CT2 1 me 

The swavy is intended as only on of several sources of Information used to satisfy the working 

group's charter. Results wil be compared with contractor information about doses, events and 

frquewcies, materials and quantities. Pe more importantly; the informed opinions of 

licewing and inspection personnel about the existence and effectiveness of barriers to dose and 

te value of particular regulatory options wil be compared with contractor developed views on 

those same subjecL 

Should you have additonal comments or questions, please feel free to contact Denn= Seig at 

301-415-7901 or via e-mail at digtggL 

Paul H. Lohaus, Deputy Director 

Office of State Programs

B-6
Appendix C 

Responses to Comments on Draft 

NUREG-1712
APPENDIX C

Introduction 

NUREG-1712, "Results of Survey of NRC and Agreement State Materials Licensing and 

Inspection Personnel," was published for public comment on August 25, 1999 (64 FR 46456). 

In response to the request for comments, NRC received 4 comments, 3 from Agreement States, 

and 1 from a private company. All comments are available for review in the NRC Public 

Document Room. 

Comment: One commenter stated that much of the content is based on terminology or 

definitions that are very different from one participant to the next. This makes the specific 

results nebulous at best. The one thing of value is the table that "ranks the various systems. The 

commenter stated that the State will expend resources based more on state-specific or site 

specific criteria rather than a table reflecting an averaging of "best guesses," even if they are 

from experienced regulators. 

Response: The survey was intended to gather information from NRC and Agreement State 

materials licensing and inspection personnel concerning typical annual doses to workers for the 

various systems, safety of each system under various conditions, the types and frequencies of 

incidents occurring at each system, definitions of safety, and opinions about the appropriate 

bases for regulatory decision making. The NRC did not intend for the States to use the results in 

making decisions related to their programs. The staff reviewed the results in line with results of 

the nuclear byproduct material risk study, NUREG/CR-6642, "Risk Analysis and Evaluation of 

Regulatory Options for Nuclear Byproduct Material Systems," for comparison purposes. The 

staff recognizes the limitations of the survey, but believes that there is useful information that 

reflects informed opinions. 

Comment: The survey provides a good subjective summary of the most knowledgeable 

professionals' views as to the safety and the impact of NRC licensed activities. However, since 

safety was not predefined and allowed to reflect each respondents personal definition, the four 

categories of safety were arbitrary and of questionable value. 

Response: Again, the survey was intended to gather information on nuclear byproduct material 

systems obtained from other sources, specifically NRC and Agreement State materials licensing 

and inspection personnel. The survey was not intended to be an absolute scientific survey, but 

more a gathering of information from knowledgeable personnel. The results were also compared 

to the results of NUREG/CR-6642, but were not used in the preparation of the NUREG. 

Comment: A commenter from a private company providing nuclear laundry services provided 

additional information regarding the percentage of doses in 2 different dose categories. 

Response: Only regulatory personnel were included in this survey, and actual data from 

licensees was not solicited in the survey process. Although activities involving the use of 

byproduct material at nuclear laundries were not included in the original survey, one survey

C-I
APPENDIX C

respondent noted nuclear laundries as an activity which should be considered separately, and 

applied the survey questions to this activity. The information regarding nuclear laundries in this 

survey is based only on the information provided by that individual. The staff appreciates the 

effort of the private company to provide data from their activities as a nuclear laundry. 

Comment: The survey results compiled in NUREG-1712 are subjective and anecdotal opinions 

of survey respondents. The survey was poor designed, encouraged subjective opinion, and 

lacked definitions and explanations. The so-called "data" in NUREG-1712 cannot be viewed as 

objective, precise, or accurate. 

Response: Again, the survey was not intended to be a "hard" scientific survey. It was intended 

to gather information, which staff recognized would be subjective and based on opinion. The 

results of the survey were not used in NUREG/CR-6642. 

C-2

I I
NRC FORM 336 U.& NUCLEAR REGULATORY COMMISSION 1. REPORT NUMBER 

2 ,(Mmeigmi- by NRC, A•d VL., Sup, Rev. WM. 3 BIBUOGRAPHIC DATA SHEET a"l • "m•"• Van•.) •3eehu c• c oneremvet) 

2. TrrLE AND SBTffLEo NUREG-1712 

Nuclear Byproduct Material Risk Review 

Results of Survey of NRC and Agreement State Materials Licensing MONT YEAR 

and Inspection Personnel Aprl 200 

Final eport4. FIN OR GRANT N UMBER Final Report 

5. AUTHOR(S) 6. TYPE OF REPORT 

D. Serig, J. Lubinski, E. Ulrich, J. Randall, N. Daugherty* Final Report 

7. PERIOD COVERED (-nctuaAD.etw) 

8. PERFORMING ORGANIZATION - NAME AND ADDRESS (Y NRC, prowe ivax Oft~aoreRi U.S. NucterRegu/sabyCo-rnn •a- mWd, gad*s i 

P nne &-dm T adduesj 

Division of Industrial and Medical Nuclear Safety "State of Colorado 

Office of Nuclear Material Safety and Safeguards Department of Public Health and Environment 

Washington, 

U.S. Nuclear Regulatory Commission 8100 Lowry Boulevard DC 20555-0001 Denver, CO 80220-6928 

90 fWV.QfW1Ur_1i ^C -MKI -

and - ft g di .) , . = PW ADDRESS (ffN , yp "S a s above 1roradw, proie ARC Dvion afr orRein US NdawReuh C a on, 

Same as 8. above.

10. SUPPLELENTARY NOTES

11. ABSTRACT (200 words aes) 

This project responded to NRC's Direction Setting Issue 12, Risk-Informed, Performance-Based Regulation. Its scope was limited to nuclear byproduct materials as defined in Section 1 1.e(1) of the Atomic Energy Act of 1954 and Tilde 10 of the Code of Federal Regulations (CFR), Section 30.4. 10 CFR Parts 30 through 36 and 39 address regulation of those materials. The goal was to confirm and augment information on nuclear byproduct material systems obtained from other sources. The process involved (1) use of a list of nuclear byproduct material systems based on how the nuclear byproduct material was used, (2) a survey of NRC and Agreement State materials licensing and inspection personnel concerning typical annual doses to workers for the various systems, safety of each system under various conditions, the types and frequencies of incidents occurring at each system, definitions of safety, and opinions about the appropriate bases for regulatory decision making, and (3) summarization of the respondents answers to those questions.

12. KEY WORDSODESCRJPTORS (List words crpl s vth win assist reserchms in locating he reat) 13. AVAJRAUTY STATEMENT 

risk unlimited nuclear byproduct material risk study 14. SECURITY CLASSIFICATION byproduct materials, nuclear (Thi paw) nuclear byproduct materials unclassified risk assessment 

(isRaport risk informed unclassified materials licensees 

materials risk study 15. NUMBER OF PAGES 

16. PRICE 

NRC FORM 335 (2.4)

This form was 6eleronicaffi produced by Elie Federa Foirim, In.

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10. SUPPLEMEN;.TARY NOTES

I
In 

Jan recyIed¶ 

Federal Recycling Program