Consolidated Guidance 

About Materials Licenses

Program-Specific Guidance 

About Fixed Gauge Licenses

Final Report

Office of Nuclear Material Safety and Safeguards

NUREG-1556

Volume 4, Rev. 1 
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infringe privately owned rights.
Consolidated Guidance 

About Materials Licenses

Program-Specific Guidance 

About Fixed Gauge Licenses

Final Report

Manuscript Completed: May 2016 

Date Published: July 2016 

Prepared by: 

J. Cook

B. Juran

A. McCraw

M. Reichard

G. Rivera-Capella

Office of Nuclear Material Safety and Safeguards

 

NUREG-1556

Volume 4, Rev. 1 

iii

ABSTRACT

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

assist applicants and licensees in preparing applications for materials licenses for fixed gauges.

In particular, it describes the types of information needed to complete U.S. Nuclear Regulatory 

Commission (NRC) Form 313, “Application for Materials License.” This document describes 

both the methods acceptable to the NRC license reviewers in implementing the regulations and 

the techniques used by the reviewers in evaluating the application to determine whether the 

proposed activities are acceptable for licensing purposes.

Paperwork Reduction Act Statement

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

Reduction Act of 1995 (44 U.S.C. 3501 et seq.). These information collections were approved 

by the Office of Management and Budget (OMB), approval numbers 3150-0001, 3150-0008,

3150-0011, 3150-0014, 3150-0016, 3150-0017, 3150-0035, 3150-0044, 3150-0120, 3150-0151,

and 3150-0214.

Public Protection Notification 

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

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

currently valid OMB control number.

v

FOREWORD

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

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

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

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

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

personnel. The NUREG–1556 series currently includes the following volumes.

Volume No. Volume Title

1 Program-Specific Guidance About Portable Gauge Licenses

2 Program-Specific Guidance About Industrial Radiography Licenses

3 Applications for Sealed Source and Device Evaluation and Registration

4 Program-Specific Guidance About Fixed Gauge Licenses

5 Program-Specific Guidance About Self-Shielded Irradiator Licenses

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

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

Other Licenses of Limited Scope Including Electron Capture Devices and X-Ray 

Fluorescence Analyzers

8 Program-Specific Guidance About Exempt Distribution Licenses

9 Program-Specific Guidance About Medical Use Licenses

10 Program-Specific Guidance About Master Materials Licenses

11 Program-Specific Guidance About Licenses of Broad Scope

12 Program-Specific Guidance About Possession Licenses for Manufacturing 

and Distribution

13 Program-Specific Guidance About Commercial Radiopharmacy Licenses

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

Study Licenses

15 Guidance About Changes of Control and About Bankruptcy Involving 

Byproduct, Source, or Special Nuclear Materials Licenses

16 Program-Specific Guidance About Licenses Authorizing Distribution to 

General Licensees

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

Critical Mass Licenses

18 Program-Specific Guidance About Service Provider Licenses

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

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

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

Work in Agreement State Jurisdiction (Reciprocity)

20 Guidance About Administrative Licensing Procedures

21 Program-Specific Guidance About Possession Licenses for Production of 

Radioactive Material Using an Accelerator

The current document, NUREG–1556, Volume 4, Revision 1, “Consolidated Guidance About 

Materials Licenses: Program-Specific Guidance About Fixed Gauge Licenses,” is intended for 

use by applicants, licensees, and NRC staff. This revision provides a general update to the 

previous information contained in NUREG–1556, Volume 4, issued October 1998, to 

incorporate certain security requirements and other regulatory and policy changes that have 

been implemented since the original version was published.
vi

This report takes a risk-informed, performance-based approach to licensing fixed gauges. 

A team composed of staff from NRC Headquarters, NRC regional offices, and Agreement 

States prepared this document, drawing on their collective experience in radiation safety in 

general and as specifically applied to fixed gauges.

NUREG–1556, Volume 4, Revision 1, is not a substitute for NRC or Agreement State 

regulations. The approaches and methods described in this report are provided for information 

only. Methods and solutions different from those described in this report may be acceptable if

they include a basis for the staff to make the determinations needed to issue or renew a license.

The comments received during the public comment period for NUREG–1556, Volume 4, 

Revision 1, were summarized and addressed in a document that can be located on the NRC’s 

Agencywide Documents Access and Management System (ADAMS) under ML15055A205. 

Access to ADAMS is available on the public Web site at: http://www.nrc.gov/readingrm/adams.html. The comments received by NRC included general corrections, comments on 

training, and comments on safety culture.

___________________________________________

Daniel S. Collins, Director

Division of Material Safety, State, Tribal, and Rulemaking Programs

Office of Nuclear Material Safety and Safeguards
vii

TABLE OF CONTENTS

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

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

FIGURES ..................................................................................................................................ix

TABLES ....................................................................................................................................ix

ACKNOWLEDGMENTS............................................................................................................xi

ABBREVIATIONS ...................................................................................................................xiii

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

2 AGREEMENT STATES ...............................................................................................2-1

2.1 Jurisdiction Determination.....................................................................2-1

2.2 Reciprocal Recognition of Specific Licenses......................................................2-3

3 MANAGEMENT RESPONSIBILITY.............................................................................3-1

3.1 Commitments and Responsibilities ...................................................................3-1

3.2 Safety Culture...................................................................................................3-2

4 APPLICABLE REGULATIONS....................................................................................4-1

5 HOW TO FILE..............................................................................................................5-1

5.1 Application Preparation.....................................................................................5-1

5.2 Where to File ....................................................................................................5-1

5.3 Paper Applications............................................................................................5-2

5.4 Electronic Applications......................................................................................5-2

6 IDENTIFYING AND PROTECTING SENSITIVE INFORMATION.................................6-1

7 APPLICATION AND LICENSE FEES..........................................................................7-1

8 CONTENTS OF AN APPLICATION.............................................................................8-1

8.1 Item 1: License Action Type.............................................................................8-1

8.2 Item 2: Name and Mailing Address of Applicant...............................................8-2

8.2.1 Notification of Bankruptcy Proceedings................................................8-2

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

or Possessed.......................................................................................8-2

8.4 Item 4: Person To Be Contacted About This Application..................................8-4

8.5 Item 5: Radioactive Material.............................................................................8-4

8.5.1 Sealed Sources and Devices ...............................................................8-4

8.5.2 Financial Assurance and Recordkeeping for Decommissioning ...........8-5

8.6 Item 6: Purpose(s) for Which Licensed Material Will Be Used..........................8-7

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

Their Training and Experience .............................................................8-8

8.7.1 Radiation Safety Officer .......................................................................8-8

8.7.2 Authorized Users ...............................................................................8-10

8.8 Item 8: Training for Individuals Working In or Frequenting Restricted 

Areas .................................................................................................8-10

8.9 Item 9: Facilities and Equipment ....................................................................8-11

8.10 Item 10: Radiation Safety Program ................................................................8-12

8.10.1 Audit Program .....................................................................................8-12
viii

8.10.2 Radiation Monitoring Instruments ........................................................8-13

8.10.3 Material Receipt and Accountability.....................................................8-15

8.10.4 Occupational Dose ..............................................................................8-16

8.10.5 Public Dose .........................................................................................8-18

8.10.6 Operating, Emergency, and Security Procedures................................8-20

8.10.7 Leak Tests...........................................................................................8-26

8.10.8 Maintenance........................................................................................8-27

8.10.9 Transportation .....................................................................................8-30

8.10.10 Fixed Gauges Used at Temporary Job Sites .....................................8-31

8.10.11 Security Program for Category 1 and Category 2

 Radioactive Material..........................................................................8-34

8.11 Item 11: Waste Management—Gauge Disposal and Transfer........................8-35

8.12 Item 12: License Fees....................................................................................8-36

8.13 Item 13: Certification......................................................................................8-36

9 LICENSE AMENDMENTS AND RENEWALS..............................................................9-1

9.1 Timely Notification of Transfer of Control ..........................................................9-1

10 APPLICATIONS FOR EXEMPTIONS ........................................................................10-1

11 TERMINATION OF ACTIVITIES ................................................................................11-1

APPENDICES

APPENDIX A U.S. NUCLEAR REGULATORY COMMISSION FORM 313......................... A–1

APPENDIX B SUGGESTED FORMAT FOR PROVIDING INFORMATION

REQUESTED IN ITEMS 5 THROUGH 11 OF U.S. NUCLEAR

REGULATORY COMMISSION FORM 313................................................... B–1

APPENDIX C TYPICAL DUTIES AND RESPONSIBILITIES OF THE

RADIATION SAFETY OFFICER................................................................... C–1

APPENDIX D CRITERIA FOR ACCEPTABLE TRAINING FOR 

AUTHORIZED USERS AND RADIATION SAFETY OFFICERS................... D–1

APPENDIX E FIXED GAUGE AUDIT CHECKLIST............................................................. E–1

APPENDIX F MODEL RADIATION SURVEY INSTRUMENT

CALIBRATION PROGRAM ...........................................................................F–1

APPENDIX G DOSIMETRY-RELATED GUIDANCE ...........................................................G–1

APPENDIX H OPERATING, EMERGENCY, AND SECURITY PROCEDURES.................. H–1

APPENDIX I MODEL LEAK TEST PROGRAM ...................................................................I–1

APPENDIX J INFORMATION NEEDED TO SUPPORT APPLICANT’S 

REQUEST TO PERFORM NONROUTINE OPERATIONS ............................J–1

APPENDIX K U.S. DEPARTMENT OF TRANSPORTATION REGULATIONS ................... K–1

APPENDIX L INCIDENT NOTIFICATIONS AND REPORTING ...........................................L–1

APPENDIX M SAFETY CULTURE POLICY STATEMENT..................................................M–1

APPENDIX N CHECKLIST FOR REQUESTS TO WITHHOLD PROPRIETARY

INFORMATION FROM PUBLIC DISCLOSURE (UNDER 10 CFR 2.390)......N-1
ix

FIGURES

Figure Page

1-1 Examples of Several Different Types of Fixed Gauges.................................................1-1

2-1 U.S. Map: Locations of NRC Offices and Agreement States........................................2-1

8-1 Location of Use or Possession .....................................................................................8-3

8-2 Typical Duties and Responsibilities of RSOs ................................................................8-9

8-3 Annual Dose Limits for Adult Radiation Workers ........................................................8-17

8-4 Limiting Public Dose...................................................................................................8-20

8-5 Proper Handling of Incident ........................................................................................8-24

8-6 Lock-Out Procedures..................................................................................................8-25

8-7 Maintenance...............................................................................................................8-28

8-8 DOT Transportation Requirements.............................................................................8-31

8-9 Examples of Uses for Fixed Gauges at Temporary Job Sites. ....................................8-32

8-10 Security ......................................................................................................................8-33

8-11 Installation of Fixed Gauges at Temporary Job Sites..................................................8-33

G-1 Diagram of Bottling Line and Fixed Gauges ...............................................................G–5

TABLES

Table Page

2-1 Who Regulates the Activity?.........................................................................................2-2

3-1 Traits of a Positive Safety Culture.................................................................................3-3

8-1 Examples of Minimum Inventory Quantities Requiring Financial Assurance .................8-6

8-2 Record Maintenance ..................................................................................................8-15

G-1 Dosimetry Evaluation..................................................................................................G–3

G-2 Information Known About Each Gauge.......................................................................G–6

G-3 Calculational Method, Part 1–Hourly and Annual Dose Received From 

Gauge 1 .....................................................................................................................G–6

G-4 Calculational Method, Part 1–Hourly and Annual Dose Received From 

Gauge 2 .....................................................................................................................G–7

G-5 Calculational Method, Part 1–Hourly and Annual Dose Received From 

Gauge 3 .....................................................................................................................G–7

G-6 Calculational Method, Part 1–Total Hourly and Annual Dose Received 

From Gauges 1, 2, and 3............................................................................................G–8

G-7 Calculational Method, Part 2–Annual Dose Received From Gauges 1, 2, 

and 3 .........................................................................................................................G–8

G-8 Calculational Method, Part 3–Summary of Information ...............................................G–9

G-9 Calculational Method, Part 3–Annual Dose Received From Gauges 1, 2, 

and 3 .......................................................................................................................G–10

G-10 Combination Measurement–Calculational Method....................................................G–12

L-1 Typical NRC Notification and Reporting Requirements for Incidents ...........................L–1

xi

ACKNOWLEDGMENTS

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

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

The working group would like to thank the staff in the regional offices of the U.S. Nuclear 

Regulatory Commission and all of the States who provided comments and technical information 

that assisted in the development of this report.

The working group also thanks Tomas Herrera for the pivotal role that he played in the 

development of this report.

The Participants for this Revision

Cook, Jackie

Juran, Brandon

McCraw, Aaron

Reichard, Michael

Rivera-Capella, Gretchen

xiii

ABBREVIATIONS

ADAMS Agencywide Documents Access and Management System

AEA Atomic Energy Act

ALARA as low as is reasonably achievable

ANSI American National Standards Institute

AU authorized user

bkg background

Bq becquerel

CFR Code of Federal Regulations

cpm counts per minute

DOT U.S. Department of Transportation

dpm disintegrations per minute

G-M Geiger-Mueller

Gy Gray

HAZMAT hazardous material

IN Information Notice

L/C License Condition

MDA minimum detectable activity

mrem millirem

mSv millisievert

NMSS Office of Nuclear Material Safety and Safeguards

NRC U.S. Nuclear Regulatory Commission

NSTS National Source Tracking System

NSTTR National Source Tracking Transaction Report

NVLAP National Voluntary Laboratory Accreditation Program

OMB Office of Management and Budget

PII personally identifiable information

Q quality factor

R Roentgen

Rev. revision

RIS Regulatory Issue Summary

RQ reportable quantity

RSO radiation safety officer

SSD Sealed Source and Device [registration certificate]

std standard

Sv sievert

TEDE total effective dose equivalent

TI Transportation Index

U.S.C. United States Code

1-1

1 PURPOSE OF REPORT

This report provides guidance to an applicant applying for a fixed gauge license and also 

provides the U.S. Nuclear Regulatory Commission (NRC) staff with the criteria for evaluating 

such applications. It is not intended to address the research and development of fixed gauges 

or the commercial aspects of manufacturing, distributing, and nonroutine servicing of such 

devices. Within this document, the phrases or terms “fixed gauge,” “gauging devices,” or 

“gauges” are used interchangeably.

This report addresses a variety of radiation safety issues associated with fixed gauges of many 

designs. Typically, gauges are used for process control (e.g., to measure the thickness of 

paper, the density of coal, the level of material in vessels and tanks, and volumetric flow rate). 

Figure 1-1 illustrates various examples of different types of fixed gauges. Because of 

differences in design, manufacturers provide appropriate instructions and recommendations for 

proper operation and maintenance. In addition, with gauges of varying designs, the sealed 

sources may be oriented in different locations within the devices, resulting in different radiation 

safety considerations. Applicants should obtain this information from the manufacturers or 

suppliers if such information is not provided with the gauge.

Figure 1-1. Examples of Several Different Types of Fixed Gauges

Chapter 8, “Contents of an Application,” of this report identifies the information needed to 

complete NRC Form 313, “Application for Materials License” (see Appendix A of this NUREG), 

for the use of sealed sources in fixed gauges. The Office of Management and Budget (OMB) 

has approved the information collection requirements in Title 10 of the Code of Federal 

Regulations (10 CFR) Part 30, “Rules of General Applicability to Domestic Licensing of 

Byproduct Material,” and NRC Form 313 under OMB Clearance Nos. 3150-0017 and 3150-

0120, respectively.

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

• Regulations—references the regulations applicable to the item

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

• Discussion—provides additional information about the topic
1-2

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

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

licensing process

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

NRC Form 313.

NRC Form 313 does not have sufficient space for applicants to provide full responses to Items 5 

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

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

convenience and streamlined handling of fixed gauge applications, Appendix B of this NUREG, 

“Suggested Format for Providing Information Requested in Items 5 through 11 of NRC

Form 313,” may be used to provide supporting information.

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

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

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

Against Radiation.” To describe units of radiation exposure or dose, rem and its International 

System of Units equivalent, sievert (Sv) (1 rem = 0.01 Sv), are used. This is done because 

10 CFR Part 20 sets dose limits in terms of rem (Sv), rather than rad or roentgen. When the 

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

assumed to equal 1 rem. For alpha- and neutron-emitting radioactive material, 1 rad is not 

equal to 1 rem. Determination of dose equivalent (rem) from absorbed dose (rad) from alpha 

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

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

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

neutrons.
2-1

2 AGREEMENT STATES

2.1 Jurisdiction Determination

Certain States, called Agreement States (see Figure 2-1), have entered into agreements with 

the U.S. Nuclear Regulatory Commission (NRC) that give them the authority to license and 

inspect byproduct, source, and special nuclear materials in quantities not sufficient to form a 

critical mass, which are used or possessed within their borders. Any applicant, other than a 

Federal entity, who wishes to possess or use licensed material in one of these Agreement 

States should contact the responsible officials in that State for guidance on preparing an 

application. These applications should be filed with State officials, not with the NRC. In areas 

under exclusive Federal jurisdiction within an Agreement State, NRC continues to be the 

regulatory authority.

Figure 2-1. U.S. Map: Locations of NRC Offices and Agreement States

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

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

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

recognized Indian Tribes.2

 

 2For the purposes of this guidance, an “Indian Tribe” is defined as an Indian or Alaska Native tribe, band, nation,

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

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

www.bia.gov.
2-2

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

while the Agreement State may have jurisdiction over nonexclusive Federal jurisdiction land. 

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

areas where they plan to conduct licensed operations. Additional guidance on determining 

jurisdictional status is found in the Office of Nuclear Material Safety and Safeguards (NMSS)

procedures in the State Agreement series, SA-500, “Jurisdiction Determination,” which is 

available at https://scp.nrc.gov. Once on the Web site, use the link for “NMSS Procedures” in 

the left-hand column under “Resources & Tools.” 

Table 2-1 provides a quick way to evaluate whether the NRC or an Agreement State has 

regulatory authority.

Table 2-1. Who Regulates the Activity?

Applicant and Proposed Location of Work

Regulatory 

Agency

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

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

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

material under certain Department of Energy and Nuclear Regulatory 

Commission contracts”)

NRC

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

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

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

Non-Federal entity on federally recognized Indian Tribal land NRC3

Federally recognized Indian Tribe or Tribal member outside of Indian Tribal 

land in Agreement State. Agreement State

Non-Federal entity in Agreement State Agreement 

State4

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

subject to exclusive Federal jurisdiction

Agreement 

State4

 3The NRC can exercise jurisdiction as the regulatory authority on Tribal land of a federally recognized Indian Tribe. 

Section 274b. agreements do not give States the authority to regulate nuclear material in these areas. However,

there may be States that exercise regulatory authority over these areas based on treaties or agreements with specific 

tribes. Companies owned or operated by federally recognized Indian Tribe members or non-Indians that wish to 

possess or use licensed material on Tribal lands should contact the appropriate NRC regional office to determine the 

jurisdictional status of the Tribal lands and identify the appropriate regulatory agency for licensing and reciprocity.

4Section 274m. of the Atomic Energy Act (AEA) withholds to the NRC regulatory authority over radioactive materials

covered under the Section 274b. agreements when the activity can affect the Commission’s authority to protect the 

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

material. (This is an uncommon situation that NRC usually evaluates on a case-by-case basis.) Individuals or 

companies wishing to possess or use licensed material should contact the licensee to determine the jurisdictional 

status for specific AEA radioactive materials they intend to possess or use.
2-3

Table 2-1. Who Regulates the Activity?

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

exclusive Federal jurisdiction NRC

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

industrial radiography) directly connected with 10 CFR Part 50 or 52 reactor 

operations or needed during the construction and preoperational phases of 

a reactor. 

NRC

Non-Federal entity in Agreement State using radioactive materials not

directly connected with 10 CFR Part 50 or 52 reactor operations or needed 

during the construction and preoperational phases of a reactor.

Agreement 

State4

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

numbers of responsible officials) is available at the NMSS public Web site, https://scp.nrc.gov. 

A request for the list can also be made to an NRC regional office.

2.2 Reciprocal Recognition of Specific Licenses

Performing licensed activities in other jurisdictions is possible through reciprocal recognition of 

specific licenses (i.e., reciprocity). Agreement States have reciprocity provisions that permit 

NRC licensees to perform licensed activities under circumstances when an Agreement State is 

the regulatory authority (See Section 2.1). NRC licensees and Agreement State licensees are 

subject to the regulations of the regulatory authority as indicated in Section 2.1. To ensure 

compliance with an Agreement State’s reciprocity requirements, licensees are advised to 

request authorization from the appropriate Agreement State radiation control program office well 

in advance of the scheduled use of licensed material. 

Agreement State licensees that wish to conduct licensed activities in areas under NRC 

jurisdiction must either obtain a specific NRC license or file for reciprocity with the appropriate 

NRC regional office for the Agreement State that issued their license. Failure to file for 

reciprocity or obtain a specific NRC license before working in areas under NRC jurisdiction can 

result in NRC enforcement action, which may include civil penalties. The reciprocity filing must 

be renewed annually.

Specific guidance regarding NRC licensees filing for reciprocity in Agreements States and 

Agreement State licensees filing for reciprocity with the NRC or another Agreement State are 

provided in NUREG–1556, Volume 19, “Consolidated Guidance About Materials 

Licenses: Guidance for Agreement State Licensees About NRC Form 241 “Report of Proposed 

Activities in Non-Agreement States, Areas of Exclusive Federal Jurisdiction, or Offshore Waters” 

and Guidance for NRC Licensees Proposing to Work in Agreement State Jurisdiction 

(Reciprocity).”

3-1

3 MANAGEMENT RESPONSIBILITY

The U.S. Nuclear Regulatory Commission (NRC) recognizes that effective management of 

radiation safety programs is vital to achieving safe, secure, and compliant operations. 

Consistent compliance with NRC regulations provides reasonable assurance that licensed 

activities will be conducted safely and that effective management will result in increased safety, 

security, and compliance.

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

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

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

3.1 Commitments and Responsibilities

Pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 30.32(c), each application 

must be signed by the applicant or licensee or a person duly authorized to act for and on behalf 

of the applicant or licensee. If it is not clear whether the application was signed by someone 

duly authorized to act for and on behalf of the applicant or licensee, NRC license reviewers may 

ask for additional assurances that the individual who signed the application is duly authorized to 

act for and on behalf of the applicant or licensee. The signature on an application 

acknowledges the licensee’s commitments and responsibilities for the following:

• radiation safety, security, and control of radioactive materials and compliance 

with regulations

• completeness and accuracy of the radiation safety records and all information provided 

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

• knowledge about the contents of the license and application

• compliance with current NRC and U.S. Department of Transportation (DOT) regulations,

the licensee’s operating, emergency, and security procedures, and NRC license 

commitments

• commitment to provide adequate resources (including space, equipment, personnel, 

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

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

is maintained

• commitment to report defects, noncompliances, or reportable events in accordance with 

regulations

• selection and assignment of a qualified individual to serve as the radiation safety officer 

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

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

and responsibilities

• commitment to ensure that radiation workers have adequate training
3-2

• prevention of discrimination of employees engaged in protected activities (10 CFR 30.7, 

“Employee protection”)

• commitment to provide information to employees about the employee protection and 

deliberate misconduct provisions in 10 CFR 30.7, “Employee protection,” and 

10 CFR 30.10, “Deliberate misconduct”

• commitment to obtain the NRC’s prior written consent before transferring control of the 

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

• notification of the appropriate NRC regional administrator in writing, immediately 

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

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

this report

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

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

the NRC’s online library, under “Document Collections” at http://www.nrc.gov/reading-rm.html.

3.2 Safety Culture

Individuals and organizations performing regulated activities are expected to establish and 

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

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

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

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

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

subject to NRC authority.

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

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

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

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

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

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

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

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

and cost of the effort versus safety). Refer to Table 3-1 for the traits of a positive safety culture 

from NRC’s safety culture policy statement.

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

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

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

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

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

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

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

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

with NRC-regulated activities.
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The NRC, as the regulatory agency with an independent oversight role, reviews the 

performance of individuals and organizations to determine compliance with requirements and 

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

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

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

programs. For instance, many fixed gauges include shutters that allow the source to be 

shielded. If the fixed gauge shutter fails and cannot be closed, licensees are required to notify 

the NRC Headquarters Operations Center within 24 hours of discovery of an event involving 

licensed material in which equipment is disabled or fails to function when it is required to be 

available and operable to prevent exposures exceeding regulatory limits. The need to 

recognize an equipment failure and make a 24-hour report may correspond with the safety 

culture trait specified in Table 3-1 as “Problem Identification and Resolution” (issues potentially 

impacting safety are promptly identified, fully evaluated, and promptly addressed and corrected 

commensurate with their significance). However, licensees should be aware that this is just an 

example, and should consider reviewing their radiation safety programs in order to develop and 

implement a safety culture commensurate with the nature and complexity of their organizations 

and functions.

Refer to Appendix M of this NUREG for the NRC’s safety culture policy statement. More 

information on NRC activities relating to safety culture can be found at 

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

Table 3-1. Traits of a Positive Safety Culture

Leadership Safety Values

and Actions

Problem Identification and 

Resolution Personal Accountability

Leaders demonstrate a 

commitment to safety in their 

decisions and behaviors 

Issues potentially impacting 

safety are promptly 

identified, fully evaluated, 

and promptly addressed and 

corrected commensurate 

with their significance 

All individuals take personal 

responsibility for safety 

Work Processes Continuous Learning

Environment for Raising 

Concerns

The process of planning and 

controlling work activities is 

implemented so that safety 

is maintained 

Opportunities to learn about 

ways to ensure safety are 

sought out and implemented 

A safety conscious work 

environment is maintained 

where personnel feel free to 

raise safety concerns 

without fear of retaliation, 

intimidation, harassment,

or discrimination 
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Table 3-1. Traits of a Positive Safety Culture

Effective Safety 

Communications

Respectful Work 

Environment Questioning Attitude

Communications maintain a 

focus on safety 

Trust and respect permeate 

the organization 

Individuals avoid 

complacency and 

continuously challenge 

existing conditions and 

activities in order to identify 

discrepancies that might 

result in error or 

inappropriate action 
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4 APPLICABLE REGULATIONS

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

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

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

Federal Regulations (10 CFR) contain regulations applicable to fixed gauges. Some of these 

parts are specific to one type of license, while others are general and will apply to many, if not 

all, licensees.

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

U.S. Nuclear Regulatory Commission’s (NRC’s) online library at http://www.nrc.gov/readingrm.html. If viewing in a browser, the following list includes direct links to the rules:

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

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

and Investigations”

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

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

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

Byproduct Material”

• 10 CFR Part 31, “General Domestic Licenses for Byproduct Material”

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

Containing Byproduct Material”

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

Radioactive Material”

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

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

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

and in Offshore Waters under Section 274”

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

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

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

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

Quality Assurance Program Approvals and Government Agencies Licensed by the NRC”
4-2

Copies of these documents may be obtained by calling the Government Publishing Office 

Customer Contact Center toll-free at 866-512-1800, in Washington, DC; calling 202-512-1800;

or ordering online at http://bookstore.gpo.gov.

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

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

NRC regulations can also be accessed from the “NRC Library” link on the NRC’s public Web 

site at http://www.nrc.gov. Regulations are periodically amended, and the NRC (as well as all 

other Federal agencies) is required to publish notice of such amendments in the Federal 

Register.
5-1

5 HOW TO FILE

5.1 Application Preparation

Applicants for a materials license should do the following:

• Use the most recent guidance in preparing an application.

• Complete U.S. Nuclear Regulatory Commission (NRC) Form 313 (Appendix B of this 

NUREG), Items 1 through 4, 12, and 13, on the form itself. A link to the form is available 

at http://www.nrc.gov/reading-rm/doc-collections/forms/.

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

Appendix C of this NUREG.

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

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

and minimize danger to life and property.

• For each separate sheet other than NRC Form 313 and Appendix C pages, as 

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

application or the topic to which it refers.

• Avoid submitting proprietary information and personally identifiable information. If 

submitted, proprietary, personal privacy, security-related, and other sensitive 

information should be clearly identified according to Title 10 of the Code of Federal 

Regulations (10 CFR) 2.390, “Public inspections, exemptions, requests for withholding” 

(see Chapter 6, “Identifying and Protecting Sensitive Information”). 

5.2 Where to File

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

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

for the locale in which the material will be possessed or used. Figure 2-1 identifies the NRC’s 

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

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

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

to Region I.

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

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

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

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

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

States,” for additional information.
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5.3 Paper Applications

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

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

applicants should do the following:

• Submit all documents, typed, on 81⁄2 × 11-inch or legal-sized paper that will feed easily 

into a document scanner.

• Choose typeface designs that are sans serif, such as Arial, Helvetica, or Futura.

• Use 11-point or larger font.

• Avoid stylized characters, such as script or italics.

• Ensure that the print is clear and sharp.

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

is best).

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

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

5.4 Electronic Applications

Applications may be submitted in electronic form via the NRC’s Electronic Information 

Exchange, or CD-ROM. Detailed guidance on making electronic submissions can be obtained 

by visiting the NRC’s Web site at http://www.nrc.gov/site-help/e-submittals.html. The guidance 

discusses, among other topics, the formats the NRC can accept, the use of electronic 

signatures, and the treatment of non-public information.
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6 IDENTIFYING AND PROTECTING SENSITIVE INFORMATION

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

available for review in the U.S. Nuclear Regulatory Commission (NRC) Public Document Room 

and electronically at the NRC Library. For more information on the NRC Library, visit 

www.nrc.gov.

The applicant or licensee should identify, mark, and protect sensitive information against 

unauthorized disclosure to the public. License applications that contain sensitive information 

should be marked as indicated in the list that follows in accordance with Title 10 of the Code of 

Federal Regulations (10 CFR 2.390) before the information is submitted to the NRC. Key 

examples are as follows:

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

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

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

substantial delays in processing the application. Appendix N of this NUREG provides a 

checklist for requests for withholding proprietary information from public disclosure.

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

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

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

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

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

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

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

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

U.S. Nuclear Regulatory Commission,” dated March 9, 2007, and Information Notice (IN)

2013-22, “Recent Licensing Submittals Containing Personally Identifiable Information,” 

dated November 15, 2013, which can be found on the NRC’s Generic Communications 

Web page under “Regulatory Issue Summaries” and “Information Notices,” respectively:

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

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

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

plan or execute an attack against facilities or citizens in the U.S. As a result, certain 

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

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

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

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

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

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

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

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

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

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

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

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

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

Summaries”: http://www.nrc.gov/reading-rm/doc-collections/gen-comm/. Additional 
6-2

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

The regulations list various forms of information that can be protected from public disclosure. 

These include:

• trade secrets and commercial or financial information

• interagency or intra-agency memoranda or letters that would not be available by law to a 

party other than an agency in litigation with NRC

• certain records or information compiled for law enforcement purposes

• geological and geophysical information and data, including maps, or information 

concerning wells

• personnel, medical, and other information, the disclosure of which would constitute a 

clearly unwarranted invasion of personal privacy

In 10 CFR 2.390, NRC specifies the procedures and requirements for persons to submit 

sensitive information to NRC so that it may be properly protected from disclosure. This 

regulation is available electronically on the NRC Web site: http://www.nrc.gov/reading-rm/doccollections/cfr. 

Except for personal privacy information, which is not subject to the affidavit requirement, if NRC

determines that the application or affidavit is deficient (i.e., does not contain the required 

information as outlined in 10 CFR 2.390), the applicant will be notified that additional information 

is needed and that the review will continue when the required information is received.

If the request is denied, in whole or in part, NRC will give the applicant the option of withdrawing 

the information or application, as permitted in 10 CFR 2.390. If the applicant decides not to 

withdraw the information or application, NRC will notify the applicant in writing that the request 

for withholding has been denied and that NRC will disregard any references concerning the 

proprietary status of the information.

Any part of a license application or information provided by a licensee or applicant that the NRC 

determines should be withheld from public disclosure will be handled in accordance with 

Management Directive 12.6, “NRC Sensitive Unclassified Information Security Program,” and 

the licensee or applicant will be notified in writing that NRC plans to honor the request. 

Management Directive 12.6 is available electronically on the NRC Web site: 

http://www.nrc.gov/reading-rm/doc-collections/management-directives/.
6-3

Anyone submitting a request to withhold information from public disclosure should thoroughly 

review 10 CFR 2.390 and be familiar with its requirements and limitations.

Withholding from public inspection shall not affect the right, if any, of persons properly and 

directly concerned to inspect the documents. If the need arises, NRC may send copies of this 

information to NRC consultants working in that area. NRC will ensure that the consultants 

have signed the appropriate agreements for handling proprietary information.

If the basis for withholding this information from public inspection should change in the future, 

such that the information could then be made available for public inspection, the licensee or 

applicant should promptly notify the NRC. The licensee or applicant also should understand 

that NRC may have cause to review this determination in the future; for example, if the scope 

of a Freedom of Information Act request includes the information in question. In all review 

situations, if NRC makes a determination adverse to the above, the licensee or applicant will 

be notified in advance of any public disclosure. Anyone submitting commercial or financial 

information they believe to be privileged, confidential, or a trade secret must remember that 

the NRC’s policy is to achieve an effective balance between legitimate concerns for the 

protection of competitive positions and the right of the public to be fully apprised of the basis 

for, and the effects of, licensing or rulemaking actions. It is within NRC’s discretion to withhold 

such information from public disclosure.

7-1

7 APPLICATION AND LICENSE FEES

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

Refer to Title 10 of the Code of Federal Regulations (10 CFR) 170.31, “Schedule of fees for 

materials licenses and other regulatory services, including inspections, and import and export 

licenses,” to determine the amount of the fee. The U.S. Nuclear Regulatory Commission (NRC)

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

information on exemptions from these fees. Once the technical review of an application has 

begun, no fees will be refunded. Application fees will be charged regardless of the NRC’s 

disposition of an application or the withdrawal of an application.

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

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

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

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

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

Note that in order to pay reduced fees, a licensee that qualifies as a “small entity” must provide 

proper certification of this status to the NRC each year along with its annual fee payment.

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

Office of the Chief Financial Officer at NRC Headquarters in Rockville, MD, 

301-415-7554. Information about fees may also be obtained by calling NRC’s toll-free number, 

800-368-5642, extension 415-7554. The e-mail address is Fees.Resource@nrc.gov.

8-1

8 CONTENTS OF AN APPLICATION

The following information applies to the indicated items on U.S. Nuclear Regulatory Commission 

(NRC) Form 313 (Appendix A of this NUREG).

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

whether the proposed equipment, facilities, training and experience, and radiation safety and 

security programs satisfy regulatory requirements and are adequate to protect public health and 

safety and minimize danger to life and property. Consideration should be given, when 

developing the application, to the concepts of keeping exposure as low as is reasonably 

achievable (ALARA), minimizing contamination, and maintaining control of radioactive materials.

Title 10 of the Code of Federal Regulations (10 CFR) 20.1101(b) states: “The licensee shall 

use, to the extent practical, procedures and engineering controls based upon sound radiation 

protection principles to achieve occupational doses and doses to members of the public that are 

as low as is reasonably achievable (ALARA).” Regulatory Guide 8.10, “Operating Philosophy 

for Maintaining Occupational Radiation Exposures as Low as Is Reasonably Achievable,” 

discusses the ALARA concepts and philosophy. The application should document ALARA 

considerations, including establishing administrative action levels and monitoring programs.

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

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

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

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

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

The application should include information on how the licensee will implement the security 

requirements in 10 CFR 20.1801, “Security of stored material,” and 10 CFR 20.1802, “Control of 

material not in storage.”

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

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

8.1 Item 1: License Action Type

Item 1 of NRC Form 313 states the following:

This is an application for (check appropriate item):

Type of Action License No.

[ ] A. New License Not Applicable

[ ] B. Amendment XX-XXXXX-XX

[ ] C. Renewal XX-XXXXX-XX

Check box A for a new license request. Note that a prelicensing visit may be conducted prior to 

issuance of the license.

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

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

See “License Amendments and Renewals” in Chapter 9 of this report.
8-2

8.2 Item 2: Name and Mailing Address of Applicant

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

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

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

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

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

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

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

Note: The NRC must be notified and the transfer approved before control of the license is 

transferred (see Section 9.1, “Timely Notification of Transfer of Control”). The NRC must also 

be notified when bankruptcy proceedings have been initiated (See Section 8.2.1, “Notification of 

Bankruptcy Proceedings”).

8.2.1 Notification of Bankruptcy Proceedings

Regulation: 10 CFR 30.34(h)

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

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

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

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

subject to all applicable NRC regulatory requirements. The NRC must be notified when 

licensees are in bankruptcy proceedings in order to determine whether all licensed material is 

accounted for and adequately controlled and whether there are any public health and safety 

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

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

bankruptcy actions are completed and may request that the U.S. Department of Justice 

represent the NRC’s interests in the bankruptcy proceeding.

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

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

involuntary petition for bankruptcy by or against the licensee.

Reference: See NUREG–1556, Volume 15, “Consolidated Guidance About Materials Licenses: 

Guidance About Changes of Control and About Bankruptcy Involving Byproduct, Source, or 

Special Nuclear Materials Licenses.”

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

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

5 miles east of the intersection of Highway 10 and State Route 234, Anytown, State) for each 

facility. The descriptive address should be sufficient to allow an NRC inspector to find the 

facility location. A post office box address is not acceptable. In addition, applicants are 

encouraged to provide global positioning system coordinates, as appropriate. 
8-3

An acceptable location of use or possession specifies street address, city, State,

and zip code and does not include a post office box number.

Figure 8-1. Location of Use or Possession 

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

address or location not already listed on the license. This applies whether the gauge is an 

additional device or a relocation of an existing device.

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

periods of time), the address may be stated as “temporary jobsites anywhere in the U.S. where 

the NRC maintains jurisdiction.” For more information, see Section 8.10.10, “Fixed Gauges 

Used at Temporary Job Sites,” of this NUREG. That section offers examples of operations 

where fixed gauges might be used at temporary jobsites and identifies information that should 

be provided to the NRC to support a request for these operations.

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

amount of radioactive material, the applicant should mark these documents as 

“Security-Related Information—Withhold under 10 CFR 2.390.” See Chapter 6, “Identifying and 

Protecting Sensitive Information,” for more details. 

The applicant need not submit sketches or identify the specific location of the fixed gauge 

within the facility with the application. The NRC will review the acceptability of the gauge’s 

location during the inspection process.

Note: As discussed in Section 8.5.2, “Financial Assurance and Recordkeeping for 

Decommissioning,” licensees must maintain permanent records describing where licensed 

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

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

is terminated). For fixed gauge licensees, acceptable records are leak test records, sketches, 

and written descriptions of specific locations or room numbers where each gauge was used or 

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

State, or local regulations (e.g., local zoning requirements).
8-4

stored, and any information relevant to damaged devices or leaking radioactive sources or other 

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

8.4 Item 4: Person To Be Contacted About This Application

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

number where the individual may be contacted as well as business cell phone numbers and email addresses. This individual, usually the radiation safety officer (RSO), will serve as the point 

of contact during the review of the application. If this individual is not a full-time employee of the 

licensed entity, his or her position and relationship to the licensee should be specified. The 

NRC should be notified if the person assigned to this function changes or if his or her telephone 

number, cell phone number, or e-mail address changes. Notification of a contact change is only 

provided for informational purposes and would not be considered an application for license 

amendment, unless the notification involves a change in the contact person who is also the 

RSO.

As indicated on NRC Form 313 (see Appendix A of this NUREG), Items 5 through 11 should be 

submitted on separate sheets of paper. Applicants may use Appendix B of this NUREG for this 

purpose and should note that using the suggested wording of responses and committing to use 

the model procedures in this report will facilitate the NRC’s review.

8.5 Item 5: Radioactive Material

8.5.1 Sealed Sources and Devices

Regulations: 10 CFR 31.5, 10 CFR 30.32(g), 10 CFR 30.33(a)(2), 10 CFR 32.210

Criteria: Applicants must provide the radionuclide and nominal activity for each requested 

sealed source, the manufacturer’s or distributor’s name, and model number for each device, 

and the number of gauges for each model. Licensees will be authorized to possess and use 

only those sealed source and devices specifically approved and registered by the NRC or an 

Agreement State. The applicant should also provide a description of the use of the gauges.

Discussion: The NRC or an Agreement State performs safety evaluations of fixed gauges 

before distribution of the devices to specific licensees. The safety evaluation is documented in 

a Sealed Source and Device (SSD) registration certificate issued to the manufacturer (or 

distributor).

Licensees may not make any changes to the sealed source, device, or source/device 

combination that would alter the description or specifications from those indicated in the 

respective registration certificates without obtaining the NRC’s prior permission in a license 

amendment. Such changes may necessitate a custom registration review, increasing the time 

needed to process a licensing action.

SSD registration certificates contain sections on “Conditions of Normal Use” and “Limitation and 

Other Considerations of Use.” These sections may include limitations derived from, conditions 

imposed by the manufacturer or distributor, particular conditions of use that would reduce the 

radiation safety of the device, or circumstances unique to the sealed source and device. For 

example, the working life of the device or the appropriate temperature and other environmental 

conditions may be specified. Except as specifically approved by the NRC, licensees are 

required to use gauges according to their respective SSD registration certificates. Accordingly,
8-5

applicants should obtain a copy of the certificate from the manufacturer or distributor. If the 

manufacturer and distributor are no longer in service, a copy of the SSD registration certificate 

may be requested from the NRC or the issuing Agreement State. The applicant should review 

the provisions of the SSD registration certificate with the manufacturer or distributor, the NRC, 

or the issuing Agreement State.

The regulations in 10 CFR Part 37 apply to licensees that possess an aggregated Category 1 or 

Category 2 quantity of radioactive material, as specified in Appendix A to 10 CFR Part 37. The 

requirements in 10 CFR 20.2207 for submitting National Source Tracking Transaction Reports 

(NSTTR) are applicable to those licensees that manufacture, transfer, receive, disassemble, or 

dispose of sealed sources containing a quantity equal to or greater than the Category 1 or 

Category 2 levels of radioactive material listed in Appendix E to 10 CFR Part 20. See section 

8.10.11, “Security Program for Category 1 and Category 2 Radioactive Material,” of this NUREG 

for further information. 

This NUREG addresses fixed gauges that are authorized under a specific license. Note that 

some fixed gauges may be authorized under a general license in accordance with 10 CFR 31.5. 

A specific license is not necessary to possess generally licensed gauges, and an application for 

a specific license does not have to include such gauges. However, licensees may choose to list 

generally licensed gauges on their specific licenses, which would require such licensees to 

possess and use these gauges in accordance with their specific license.

Response from Applicant: Provide all of the following:

• Identify each radionuclide and nominal activity in each fixed gauge.

• Identify the manufacturer (or distributor) and model number of each type of fixed gauge.

• State the number of each type of fixed gauge requested.

• Provide a description of the use of the gauges.

• Confirm that the activity per source and maximum activity per gauge being requested will 

not exceed the maximum activity listed in the approved certificate of registration issued 

by the NRC or by an Agreement State.

For existing licensees with Category 1 or Category 2 quantities of materials, mark the section 

related to the possession of sealed source and devices that includes manufacturers, model 

numbers, and possession limits as follows: “Security-Related Information—Withhold Under 

10 CFR 2.390.”

Reference: For more information about the SSD registration process, see NUREG–1556, 

Volume 3, “Consolidated Guidance About Materials Licenses: Applications for Sealed Source 

and Device Evaluation and Registration.”

8.5.2 Financial Assurance and Recordkeeping for Decommissioning

Regulations: 10 CFR 30.34(b), 10 CFR 30.35, 10 CFR 30.51(f)

Criteria: Fixed gauge licensees authorized to possess sealed sources containing radioactive 

material in excess of the limits specified in 10 CFR 30.35, “Financial assurance and 
8-6

recordkeeping for decommissioning,” must provide evidence of financial assurance 

for decommissioning.

Licensees are required to maintain, in an identified location, decommissioning records related to 

leaking sources and to structures and equipment where gauges are used or stored. Pursuant to 

10 CFR 30.35(g), licensees must transfer these records important to decommissioning to the 

new proposed licensee before licensed activities are transferred or assigned in accordance with 

10 CFR 30.34(b). Furthermore, pursuant to 10 CFR 30.51(f), prior to license termination, each 

licensee must forward the records required by 10 CFR 30.35(g) to the appropriate NRC 

regional office.

Discussion: The requirements for financial assurance are specific to the types and quantities 

of byproduct material authorized on a license. Most fixed gauge applicants and licensees do 

not need to take any action to comply with the financial assurance requirements, because their 

possession limits do not exceed the thresholds in 10 CFR 30.35(d). The thresholds for typical 

radionuclides used for fixed gauge sealed sources are shown in Table 8-1.

Table 8-1. Examples of Minimum Inventory Quantities Requiring Financial Assurance

Radionuclide

(Sealed Sources) Activity in Gigabecquerels Activity in Curies

Cobalt-60 3.7 × 105 10,000

Krypton-85 3.7 × 107 1,000,000

Strontium-90 3.7 × 104 1,000

Cesium-137 3.7 × 106 100,000

Americium-241 3.7 × 103 100

Californium-252 3.7 × 103 100

A licensee would need to possess tens to hundreds of gauges before the financial assurance 

requirements would apply. Applicants and licensees desiring to possess gauges exceeding the 

threshold amounts must submit evidence of financial assurance. Licensees should follow the 

guidance provided in NUREG-1757, Volume 3, “Consolidated Decommissioning Guidance—

Financial Assurance, Recordkeeping, and Timeliness.” 

Applicants requesting more than one radionuclide may determine whether financial assurance 

for decommissioning is required by calculating, for each radionuclide possessed, the ratio 

between the activity possessed, in curies, and the radionuclide’s threshold activity requiring 

financial assurance, in curies. If the sum of such ratios for all of the radionuclides possessed 

exceeds “1” (i.e., “unity”), then applicants must submit evidence of financial assurance 

for decommissioning.

The regulations in 10 CFR 30.35(g) also require that licensees maintain records important to 

decommissioning in an identified location. All fixed gauge licensees need to maintain records of 

structures and equipment where each gauge was used or stored. As-built drawings (not 

blueprints) with modifications of structures and equipment shown, as appropriate, fulfill this 

requirement. If drawings are not available, licensees must substitute appropriate records (e.g., 

a sketch of the room or building or a narrative description of the area) concerning these areas 

and locations. If no records exist regarding structures and equipment where gauges were used 

or stored, licensees must make all reasonable efforts to create such records based on historical 

information (e.g., employee recollections). In addition, if fixed gauge licensees have 

experienced unusual occurrences (e.g., leaking sources and other incidents that involve the 

spread of contamination) they also need to maintain records about possible contamination that 

remains after cleanup or that may have spread to inaccessible areas.
8-7

For fixed gauge licensees whose sources have never leaked, acceptable records important to 

decommissioning are sketches or written descriptions of the specific locations where each 

gauge was used or stored, copies of a current leak test for each gauge, and records of transfer 

or disposal.

Response from Applicant: No response is needed from most applicants. If financial 

assurance is required, submit the documentation required under 10 CFR 30.35 and follow the 

guidance of NUREG-1757.

Reference: NUREG-1757, Volume 3, “Consolidated Decommissioning Guidance—Financial 

Assurance, Recordkeeping, and Timeliness.”

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

Regulation: 10 CFR 30.33(a)(1)

Criteria: An application for a license will be approved if the proposed activity is authorized by 

the Atomic Energy Act of 1954, as amended, and devices will be used only for the purposes for 

which they were designed and according to the manufacturer’s recommendations for use as 

specified in an approved SSD registration certificate.

Discussion: Uses other than those listed in the SSD registration certificate require review and 

approval by the NRC or an Agreement State. Requests to use fixed gauges for purposes not 

listed in the SSD registration certificate will be reviewed on a case-by-case basis. Applicants 

need to submit sufficient information to demonstrate that the proposed use will not compromise 

the source integrity or shielding, or other components of the device critical to radiation safety. 

The NRC will evaluate the radiation safety program for each type and use of gauge requested.

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

State, or local regulations.

Response from Applicant: Specifically describe how each device will be used. If the fixed 

gauge(s) will be used for the purposes listed on the SSD registration certificate, or as 

recommended by the manufacturer, the applicant may so state. If the fixed gauge will be used 

for purposes other than those listed on the SSD registration certificate, specify these other 

purposes and include a safety analysis supporting the request.

Notes:

• Allowed uses of fixed gauges normally include process control methods, such as 

measuring the thickness of paper, the density of coal, the level of material in vessels and 

tanks.

• Unusual uses will be evaluated on a case-by-case basis, and the authorized use 

condition will reflect approved uses.
8-8

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

Training and Experience

8.7.1 Radiation Safety Officer

Regulation: 10 CFR 30.33(a)(3)

Criteria: RSOs must have adequate training and experience. In the past, the NRC has 

found successful completion of one of the following to be evidence of adequate training 

and experience:

• fixed gauge manufacturer’s or distributor’s course for users or for RSOs 

OR

• equivalent course that meets the criteria in Appendix D of this NUREG

Additional training is required for RSOs in programs that perform nonroutine operations. This 

includes repairs involving or potentially affecting components related to the radiological safety of 

the gauge (e.g., the source, source holder, source drive mechanism, shutter, shutter control, or 

shielding) and any other activities during which personnel could receive radiation doses 

exceeding the NRC’s regulatory dose limits (e.g., installation, initial radiation survey, gauge 

relocation, and removal of the gauge from service). See Section 8.10.8, “Maintenance,” and 

Appendix J to this report for more information on nonroutine operations.

Discussion: The person responsible for the radiation protection program is the RSO. The 

RSO is key to overseeing and ensuring safe operation of the licensee’s radiation protection

program. The RSO must have adequate training to understand the hazards associated with 

radioactive material and be familiar with all applicable regulatory requirements. The RSO 

should have independent authority to stop operations that he or she considers unsafe. He or 

she should have sufficient time and commitment from management to fulfill his or her duties and 

responsibilities to ensure that radioactive materials are used in a safe manner, approved 

radiation safety procedures are being implemented, and the required records of licensed 

activities are maintained. Typical RSO duties are illustrated in Figure 8-2 and described in 

Appendix C of this NUREG. The NRC requires the name of the RSO to be listed on the license 

to ensure that licensee management always has a responsible, qualified person identified and 

that the named individual knows of his or her designation as RSO. Appendix C of this NREG 

also provides a model Delegation of Authority, which should be used to further emphasize the 

agreement on duties and responsibilities of the RSO by management and the designated RSO.
8-9

Figure 8-2. Typical Duties and Responsibilities of RSOs

The RSO may delegate certain day-to-day tasks of the radiation protection program to other 

responsible individuals, sometimes referred to as “alternate RSOs” or “site RSOs.” For 

example, a licensee with multiple permanent locations of use or use at temporary jobsites may 

appoint “site RSOs,” who assist the RSO and are responsible for the day-to-day activities at 

these locations. Licensees may also appoint “alternate RSOs” who may “step in” as an 

emergency contact when the RSO is unavailable. Such “alternate RSOs” or “site RSOs” do not 

need to meet all RSO qualifications; however, they should be qualified, experienced authorized

users who have adequate knowledge of the activities to which they are assigned. These 

individuals should have the same management support and decision-making authority as the 

RSO that is necessary to accomplish the tasks to which they have been assigned. Please note 

that only the primary RSO is named on an NRC license.

Response from Applicant: Provide the following:

• name of the proposed RSO

• documentation demonstrating that the proposed RSO is qualified by training and 

experience (e.g., certificate of completion of the RSO’s course and/or the authorized 

user’s course)

Note: Licensees must notify the NRC and obtain a license amendment before making changes 

in the designation of the RSO responsible for the radiation safety program.
8-10

8.7.2 Authorized Users

Regulation: 10 CFR 30.33(a)(3)

Criteria: The individuals using the gauges are usually referred to as “authorized users.” 

Authorized users (AUs) must have adequate training and experience in the use of fixed gauges. 

In the past, the NRC has found successful completion of one of the following to be evidence of 

adequate training and experience:

• fixed gauge manufacturer’s or distributor’s course for users 

OR

• equivalent course that meets the criteria in Appendix D of this NUREG

Applicants requesting to perform nonroutine operations, such as gauge installation; initial 

radiation survey; repair and maintenance of components related to the radiological safety of the 

gauge; gauge relocation; replacement and disposal of sealed sources; gauge alignment; or 

removal of a gauge from service, must provide additional training. See Section 8.10.8, 

“Maintenance,” and Appendix J to this report for more information.

Discussion: AUs have the responsibility to ensure the proper use, security, and routine

maintenance of fixed gauges containing licensed material. AUs must attend the training and 

instruction given at the time of installation or receive equivalent training and instruction.

An AU is considered to be supervising the use of licensed material when he or she directs 

personnel in operations involving the material. Although the AU may delegate specific tasks to 

supervised users (e.g., maintaining records), he or she is still responsible for safe use of 

licensed material.

Response from Applicant: Provide either of the following:

• the statement: “Before using licensed materials, authorized users will have successfully 

completed one of the training courses described in the ‘Criteria’ part of the section titled,

‘Authorized Users’ in NUREG–1556, Volume 4, Revision 1, ‘Consolidated Guidance 

About Materials Licenses: Program-Specific Guidance About Fixed Gauge Licenses.’”

OR

• a description of the training and experience for proposed AUs

Note: Records of the training of each AU must be maintained for 3 years following the last use 

of licensed material by the AU.

8.8 Item 8: Training for Individuals Working In or Frequenting Restricted Areas

Regulations: 10 CFR 19.12, 10 CFR 30.33(a)(3)

Criteria: Individuals who in the course of employment are likely to receive occupational doses 

of radiation in excess of 1 millisievert (mSv) [100 millirem (mrem)] in a year must receive 
8-11

training according to 10 CFR 19.12, “Instruction to workers.” The extent of this training must be 

commensurate with potential radiological health protection problems present in the work place.

Discussion: Licensees need to perform a prospective evaluation to determine radiation doses 

likely to be received by different individuals or groups (see Section 8.10.4, “Occupational 

Dose”). AUs and individuals performing installations, relocations, nonroutine maintenance, or 

repairs would be most likely to receive doses in excess of 1 mSv [100 mrem] in a year. See the 

previous section for a discussion of training and experience for AUs.

Licensee personnel who work in the vicinity of a fixed gauge but do not use gauges 

(ancillary staff) are not required to have radiation safety training as long as they are not likely to 

receive a dose of 1 mSv [100 mrem] in a year. However, to minimize potential radiation 

exposure when ancillary staff are working in the vicinity of a fixed gauge, it is prudent for them to 

work under the supervision and in the physical presence of an AU or to be provided some basic 

radiation safety training. Such ancillary staff should be informed of the nature and location of 

the gauge and the meaning of the radiation symbol and should be instructed not to touch the 

gauge and to keep away from it as much as their work permits.

Some ancillary staff, although not likely to receive doses over 1 mSv [100 mrem], should receive 

training to ensure adequate security and control of licensed material. To ensure the control and 

security of licensed material, licensees may provide these individuals with training 

commensurate with their assignments in the vicinity of the gauge.

Response from Applicant: No response is required from the applicant as part of the license 

application. The applicant’s training program for individuals who in the course of employment 

are likely to receive occupational doses of radiation in excess of 1 mSv [100 mrem] in a year 

(occupationally exposed workers) and ancillary personnel will be examined during inspections.

8.9 Item 9: Facilities and Equipment

Regulations: 10 CFR 20.1101(b), 10 CFR 20.1201, 10 CFR 20.1301, 10 CFR 20.1801, 

10 CFR 30.33(a)(2)

Criteria: Facilities and equipment must be adequate to protect health and to minimize danger 

to life or property. This may be demonstrated by the following:

• the location of the gauge is compatible with the “Conditions of Normal Use” and 

“Limitations and/or Other Considerations of Use” on the SSD registration certificate

AND

• the fixed gauge is secured to prevent unauthorized removal or access (e.g., located in a

locked room, permanently mounted, or chained and locked to a storage rack)

Discussion: Fixed gauges incorporate many engineering features to protect the user from 

unnecessary radiation exposure in a wide variety of environments. Fixed gauges may be 

located in harsh environments involving variables such as pressure; vibration; mounting 

height/method; temperature; humidity; air quality; corrosive atmospheres; corrosive chemicals 

including process materials and cleaning agents; possible impact or puncture conditions; and 

fire, explosion, and flooding potentials. Applicants and/or licensees need to consult the sections 

on the SSD registration certificate titled, “Conditions of Normal Use” and “Limitations and/or 
8-12

Other Considerations of Use” to determine the appropriate gauge and location. In those 

instances when a proposed location is not consistent with the SSD registration certification, the 

applicant may ask the source or device manufacturer or distributor to request an amendment to 

modify the SSD registration certificate to include the new conditions. If the manufacturer or 

distributor does not request an amendment, the applicant must provide the NRC with specific 

information demonstrating that the proposed new conditions will not impact the safety or 

integrity of the source or device.

Response from Applicant: Provide one of the following:

• the statement: “We will ensure that the location of each fixed gauge meets the criteria in 

Section 8.9, ‘Facilities and Equipment,’ in NUREG–1556, Volume 4, Revision 1, 

‘Consolidated Guidance About Materials Licenses: Program-Specific Guidance About 

Fixed Gauge Licenses.’”

OR

• confirmation that the fixed gauge is secured to prevent unauthorized removal or access 

and submittal of specific information demonstrating that the proposed conditions will not 

impact the safety or integrity of the source or device (Address any instances where the 

proposed conditions exceed any conditions listed in the SSD registration certificate.)

Note: Any deviations from an SSD registration certificate will require specific NRC or 

Agreement State approval.

8.10 Item 10: Radiation Safety Program

8.10.1 Audit Program

Regulations: 10 CFR 20.1101, 10 CFR 20.2102, 10 CFR 20.2103(a)

Criteria: Licensees must review the content and implementation of their radiation protection 

programs at least annually to ensure the following:

• Programs comply with NRC and U.S. Department of Transportation (DOT) regulations 

(as applicable) and the terms and conditions of the license.

• Occupational doses and doses to members of the public are ALARA.

Records of audits and other reviews of program content are maintained for 3 years after the 

record is made.

Discussion: Appendix E of this NUREG contains a suggested annual audit program that is 

specific to the use of fixed gauges and is acceptable to the NRC. Since all areas indicated in 

Appendix E may not be applicable to every licensee and all items may not need to be 

addressed during each audit, licensees may wish to develop a program-specific audit checklist.

The NRC encourages licensee management to conduct performance-based reviews by 

observing work in progress, interviewing staff, and spot-checking required records. As part of 

the audit program, licensees should consider including unannounced audits of fixed gauge 

users to observe whether radiation safety procedures are being followed. 
8-13

It is essential that once problems are identified, comprehensive corrective actions are taken in a 

timely manner. Information Notice (IN) 96-28, “Suggested Guidance Relating to Development 

and Implementation of Corrective Action,” dated May 1, 1996, provides guidance on this 

subject. The NRC routinely reviews licensee’s records to verify whether appropriate corrective 

actions were implemented in a timely manner to address recurrence. It is in the best interest of 

the licensee to identify potential violations of regulatory requirements and take necessary steps 

to correct them. The NRC can opt to exercise discretion and may elect not to cite the licensee 

for these violations if prompt and effective corrective actions are implemented. The NRC’s 

Enforcement Policy may be found online at http://www.nrc.gov/aboutnrc/regulatory/enforcement/enforce-pol.html, and the Enforcement Manual may be found online 

at http://www.nrc.gov/about-nrc/regulatory/enforcement/guidance.html. For examples of the 

NRC’s use of discretion in issuing a notice of violation, refer to the most recent version of NRC’s 

enforcement documents at http://www.nrc.gov/reading-rm/doc-collections/enforcement/.

With regard to audit records, 10 CFR 20.2102 requires, in part, that licensees maintain records 

of “audits and other reviews of program content and implementation” for 3 years after the record 

is made. The NRC has found audit records that contain the following information to be 

acceptable: date of audit, name of person(s) who conducted audit, persons contacted by the 

auditor(s), areas audited, audit findings, corrective actions, and followup.

Response from Applicant: The applicant should not submit its audit program to the NRC for 

review during the licensing phase. The audit program will be reviewed during NRC inspections.

Reference: Inspection Procedure 87124, “Fixed and Portable Gauge Programs”

8.10.2 Radiation Monitoring Instruments

Regulations: 10 CFR 20.1501, 10 CFR 20.2103(a), 10 CFR 30.33(a)(2)

Criteria: Licensees should possess, or have access to, radiation monitoring instruments, which 

are necessary to protect health and minimize danger to life or property. Instruments used for 

quantitative radiation measurements must be calibrated periodically for the radiation measured.

Discussion: Typically, fixed gauge licensees that only engage in routine operations do not 

possess their own radiation survey meters, because these licensees contract with service 

providers that perform the surveys required by 10 CFR 20.1501. However, an applicant that 

plans to conduct nonroutine operations will also need to perform surveys in accordance with 

10 CFR 20.1501 that are related to these activities and such licensees usually possess radiation 

survey meters that are used for this purpose. Nonroutine operations include installation, initial 

radiation surveys, relocation, removal from service, dismantling, alignment, replacement, 

disposal of the sealed source, and nonroutine maintenance and repair of components related to 

the radiological safety of the gauge. See Section 8.10.8, “Maintenance,” and Appendix J for 

more information on maintenance and nonroutine operations. Because some of these 

operations may increase the opportunity for radiation exposure, the areas where individuals will 

be performing these operations should be carefully monitored with a survey meter. Such survey 

meters must be properly calibrated. Proper calibration is particularly important for initial surveys 

because the results can be used as a basis for public dose estimates. For those licensees 

requesting authorization to calibrate their own survey instruments, Appendix F of this NUREG 

contains calibration procedures acceptable to the NRC. 
8-14

Each year, a number of gauges experience equipment failures because of corrosion caused by 

the harsh environmental conditions in which many gauges are operated. Following discovery of 

an equipment failure, it is important to determine whether the shielding and source are intact. 

The most efficient and effective way to do this is by measuring the radiation levels in the vicinity 

of the gauge with an appropriate, calibrated survey instrument. Because many fixed gauge 

licensees are not required to possess a survey meter, applicants should preplan how they will 

obtain assistance in performing a radiation survey in the event of an emergency (e.g., obtain a 

survey instrument from the manufacturer, a consultant, another NRC or Agreement State 

licensee, or a local emergency response organization).

Response from Applicant: Provide one of the following:

• the statement: “Surveys according to 10 CFR 20.1501 will be performed by a person 

specifically authorized by the NRC or an Agreement State to perform these surveys.”

OR

• the statement: “We will use radiation survey instruments that meet the criteria in 

Section 8.10.2, ‘Radiation Monitoring Instruments,’ in NUREG–1556, Volume 4, Revision 

1, ‘Consolidated Guidance About Materials Licenses: Program-Specific Guidance About 

Fixed Gauge Licenses,’ and one of the following three choices:

– “Each radiation survey meter will be calibrated by the manufacturer or other 

person authorized by the NRC or an Agreement State to perform radiation survey 

meter calibrations.”

OR

– “We will implement the model radiation survey instrument calibration program in 

Appendix F, ‘Model Radiation Survey Instrument Calibration Program,’ in 

NUREG–1556, Volume 4, Revision 1, ‘Consolidated Guidance About Materials 

Licenses: Program-Specific Guidance About Fixed Gauge Licenses.’”

OR

– “We will submit alternative calibration procedures for NRC review.”

OR, IN LIEU OF ALL PREVIOUS STATEMENTS

• submit a description of an alternative method to perform radiation surveys according to 

10 CFR 20.1501

Notes:

• Alternative responses will be reviewed against the previously criteria listed.

• Regardless of whether an applicant is authorized to calibrate radiation survey meters or 

contracts an authorized firm to perform calibrations, the licensee must retain records of 

the calibration of instruments and equipment used for quantitative radiation 

measurements for 3 years after the record is made, in accordance with 10 CFR 

20.2103(a).
8-15

8.10.3 Material Receipt and Accountability

Regulations: 10 CFR 20.1801, 10 CFR 20.1802, 10 CFR 20.2201, 10 CFR 20.2207, 

10 CFR 30.34(e), 10 CFR 30.41, 10 CFR 30.51

Criteria: Licensees must do the following:

• maintain records of receipt, transfer, and disposal of fixed gauges

• conduct physical inventories every 6 months (or at some other intervals justified by the 

applicant and approved by the NRC) to account for all sealed sources

• update transactions in the National Source Tracking System (NSTS) and perform an 

NSTS annual inventory reconciliation, if applicable

Discussion: Licensed materials must be tracked “from cradle to grave” in order to ensure 

gauge accountability; identify when sealed sources/gauges could be lost, stolen, or misplaced; 

and ensure that possession limits listed on the license are not exceeded. Significant problems 

can arise from failure to ensure the accountability of fixed gauges (see NRC IN 88-02, “Lost or 

Stolen Gauges,” dated February 2, 1988).

Receipt, inventory, transfer, and disposal records must be maintained for the times specified in 

Table 8-2. Typically, these records contain the following types of information:

• radionuclide and the activity (in units of becquerels or curies) of byproduct material in 

each sealed source

• manufacturer’s or distributor’s name, model number, and serial number (if appropriate) 

of each device containing byproduct material

• location of each sealed source and device

• for inventories, the date of the inventory, and name and signature of the individual 

conducting the inventory

• for materials transferred or disposed of, the date of the transfer or disposal, the name 

and license number of the recipient, and a description of the affected radioactive 

material (e.g., radionuclide, activity, manufacturer’s or distributor’s name and model 

number, serial number)

Table 8-2. Record Maintenance

Type of Record How Long Record Must Be Maintained

Receipt For as long as the material is possessed and for 3 years 

following the transfer or disposal of the material

Inventory For 5 years from the date of the inventory in accordance 

with license conditions

Transfer For 3 years after each transfer unless a specific requirement 

dictates otherwise

Disposal Until the NRC terminates the license

Important to Decommissioning* Until the site is released for unrestricted use

*See Section 8.5.2, “Financial Assurance and Recordkeeping for Decommissioning,” for more details.
8-16

Response from Applicant: Provide either of the following:

• the statement: “Physical inventories will be conducted every 6 months or at other 

intervals approved by the NRC to account for all sealed sources and devices received 

and possessed under the license.”

OR

• a description and justification of an alternate frequency and/or procedure to account for 

all sealed sources and devices received and possessed under the license

AND

• the statement: “We will develop, implement, and maintain procedures for ensuring 

accountability of licensed materials at all times.”

Note: The requirements of the NSTS apply to sealed sources containing a quantity equal to or 

greater than Category 1 or Category 2 levels of any radioactive material listed in Appendix E, 

“Nationally Tracked Source Thresholds,” to 10 CFR Part 20.

References: INs are available in the “NRC Library” on the NRC’s public Web site at 

http://www.nrc.gov. 

8.10.4 Occupational Dose

Regulations: 10 CFR 19.13, 10 CFR 20.1201, 10 CFR 20.1207, 10 CFR 20.1208, 

10 CFR 20.1501, 10 CFR 20.1502

Criteria: Applicants must do either of the following:

• perform a prospective evaluation demonstrating that unmonitored individuals are not 

likely to receive a radiation dose in excess of the limits in 10 CFR 20.1502(a), and 

maintain a record of this evaluation for inspection by the NRC

OR

• provide and require the use of individual monitoring devices (dosimetry) (All personnel 

dosimeters that require processing to determine the radiation dose must be processed 

and evaluated by a National Voluntary Laboratory Accreditation Program (NVLAP)-

approved processor.)

Discussion: Licensees must evaluate the potential occupational exposure of all workers and 

monitor occupational exposure. When personnel monitoring is required, for all personnel 

dosimeters that require processing to determine the radiation dose, licensees must use 

dosimeters supplied by an NVLAP-approved processor. The exchange frequency for 

dosimeters is typically monthly or quarterly. Applicants should consult with their 

NVLAP-approved processor for its recommendations for exchange frequency and proper use of 

the dosimeter.
8-17

The annual dose limits for adult radiation workers are shown in Figure 8-3. Note that in 

accordance with 10 CFR 20.1207, the annual occupational dose limits for minors are 10 percent 

of the annual dose limits specified for adult workers. Also, 10 CFR 20.1208 requires the 

licensee to ensure that the dose equivalent to the embryo/fetus during the entire pregnancy, due 

to the occupation exposure of a declared pregnant woman, does not exceed 0.5 rem [5 mSv].

Figure 8-3. Annual Dose Limits for Adult Radiation Workers

Total effective dose equivalent (TEDE) equals the effective dose equivalent (for external 

exposures) plus the committed effective dose equivalent (for internal exposures).

The use of individual monitoring devices for external dose is required, pursuant to 

10 CFR 20.1502(a), for

• adults who are likely to receive an annual dose in excess of any of the following 

(each evaluated separately)

– 5 mSv [0.5 rem] deep-dose equivalent

– 15 mSv [1.5 rems] lens (of the eye) dose equivalent

– 50 mSv [5 rems] shallow-dose equivalent to the skin

– 50 mSv [5 rems] shallow-dose equivalent to any extremity

• minors who are likely to receive an annual dose in excess of any of the following 

(each evaluated separately)

– 1.0 mSv [0.1 rem] deep-dose equivalent

– 1.5 mSv [0.15 rem] lens (of the eye) dose equivalent

– 5 mSv [0.5 rem] shallow-dose equivalent to the skin

– 5 mSv [0.5 rem] shallow-dose equivalent to any extremity

• declared pregnant women who are likely to receive a dose from radiation sources 

external to the body during the entire pregnancy in excess of 1.0 mSv [0.1 rem] deepdose equivalent
8-18

• individuals entering a high or very high radiation area

Under conditions of routine use, typically a worker does not require an individual monitoring 

device (dosimetry). A worker also may not require dosimetry when proper emergency 

procedures are followed. Appendix G of this NUREG provides guidance on performing a 

prospective evaluation demonstrating that workers are not likely to exceed the limits in 10 CFR 

20.1502(a) and thus are not required to have personnel dosimetry.

Workers who perform nonroutine operations, such as gauge installation; initial radiation survey;

repair and maintenance of components related to the radiological safety of the gauge; gauge 

relocation; replacement and disposal of sealed sources; gauge alignment; or removal of a 

gauge from service, are more likely than workers who only engage in routine activities to exceed 

the limits in 10 CFR 20.1502(a). Applicants must provide dosimetry (whole body and perhaps 

extremity monitors) to workers who perform nonroutine operations or must perform a 

prospective evaluation demonstrating that unmonitored workers who perform nonroutine 

operations are not likely to receive radiation doses in excess of the limits in 10 CFR 20.1502(a).

Response from Applicant: Provide one of the following:

• the statement: “We will maintain, for inspection by the NRC, documentation 

demonstrating that unmonitored individuals are not likely to receive a radiation dose in 

excess of the limits in 10 CFR 20.1502(a).”

OR

• the statement: “We will provide and require the use of individual monitoring devices 

(dosimetry). All personnel dosimeters that require processing to determine the radiation 

dose will be processed and evaluated by a NVLAP-approved processor.”

Notes:

• Alternative methods for demonstrating compliance with the referenced regulations will be 

evaluated against the previously listed criteria.

• Some licensees choose to provide personnel dosimetry to their workers for reasons 

other than compliance with NRC requirements (e.g., to respond to worker requests or to 

maintain records of personal exposure).

Reference: The National Institute of Standards and Technology maintains a directory of 

laboratories that are NVLAP-approved at http://ts.nist.gov/standards/scopes/dosim.htm.

8.10.5 Public Dose

Regulations: 10 CFR 20.1301, 10 CFR 20.1302, 10 CFR 20.1801, 10 CFR 20.1802, 

10 CFR 20.2107

Criteria: Licensees must do the following:

• ensure that fixed gauges will be used, transported, and stored in such a way that 

members of the public will not receive more than 1 mSv [100 mrem] in a year, and the 
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dose in any unrestricted area will not exceed 0.02 mSv [2 mrem] in any one hour, from 

licensed operations

• prevent unauthorized access, removal, or use of fixed gauges

Discussion: Public dose is defined in 10 CFR Part 20 as “the dose received by a member of 

the public from exposure to radiation or to radioactive material released by a licensee, or to any 

other source of radiation under the control of a licensee.” Public dose excludes doses received 

from background radiation and medical procedures. Whether the dose to an individual is an 

occupational dose or a public dose depends on the individual’s assigned duties. It does not 

depend on the area (restricted, controlled, or unrestricted) where the individual is when he or 

she receives the dose.

In the case of fixed gauges, members of the public include persons who live, work, or may be

near locations where fixed gauges are used or stored and employees whose assigned duties do 

not include the use of licensed materials and who work in the vicinity where gauges are used or 

stored. Because a fixed gauge presents a radiation field, the applicant must use methods to 

limit the public dose such that it does not exceed 1 mSv [100 mrem] in a year or 0.02 mSv 

[2 mrem] in any one hour.

Because fixed gauges are generally permanently mounted (e.g., chained and locked to a 

storage rack), they may not need to be in a locked area to prevent loss, theft, or unauthorized 

removal. Procedures regarding security and lock-out procedures specified in Section 8.10.6, 

“Operating and Emergency Procedures,” of this document should be sufficient to limit the 

exposure to the public during use or storage and after accidents. IN 81-37, Revision 1, 

“Unnecessary Radiation Exposures to the Public and Workers During Events Involving 

Thickness and Level Measuring Devices,” dated February 9, 1982, provides information about 

an event that resulted or may have resulted in unnecessary radiation exposure to members of 

the public. IN 88-02 provides information about several events where fixed gauges were lost or 

stolen.

Public dose is also affected by the location of the gauge. Use the concepts of time, distance, 

and shielding when developing a method to limit public dose. Decreasing the time spent near a 

gauge, increasing the distance from the gauge, and using shielding will reduce the radiation 

exposure. The most effective way to limit public dose is to prevent members of the public from 

entering areas where gauges are used or stored. This may be accomplished by administrative 

or engineering controls.

Administrative controls include training and warning signs. In cases where gauges are located 

in harsh environmental conditions (e.g., high temperatures, caustic chemicals), warning signs 

may be difficult to maintain so requiring radiation awareness training to caution employees 

would be a good practice.

Engineering controls reduce radiation levels. Shielding the gauge with a protective barrier 

(e.g., using brick, concrete, lead, or other solid walls) or placing the gauge within an 

enclosure to prevent access to higher radiation levels are examples of engineering controls 

(see Figure 8-4).
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Figure 8-4. Limiting Public Dose. When dose rates in an area are high enough that a 

member of the public could receive a dose in excess of 0.02 mSv [2 mrem] in any 

one hour or 1 mSv [100 mrem] in a year, licensees must take additional measures 

to prevent public access to these higher dose rates, such as building enclosures 

around the gauges.

Public dose can be estimated in areas near the gauge by using radiation levels determined 

during initial surveys and applying the “inverse square” law to evaluate the effect of distance on 

radiation levels and occupancy factors to account for the actual presence of members of the 

public (see Appendix G of this NUREG for an example).

If, after making a public dose estimate, the conditions used to make the evaluation change 

(e.g., there are changes to the location of gauges, changes to the type or frequency of gauge 

use, addition of new gauges, or changes to the occupancy of adjacent areas), then the licensee 

must perform a new evaluation to ensure that the public dose limits are not exceeded and take 

corrective action, as needed.

During NRC inspections, licensees must be able to provide documentation demonstrating, by 

measurement or calculation, that the dose to the individual likely to receive the highest dose 

from the licensed operation does not exceed the annual limit for individual members of the 

public (see Appendix G of this NUREG for examples of methods to demonstrate compliance).

Response from Applicant: No response is required from the applicant in a license application, 

but the NRC will examine this matter during inspections.

8.10.6 Operating, Emergency, and Security Procedures

Regulations: 10 CFR 19.11(a)(3), 10 CFR 20.1101, 10 CFR 20.1801, 10 CFR 20.1802, 

10 CFR 20.2201–2203, 10 CFR 20.2207, 10 CFR 21.21, 10 CFR 30.50
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Criteria: Each applicant should do the following:

• develop, implement, and maintain operating procedures that contain the following 

elements for each type of fixed gauge:

– instructions for using the gauge, including use at temporary jobsites if requested 

and authorized on the license (see Section 8.10.10, “Fixed Gauges Used at 

Temporary Job Sites,” for more information on fixed gauges used at temporary 

jobsites)

– instructions for performing routine maintenance according to the manufacturer’s 

recommendations and instructions

– instructions for testing each gauge for the proper operation of the on-off 

mechanism (shutter) and indicator, if any, at intervals not to exceed 6 months or 

as specified in the Sealed Source and Device (SSD) registration certificate

– instructions for lock-out procedures, if applicable, that are adequate to ensure 

that no individual or portion of an individual’s body can enter the radiation beam

– steps to take to keep radiation exposures ALARA

– steps to maintain accountability of gauges (i.e., inventory)

– instructions to ensure that nonroutine operations, such as gauge installation;

initial radiation survey; repair and maintenance of components related to the 

radiological safety of the gauge; gauge relocation; replacement and disposal of 

sealed sources; gauge alignment; or removal of a gauge from service, are 

performed by the manufacturer, distributor, or person specifically authorized by 

the NRC or an Agreement State

– steps to ensure that radiation warning signs are visible and legible

– instructions for transporting radioactive material to ensure compliance with DOT 

regulations, if the applicant will be transporting gauges to temporary jobsites

• develop, implement, and maintain emergency procedures for gauge malfunction or 

damage that contain the following elements for each type of fixed gauge:

– instructions for how to stop the use of the gauge

– instructions for restricting access to the area

– contact information for safety/emergency personnel (telephone numbers for the 

RSO, AUs, the gauge manufacturer or distributor, fire department, or other 

emergency response organization)

– guidelines for reporting to the NRC pursuant to 10 CFR 20.2202, “Notification of 

incidents”, 10 CFR 20.2203, “Reports of exposures, radiation levels, and 

concentrations of radioactive material exceeding the constraints or limits”,
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10 CFR 21.21, “Notification of failure to comply or existence of a defect and its 

evaluation”, and/or 10 CFR 30.50, “Reporting requirements”

– descriptions of additional actions or precautions based on the specific situation

– guidelines to follow when a gauge is involved in a transportation accident, if the 

license authorizes temporary jobsites

• develop, implement, and maintain security procedures to prevent theft, loss, or sabotage 

that contain the following elements:

– instructions to prevent unauthorized access, removal, or use of fixed gauges, 

including at temporary jobsites if authorized on the license

– requirements for reporting to the NRC pursuant to 10 CFR 20.2201, “Reports of 

theft or loss of licensed material,” and 10 CFR 20.2207, “Reports of transactions 

involving nationally tracked sources,” as appropriate

– guidelines to meet the security requirements of 10 CFR 20.1801, “Security of 

stored material”, 10 CFR 20.1802, “Control of material not in storage”, and any 

other applicable security requirements

– if a licensee possesses or uses an aggregated Category 1 or Category 2 quantity 

of radioactive material listed in Appendix A to 10 CFR Part 37 at any site, 

procedures should be developed that ensure the physical protection of the 

radioactive material (See Section 8.10.11, “Security Program for Category 1 and 

Category 2 Radioactive Materials”). 

• provide copies of operating, emergency, and security procedures to all gauge users and 

have them available at each site.

• post copies of operating and emergency procedures at each location of use, or if posting 

procedures is not practicable, post a notice that briefly describes the procedures and 

states where they may be examined.

Discussion: Applicants must develop, implement, and maintain operating and emergency 

procedures that will be reviewed by the NRC during inspections. The NRC will permit an 

applicant greater flexibility when licensing certain types of gauges. For each gauge that is 

requested, if one or more of the following safety conditions are met, the applicant need not

submit these procedures for NRC review during the licensing process:

• the air gap between the radiation source and detector of the device is less than 

45 centimeters [18 inches]

• the air gap of the device would not allow insertion of a 30-centimeter [12-inch] diameter 

sphere into the radiation beam of the device without removal of a barrier

• the radiation dose rate in the radiation beam of the device at 45 centimeters [18 inches]

from the radiation source with the device shutters, if any, in the open position does not 

exceed 1 mSv per hour [0.1 rem per hour]
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• entry into vessels (e.g., bins, tanks, hoppers, or pipes) with a gauge installed is not 

necessary under any foreseeable circumstances and is prohibited

If the requested gauge does not meet any of the safety conditions outlined previously, then the 

applicant must submit its procedures to the NRC for review during the licensing process.

Operating, emergency, and security procedures should be developed, maintained, and 

implemented to ensure that gauges are used only as they were designed to be used, control 

and accountability are maintained, and radiation doses received by occupational workers and 

members of the public are ALARA.

Improper operation could lead to the damage or malfunction of a gauge and elevated exposure 

rates in the gauge’s immediate vicinity. A list of specific items that should be addressed in 

operating, emergency, and security procedures is contained in Appendix H of this NUREG. 

Figure 8-5 illustrates a proper response to a fire involving a fixed gauge. Emergency 

procedures should be developed to address a spectrum of incidents (e.g., fire, explosion, 

mechanical damage, flood, or earthquake).
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Figure 8-5. Proper Handling of Incident. Licensee personnel implement emergency 

procedures when a fire melts the lead shielding of a gauge, producing the 

potential for elevated exposure levels.

The NRC considers the security of licensed material to be extremely important, and lack of 

security is a significant violation for which licensees may be fined. Although most fixed gauges 

are difficult to move, the licensee must prevent unauthorized access, removal, or use of the 

gauge. Licensees are responsible for ensuring that gauges are secured and accounted for at all 

times (e.g., during plant modifications, change in ownership, staffing changes, or after 

termination of activities at a particular location).
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The NRC must be notified when gauges are lost or stolen or certain other conditions occur.

The RSO should be proactive in evaluating whether NRC notification is required. Refer to 

Appendix L and the relevant regulations (i.e., 10 CFR 20.2201–20.2203, 10 CFR 20.2207, 

10 CFR 21.21, and 10 CFR 30.50) for a description of when and where notifications 

are required.

Figure 8-6. Lock-Out Procedures. Typical lock-out procedures include locking the shutter 

into the “off” position and tagging the shutter control mechanism to indicate the 

gauge is locked out.

When the distance or air gap between the source and detector permits entry of all or a portion of 

a person’s body into the primary radiation beam, licensees must develop lock-out procedures

(See Figure 8-6). Lock-out procedures encompass locking the “on”-“off” or shutter mechanism 

into the “off” position or otherwise controlling the radiation beam or using any other means of 

preventing an individual or a portion of an individual’s body from entering the radiation beam 

during maintenance, repairs, or work in, on, or around the process line (e.g., bin, tank, hopper, 

pipe, or conveyor belt) where the device is mounted. The “on”-“off” or shutter control 

mechanism should be tagged to indicate that the gauge is locked out. A warning sign should be 

posted at each entryway to an area where it is possible to be exposed to the radiation beam. In 

addition to providing a warning, the sign should give safety instructions (e.g., “contact the RSO 

before entering this vessel”). Lock-out procedures should specify who is responsible for 

performing them.

Response from Applicant: Provide one of the following:

• If the gauge meets one or more of the safety conditions specified in “Discussion,” 

provide the statement: “Operating, emergency, and security procedures will be 

developed, implemented, maintained, and distributed, and will meet the criteria in 

Section 8.10.6, ‘Operating, Emergency, and Security Procedures’ in NUREG–1556, 
8-26

Volume 4, Revision 1, ‘Consolidated Guidance About Materials Licenses: ProgramSpecific Guidance About Fixed Gauge Licenses.’”

OR

• If the gauge does not meet any of the safety conditions specified in “Discussion,” provide 

your operating, emergency, security, and lock-out (if applicable) procedures.

Note: When developing operating, emergency, and security procedures, applicants should 

consider the information contained in the following documents describing incidents involving 

fixed gauges:

• IN 81-37, Revision 1, “Unnecessary Radiation Exposures to the Public and 

Workers During Events Involving Thickness and Level Measuring Devices,” 

dated February 9, 1982

• IN 86-31, “Unauthorized Transfer and Loss of Control of Industrial Nuclear Gauges,” 

dated May 5, 1986 

• IN 88-02, “Lost or Stolen Gauges,” dated February 2, 1988

• IN 88-90, “Unauthorized Removal of Industrial Nuclear Gauges,” 

dated November 22, 1988 

• IN 94-15, “Radiation Exposures During an Event Involving a Fixed Nuclear Gauge,” 

dated March 2, 1994

• IN 2009-05, “Contamination Events Resulting From Damage to Sealed Radioactive 

Sources During Gauge Dismantlement and Non-Routine Maintenance Operations,” 

dated February 3, 2009

• IN 2011-09, “Fixed Gauge Shutter Failures Due to Operating in Harsh Working 

Environments,” dated May 18, 2011

8.10.7 Leak Tests

Regulations: 10 CFR 20.1501, 10 CFR 20.2103, 10 CFR 30.50(c)(2), 10 CFR 30.53

Criteria: The NRC requires testing to determine whether there is any radioactive leakage from 

the source in the fixed gauge. The NRC finds leak testing to be acceptable if it is conducted by 

an organization licensed by the NRC or an Agreement State. Licensees must maintain records 

of leak test results in accordance with license requirements and NRC regulations.

Discussion: When issued, a license will require the performance of leak tests at intervals

approved by the NRC or an Agreement State, as specified in the device’s SSD registration 

certificate or at a more frequent interval that the licensee committed to in its license application. 

The measurement of the leak test sample is a quantitative analysis that requires instrumentation 

capable of detecting 185 becquerels [0.005 microcuries] of radioactivity. If the test reveals the 

presence of 185 Bq [0.005 microcurie] or more of removable contamination, a report should be 

filed with the NRC in accordance with 10 CFR 30.50(c)(2).
8-27

Manufacturers, distributors, consultants, and other organizations may be authorized by the NRC 

or an Agreement State to either perform the entire leak test process for other licensees or 

provide leak test kits to licensees. In the latter case, the licensee is expected to take the leak 

test sample according to the gauge manufacturer’s and the kit supplier’s instructions and return 

it to the kit supplier for analysis and reporting results. Leak test samples should be collected at 

the most accessible area where contamination would accumulate if the sealed source were 

leaking. The NRC or an Agreement State may, in a license condition, specifically authorize 

portable gauge licensees to conduct the entire leak test sequence themselves. Appendix I of 

this NUREG provides information to support a request to perform leak testing and sample 

analysis.

Response from Applicant: Provide one of the following:

• the statement: “Leak tests will be performed at intervals approved by the NRC or an 

Agreement State and specified in the Sealed Source and Device registration certificate. 

Leak tests will be performed by an organization licensed by the NRC or an Agreement 

State to provide leak testing services to other licensees; or by using a leak test sample 

collection kit supplied by an organization licensed by the NRC or an Agreement State to 

provide leak test kits and/or sample analysis services to other licensees and according 

to the kit supplier’s instructions. Records of leak test results will be maintained.”

OR

• the statement: “We will implement the model leak test program in Appendix I of 

NUREG–1556, Volume 4, Revision 1, ‘Consolidated Guidance About Materials 

Licenses: Program-Specific Guidance About Fixed Gauge Licenses.’ Records of leak 

tests will be maintained.”

OR

• a description of alternative equipment and/or procedures for determining whether there 

is any radioactive leakage from sources contained in gauges and the statement: 

“Records of leak tests will be maintained.”

Note: Requests for authorization to perform leak testing and sample analysis will be reviewed 

on a case-by-case basis and, if approved, will be authorized via a license condition.

8.10.8 Maintenance

Regulations: 10 CFR 20.1101, 10 CFR 30.34(e)

Criteria: Licensees should routinely clean and maintain gauges according to the 

manufacturer’s or distributor’s written recommendations and instructions. Individuals performing 

routine maintenance must have adequate training and experience. Radiation safety procedures 

for routine cleaning and maintenance (e.g., removal of exterior residues from the gauge 

housing, shutter operation checks, external lubrication of shutter mechanism, calibration, and 

electronic repairs) must consider ALARA principles and ensure that the gauge functions as 

designed and source integrity is not compromised.
8-28

“Nonroutine maintenance or repair” (beyond routine cleaning, lubrication, calibration, and 

electronic repairs) means any maintenance or repair that involves or potentially affects 

components, including electronics, related to the radiological safety of the gauge (e.g., the 

source, source holder, source drive mechanism, shutter, shutter control, or shielding) and any 

other activities during which personnel could receive radiation doses exceeding the NRC’s 

regulatory dose limits.

Specific authorization by the NRC or an Agreement State is required to perform nonroutine 

maintenance and repair of fixed gauges. Typically, fixed gauge manufacturers, distributors, and 

other service providers are specifically authorized to perform such operations. Fixed gauge 

licensees that have received specific authorization from the NRC or an Agreement State may

perform nonroutine activities. Appendix J of this NUREG presents information to support 

requests for specific authorization to perform nonroutine maintenance or repair.

Figure 8-7. Maintenance. Licensees need to perform routine maintenance to ensure proper 

operation of the fixed gauge. For nonroutine maintenance, most licensees use 

or contract the services of the gauge manufacturer, distributor, or a service 

company.

Discussion: The NRC allows fixed gauge licensees to perform routine maintenance of the 

gauges. Licensees should follow the gauge manufacturer’s or distributor’s written 

recommendations and instructions provided with the gauge(s). Generally, before any 

maintenance or repair work is done, licensees need to determine (and assure themselves of the 

adequacy of) the following:

• the tasks to be performed

• the protocol or procedures to be followed

• the radiation safety procedures including possible need for compensatory measures 

(i.e., steps taken to compensate for lack of or reduced shielding)

• ALARA considerations
8-29

• training and experience of personnel performing the work

• instructions for lock-out procedures

• the qualification of parts, components, and other materials to be used in the gauge

• the tests to be performed before the gauge is returned to routine use to ensure that it 

functions as designed

Although manufacturers or distributors may use different terms, “routine maintenance” includes, 

but is not limited to, cleaning, lubricating, and calibrating the gauge and making electronic 

repairs. Routine maintenance also includes testing the proper operation of the gauge’s 

“on”-“off” mechanism (i.e., shutter checks) and indicator at intervals not to exceed 6 months or 

as specified in the SSD registration certificate. A standard license condition in all fixed gauge 

licenses imposes this requirement. Two NRC INs discuss the importance of performing shutter 

checks: (1) IN 2009-18, “Performance of Required Shutter Checks and Reporting of Gauge 

Shutter Failures,” dated September 18, 2009, and (2) IN 2011-09, “Fixed Gauge Shutter 

Failures Due to Operating in Harsh Working Environments,” dated May 18, 2011. 

Routine maintenance does not include any activities that involve:

• components, including electronics, related to the radiological safety of the gauge 

(e.g., the source, source holder, source drive mechanism, shutter, shutter control 

or shielding)

• installation, relocation, or alignment of the gauge

• initial radiation surveys

• replacement and disposal of sealed sources

• removal of a gauge from service

• a potential for any portion of the body to come into contact with the primary 

radiation beam

• any other activity during which personnel could receive radiation doses exceeding the 

NRC’s regulatory dose limits

Mounting a gauge is unpacking or uncrating the gauge and fastening, hanging, or affixing the 

gauge into position before using. Mounting does not include electrical connection, activation, or 

operation of the gauge. Installing a gauge includes mounting, electrical connection, activation, 

and first use of the device. Specific NRC or Agreement State authorization in a license is 

required to install a gauge; however, a licensee may initially mount a gauge, without specific 

NRC or Agreement State authorization, if the gauge’s SSD registration certificate explicitly 

permits it. The conditions under which a licensee may initially mount a gauge will be specified 

in the license as a standard license condition if the licensee is not specifically authorized to 

install a gauge. The source must remain fully shielded, and the gauge may not be used until it 

is installed and made operational by a person or entity specifically licensed by the NRC or an 

Agreement State to perform such operations.
8-30

A condition in the NRC license will state that operations, such as gauge installation; initial 

radiation survey; repair and maintenance of components related to the radiological safety of the 

gauge; gauge relocation; replacement and disposal of sealed sources; gauge alignment; or 

removal of a gauge from service, may be performed only by the manufacturer, distributor, or 

other persons specifically licensed by the NRC or an Agreement State to perform such services. 

Most licensees do not perform nonroutine operations. Rather, these licensees use or contract 

the services of other licensees that have the specialized equipment and the technical expertise 

needed to perform these activities. Applicants seeking authorization to perform nonroutine 

operations must submit specific procedures for review. See Appendix J of this NUREG for more 

information.

Response from Applicant:

For routine maintenance: Submit either of the following:

• the statement: “We will implement and maintain procedures for routine maintenance of 

our gauges according to each manufacturer’s or distributor’s written recommendations 

and instructions.”

OR

• alternative procedures for NRC review

For nonroutine operations: Submit either of the following:

• the statement: “The gauge manufacturer, distributor, or other person licensed by the 

NRC or an Agreement State will perform nonroutine operations such as installation, 

initial radiation survey, repair and maintenance of radiological safety components, 

relocation, replacement, alignment, removal from service, and disposal of 

sealed sources.”

OR

• a request to perform this work “in-house,” using the information in Appendix J of this 

NUREG to support the request

Notes:

• Alternative procedures for performing routine maintenance will be evaluated using the 

criteria listed previously.

• Information requested in Appendix J of this NUREG will be reviewed on a case-by-case 

basis; if the request is approved, the license will contain a specific condition authorizing 

the licensee to perform nonroutine operations.

8.10.9 Transportation

Regulations: 10 CFR 20.1101, 10 CFR 71.5, 49 CFR Parts 171–178, 390–397

Criteria: Applicants must follow DOT regulations for the offsite transport of radioactive material.
8-31

Discussion: Some fixed gauge licensees have the manufacturer, distributor, or another 

licensee arrange for preparing and shipping licensed material. If licensees decide to transport 

their own gauges, they are responsible for compliance with DOT regulations, including 

hazardous material (HAZMAT) employee training.

Figure 8-8 illustrates some important DOT requirements for gauge licensees. The NRC uses 

the provisions of 10 CFR 71.5, “Transportation of licensed material,” to examine and enforce 

transportation requirements found in 49 CFR, “Transportation.” Appendix K of this NUREG lists 

applicable DOT regulations.

Figure 8-8. DOT Transportation Requirements

Response from Applicant: No response is needed; the NRC will review this issue during 

inspection.

Reference: “Radioactive Material Regulations Review,” published by DOT, Pipeline and 

Hazardous Materials Safety Administration, in December 2008 (can be obtained at 

http://www.phmsa.dot.gov)

8.10.10 Fixed Gauges Used at Temporary Job Sites

Regulations: 10 CFR 20.1101, 10 CFR 20.1801, 10 CFR 20.1802, 10 CFR 20.2201–2203, 

10 CFR 30.34(e), 10 CFR 30.50

Criteria: Each applicant requesting authorization to perform work with fixed gauges at 

temporary jobsites must develop, implement, and maintain operating, emergency, and security 

procedures, as described in Section 8.10.6, “Operating, Emergency, and Security Procedures,”

and provide copies of those procedures to all gauge users and at each jobsite.

Discussion: A temporary jobsite is a location where work with licensed materials is conducted 

for a limited period of time. Temporary jobsites are not specifically listed on a license. A gauge 

user may be dispatched to work at several temporary jobsites in one day. A location is not 

considered a temporary jobsite if it is used to store and dispatch licensed material. The NRC 
8-32

considers such a location to be a field office. Licensees must apply for and receive a license 

amendment specifically listing each field office location.

There are two primary categories of fixed gauges used at temporary jobsites: (1) gauges that 

are permanently mounted to vehicles or trailers and (2) gauges that are transported to industrial 

facilities and temporarily installed on process equipment to conduct short-term quality 

assurance and/or quality control studies (see Figure 8-9). The NRC also handles the licensing 

of sealed sources used for industrial diagnostic scanning at facilities and mobile nonintrusive 

scanning systems in the same manner as fixed gauges. These applications of radioactive 

materials may also be used at temporary jobsites.

Figure 8-9. Examples of Uses for Fixed Gauges at Temporary Job Sites

When working at a temporary jobsite, licensees generally have to follow the rules and 

procedures of the organization that owns or controls the site. Thus, licensees may not be able 

to restrict access to areas in the same manner that they can at their own facilities. Furthermore, 

nonlicensee personnel may not be familiar with fixed gauges or radioactive material. Therefore, 

to avoid lost or stolen gauges and to prevent unnecessary radiation exposures to members of 

the public, licensees must keep gauges under constant surveillance or secured against 

unauthorized use or removal (see Figure 8-10).
8-33

Figure 8-10. Security. Examples of Methods Used To Secure and Control Fixed Gauges at 

Temporary Job Sites.

While installing gauges at a temporary jobsite, personnel could receive radiation doses 

exceeding NRC limits if they do not follow proper radiation safety principles. Licensee 

personnel performing installations should be assigned and wear dosimetry and must use a 

survey meter to monitor radiological conditions (see Figure 8-11).

Figure 8-11. Installation of Fixed Gauges at Temporary Job Sites. Examples of the 

Additional Precautions Needed When Installing Fixed Gauges at Temporary 

Job Sites.
8-34

After installing a gauge at a temporary jobsite, a radiation survey must be conducted to ensure 

that doses in unrestricted areas will not exceed 0.02 mSv [2 mrem] in any one hour or 1 mSv 

[100 mrem] in a year. If surveys indicate that a member of the public (e.g., client personnel) 

could receive a dose exceeding these limits, licensees would need to implement additional 

measures to prevent public access, such as maintaining constant surveillance or erecting 

physical barriers.

Response from Applicant: Submit one of the following:

• the statement: “We will not use fixed gauges at temporary jobsites.”

OR

• the statement: “We will address the use of fixed gauges at temporary jobsites in our 

operating, emergency, and security procedures developed in accordance with the 

Criteria in Section 8.10.6 ‘Operating, Emergency, and Security Procedures,’ of 

NUREG–1556, Volume 4, Revision 1, ‘Consolidated Guidance About Materials 

Licenses: Program-Specific Guidance About Fixed Gauge Licenses.’ Copies of these 

procedures will be provided to all gauge users and will be available at all temporary 

jobsites.”

8.10.11 Security Program for Category 1 and Category 2 Radioactive Material

Regulations: 10 CFR Part 37, 10 CFR 20.2207

Criteria: Licensees must ensure the security of Category 1 and Category 2 radioactive 

material.

Note: The regulations in 10 CFR Part 37 apply to licensees that possess an aggregated

Category 1 or Category 2 quantity of radioactive material, as specified in Appendix A to 10 CFR 

Part 37. The requirements in 10 CFR 20.2207 for submitting National Source Tracking 

Transaction Reports (NSTTR) are applicable to those licensees that manufacture, transfer, 

receive, disassemble, or dispose of sealed sources containing a quantity equal to or greater 

than the Category 1 or Category 2 levels of radioactive material listed in Appendix E to 10 CFR 

Part 20.

Discussion: 

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

of Radioactive Material”

In accordance with 10 CFR Part 37, licensees authorized to possess Category 1 or Category 2 

quantities of radioactive material must establish, implement, and maintain a security program to 

ensure physical protection of the radioactive material. 

Table 1 of Appendix A, “Category 1 and Category 2 Radioactive Materials,” to 10 CFR Part 37, 

lists Category 1 and Category 2 threshold quantities of radioactive material. The applicant 

should refer to this table to determine whether its proposed activities would be subject to the 10 

CFR Part 37 requirements.
8-35

Licensees authorized to hold Category 1 or Category 2 quantities of radioactive material must 

establish access authorization programs in accordance with 10 CFR Part 37, Subpart B. Before 

giving individuals unescorted access to such quantities of radioactive material, licensees must 

conduct prior background investigations of these individuals in accordance with 10 CFR 37.25. 

In accordance with 10 CFR 37.41(b), licensees must establish a security program designed to 

monitor and, without delay, detect, assess, and respond to any actual or attempted efforts to 

gain unauthorized access to Category 1 or Category 2 quantities of radioactive material. 

Per 10 CFR Part 37, Subpart D, licensees must provide for physical protection of Category 1 or 

Category 2 quantities of radioactive materials in transit. These requirements apply to licensees 

delivering such material to a carrier for transport, as well as cases in which licensees are 

transporting such material. Please note that the Subpart D requirements applicable to the 

transport of Category 1 quantities of radioactive material are more stringent than those 

applicable to Category 2 quantities.

Applicants and licensees are required to implement the 10 CFR Part 37 security requirements 

before they take possession of an aggregated Category 1 or Category 2 quantity of radioactive 

material.

In accordance with 10 CFR 37.41(a)(3), any licensee that has not previously implemented the 

Security Orders (i.e., orders issued by the NRC to require licensees to implement interim 

security measures) or been made subject to the provisions of 10 CFR Part 37, Subpart C shall 

notify the NRC regional office specified in 10 CFR 30.6 in writing at least 90 days before 

aggregating radioactive material to a quantity that equals or exceeds the Category 2 threshold.

For additional guidance on implementing 10 CFR Part 37 requirements, see NUREG–2155, 

“Implementation Guidance for 10 CFR Part 37, ‘Physical Protection of Category 1 and 

Category 2 Quantities of Radioactive Material’.” Additional information regarding best practices 

for protection of risk-significant radioactive material is available in NUREG–2166, “Physical 

Security Best Practices for the Protection of Risk-Significant Radioactive Material.”

Requirements in 10 CFR 20.2207, “Reports of transactions involving nationally tracked sources”

The regulations in 10 CFR 20.2207 require that each licensee that manufactures, transfers, 

receives, disassembles, or disposes of a nationally tracked source shall complete and submit an 

NSTTR to the NRC. The NSTTRs are maintained in the National Source Tracking System

(NSTS), a secure computer system that tracks high-risk radioactive sources from the time they 

are manufactured or imported through the time of their disposal or export, or until the source 

activity decays enough to no longer be of concern.

Response from Applicant: No response is required from an applicant or licensee. 

Note: In relation to security events involving a Category 1 or Category 2 quantity of radioactive 

material, notifications to the local law enforcement agency and the NRC, as well as subsequent 

reports to the NRC, must be made in accordance with 10 CFR 37.57 and 10 CFR 37.81, as 

appropriate.

8.11 Item 11: Waste Management—Gauge Disposal and Transfer

Regulations: 10 CFR 20.2001, 10 CFR 20.2207, 10 CFR 30.36, 10 CFR 30.41, 10 CFR 30.51
8-36

Criteria: Licensed materials must be disposed of in accordance with NRC requirements by 

transfer to an authorized recipient. Appropriate records must be maintained.

Discussion: Significant problems can arise from improper gauge transfer or failure to dispose 

of gauges in a proper and timely manner. Such problems include the possession of radioactive 

materials by unauthorized individuals, which could result in exposures to members of the 

general public. When disposing of fixed gauges, licensees must transfer them to an authorized 

recipient. Authorized recipients are the original manufacturer or distributor of the device, a 

commercial firm licensed by the NRC or an Agreement State to accept radioactive waste from 

other persons, or another specific licensee authorized to possess the licensed material 

(i.e., their license specifically authorizes the same manufacturer, model, isotope(s), and quantity 

of byproduct material).

Before transferring radioactive material, the licensee must verify that the recipient is properly 

authorized to receive the licensed material using one of the methods described in 

10 CFR 30.41, “Transfer of byproduct material.” In addition, all packages containing radioactive 

sources must be prepared and shipped in accordance with NRC and DOT regulations. The 

licensee must maintain records of the transfer, as required by 10 CFR 30.51, “Records.”

If source activity exceeds activities listed in Appendix E to 10 CFR Part 20, the transfer 

transaction must be reported in accordance with 10 CFR 20.2207.

Response from Applicant: The applicant does not need to provide a response to this item 

during the licensing process. However, the licensee should establish and include gauge 

transfer and waste disposal procedures in its radiation safety program.

References: See IN 86-31 and IN 88-02. INs are available in the “NRC Library” on the NRC’s 

home page at http://www.nrc.gov.

8.12 Item 12: License Fees

On NRC Form 313, enter the appropriate fee category from 10 CFR 170.31 and the amount of 

the fee enclosed with the application.

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

the Office of the Chief Financial Officer at NRC Headquarters in Rockville, MD, 

301-415-7554. Information about fees may also be obtained by calling the NRC’s toll-free 

number, 800-368-5642, extension 415-7554. The e-mail address for fees questions is 

Fees.Resource@nrc.gov.

8.13 Item 13: Certification

A representative of the corporation or legal entity filing the application must sign and date NRC 

Form 313. The representative signing the application must be authorized to make binding 

commitments and to sign official documents on behalf of the applicant. As discussed previously 

in Chapter 3, “Management Responsibility,” signing the application acknowledges

management’s commitment to and responsibility for the radiation protection program. The NRC 

will return all unsigned applications for proper signature.
8-37

Notes:

• It is a criminal offense to knowingly and willfully make a false statement or 

representation on applications or correspondence (18 U.S.C. 1001).

• When the application references commitments, those items will be incorporated into the 

license and therefore will become binding regulatory requirements.

9-1

9 LICENSE AMENDMENTS AND RENEWALS

It is the licensee’s obligation to keep the license current. If any of the information provided in 

the original application is to be modified or changed, the licensee must submit an application for 

a license amendment before the change takes place. The change is not in effect until the 

amendment has been issued. Also, to continue the license after its expiration date, the licensee 

must submit an application for a license renewal at least 30 days before the expiration date 

(Title 10 of the Code of Federal Regulations (10 CFR) [10 CFR 2.109(a), 10 CFR 30.36(a)].

Applicants for license amendment or renewal should do the following:

• Use the most recent guidance in preparing an amendment or renewal request.

• Submit either a U.S. Nuclear Regulatory Commission (NRC) Form 313 or a letter 

requesting amendment or renewal.

• Provide the license number and docket number.

• For renewals, provide a complete and up-to-date application, including all required 

program elements outlined in Appendix B of this NUREG. Training documentation for 

personnel currently listed on the license does not need to be submitted as part of the 

renewal application.

9.1 Timely Notification of Transfer of Control

Regulation: 10 CFR 30.34(b)

Criteria: Licensees must provide all supporting information and obtain the NRC’s prior, written 

consent before transferring control of the license, also referred to as a “change of ownership” 

and/or “transferring the license.”

Discussion: Transferring control may be the result of mergers, buyouts, or majority stock 

transfers. Although it is not the NRC’s intent to interfere with the business decisions of 

licensees, it is necessary for licensees to obtain prior NRC written consent to ensure 

the following:

• radioactive materials are possessed, used, or controlled only by persons who have valid 

NRC licenses or Agreement State licenses

• materials are properly handled and secured

• persons using these materials are capable, competent and committed to implementing 

appropriate radiological controls

• a clear chain of custody is established to identify who is responsible for disposition of 

records and licensed material

• public health and safety are not compromised by the use of such materials

Response from Applicant: No response is required from an applicant for a new license. 

However, current licensees should refer to NUREG–1556, Volume 15, “Consolidated Guidance 
9-2

About Materials Licenses: Guidance About Changes of Control and About Bankruptcy Involving 

Byproduct, Source, or Special Nuclear Materials Licenses,” for more information about transfer 

of control (i.e., ownership).

Reference: For further information, see Regulatory Issue Summary (RIS) 2014-08, Revision 1, 

“Regulatory Requirements for Transfer of Control (Change of Ownership) of Specific Materials 

Licenses,” dated May 5, 2016, which can be found on the NRC’s Generic Communications Web

page under “Regulatory Issue Summaries”: http://www.nrc.gov/reading-rm/doc-collections/gencomm/ 
10-1

10 APPLICATIONS FOR EXEMPTIONS

Regulations: 10 CFR 19.31, 10 CFR 20.2301, 10 CFR 30.11

Criteria: Licensees may request exemptions from U.S. Nuclear Regulatory Commission (NRC) 

regulations. The licensee must demonstrate that the exemption is authorized by law; will not 

endanger life, property, or the common defense and security; and is otherwise in the public 

interest.

Discussion: Various sections of the NRC’s regulations address requests for exemptions [e.g.,

10 CFR 19.31, “Application for exemptions”; 10 CFR 20.2301, “Applications for exemptions”; 

10 CFR 30.11, “Specific exemptions”]. These regulations state that the NRC may grant an 

exemption, acting on its own initiative or on an application from an interested person.

Exemptions are not intended to revise regulations or apply to large classes of licensees and are 

generally limited to unique situations. Requests for exemptions submitted to the NRC must 

identify the regulation for which the exemption is being requested and include a justification for 

the requested exemption.

Unless the NRC has granted an exemption in writing, licensees must comply with all 

applicable regulations.

11-1

11 TERMINATION OF ACTIVITIES

Regulations: 10 CFR 30.34(b), 10 CFR 30.35(g), 10 CFR 30.36(d), 10 CFR 30.36(h), 

10 CFR 30.36(j)(1), 10 CFR 30.51(f)

Criteria: The licensee must do the following:

• Notify the U.S. Nuclear Regulatory Commission (NRC), in writing, within 60 days of the 

occurrence of any of the following:

– expiration of its license

– a decision to permanently cease principal activities1 at the entire site

– a decision to permanently cease principal activities1 in any separate building or 

outdoor area that contains residual radioactivity such that the building or area is 

unsuitable for release according to NRC requirements

– no principal activities1 under the license have been conducted for a period of 

24 months

– no principal activities1 have been conducted for a period of 24 months in any 

separate building or outdoor area that contains residual radioactivity such that 

the building or area is unsuitable for release according to NRC requirements

• Conduct decommissioning, as required by Title 10 of the Code of Federal Regulations 

(10 CFR) 30.36(h).

• Submit, to the appropriate NRC regional office, a completed NRC Form 314, “Certificate 

of Disposition of Materials” (or equivalent information), and information demonstrating 

that the premises are suitable for release for unrestricted use (e.g., results of final leak 

tests of sealed sources).

• Before a license is terminated, send records important to decommissioning that are 

required by 10 CFR 30.35(g) to the appropriate NRC regional office in accordance with 

10 CFR 30.51(f).

Discussion: Typically, a fixed gauge termination request will meet the previously listed criteria 

if the licensee has performed the following steps:

• The licensee must dispose of or transfer the gauges to an NRC or Agreement State 

licensee authorized to possess these devices, as described in Section 8.11, “Waste 

Management—Gauge Disposal and Transfer.”

• The licensee must copy applicable decommissioning records as described in Section 

8.5.2, “Financial Assurance and Recordkeeping for Decommissioning.” Typically, this 

includes transfer of records and final leak test records to the appropriate NRC regional 

 1 ‘Principal activities’ are activities which are essential to achieving the purpose(s) for which the license was issued or 

amended. Storage during which no licensed material is accessed for use or disposal and activities incidental to 

decontamination or decommissioning are not principal activities.
11-2

office. See Section 8.5.2 for additional recordkeeping requirements if leaking sealed 

sources or other incidents that involve the spreading of contamination have occurred.

• The licensee must submit a completed NRC Form 314 and a copy of the applicable 

decommissioning records to the appropriate NRC regional office.

Response from Applicant: The applicant is not required to submit a response to the NRC 

during the initial application. The licensee’s obligations in this matter begin when the license 

expires or at the time the licensee ceases operations, whichever is earlier. These obligations 

are to undertake the necessary decommissioning activities, to submit NRC Form 314 or 

equivalent information, and to perform any other actions summarized in the previously listed 

“Criteria.”

Reference: NRC Form 314 is available at http://www.nrc.gov/reading-rm/doc-collections/forms.
APPENDIX A

U.S. NUCLEAR REGULATORY COMMISSION FORM 313

A–1

U.S. NUCLEAR REGULATORY COMMISSION FORM 313

Please use the most current version of this form, which may be found at:

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

APPENDIX B

SUGGESTED FORMAT FOR PROVIDING INFORMATION REQUESTED IN 

ITEMS 5 THROUGH 11 OF 

U.S. NUCLEAR REGULATORY COMMISSION FORM 313

B–1

SUGGESTED FORMAT FOR PROVIDING INFORMATION REQUESTED IN

ITEMS 5 THROUGH 11 OF

U.S. NUCLEAR REGULATORY COMMISSION FORM 313

Items 5 and 6: Materials To Be Possessed and Proposed Uses

Yes No Radionuclide Manufacturer

or Distributor 

Model No.

Quantity Use as Listed on 

SSD Registration 

Certificate

Specify Other 

Uses Not Listed 

on SSD 

Registration 

Certificate

Isotope 

(Specify):

Device 

manufacturer (or 

distributor) and 

model number:

______________

Specify activity 

per source and 

number of 

gauges 

requested. 

Yes ❒

Specific 

description of the 

gauge use:

______________

______________

______________

______________

______________

______________

______________

❒ Not applicable

❒ Uses are:

(Submit safety 

analysis 

supporting safe 

use)

Isotope 

(Specify):

Device 

manufacturer (or 

distributor) and 

model number:

______________

Specify activity 

per source and 

number of 

gauges 

requested.

Yes ❒

Specific 

description of the 

gauge use:

______________

______________

______________

______________

______________

______________

______________

❒ Not applicable

❒ Uses are:

(Submit safety 

analysis 

supporting safe 

use)

Isotope 

(Specify):

Device 

manufacturer (or 

distributor) and 

model number:

______________

Specify activity 

per source and 

number of 

gauges 

requested.

Yes ❒

Specific 

description of the 

gauge use:

______________

______________

______________

______________

______________

______________

______________

❒ Not applicable

❒ Uses are:

(Submit safety 

analysis 

supporting safe 

use)

Is financial assurance required? If yes, submit evidence of financial assurance.

NOTE: Copy and attach additional pages as needed.
B–2

Items 7 through 11: Training and Experience, 

Facilities and Equipment, Radiation Safety Program, 

and Waste Disposal

Item No. and Title Suggested Response Yes Alternative 

Procedures Attached

7. Individual(s) 

Responsible For 

Radiation Safety 

Program and 

Their Training 

and Experience

7.1 Radiation safety 

officer

Name: __________

Documentation demonstrating the proposed 

radiation safety officer’s training and 

experience (e.g., certificate of completion of 

the RSO’s course and/or the authorized 

user’s course).

Submit applicable documentation.

7. Individual(s) 

Responsible For 

Radiation Safety 

Program and 

Their Training 

and Experience

7.2 Authorized 

users

Before using licensed materials, authorized 

users will have successfully completed one of 

the training courses described in the “Criteria”

part of the section titled, “Authorized Users” in 

NUREG-1556, Volume 4, Revision 1, 

“Consolidated Guidance About Materials 

Licenses: Program-Specific Guidance About 

Fixed Gauge Licenses.”

❒ ❒

8. Training for 

Individuals 

Working In or 

Frequenting 

Restricted 

Areas

The applicant is not required to and should 

not submit its training program for individuals 

who in the course of employment are likely to 

receive occupational doses of radiation in 

excess of 1 mSv (100 mrem) in a year 

(occupationally exposed workers) and 

ancillary personnel to the NRC for review 

during the licensing phase.

Need not be submitted with 

application.
B–3

Item No. and Title Suggested Response Yes Alternative 

Procedures 

Attached

9. Facilities and 

Equipment

We will ensure that the location of each fixed gauge 

meets the criteria in Section 8.9, “Facilities and 

Equipment,” in NUREG-1556, Volume 4, Revision 

1, “Consolidated Guidance About Materials 

Licenses: Program-Specific Guidance About Fixed 

Gauge Licenses.”

OR

Provide confirmation that the fixed gauge is 

secured to prevent unauthorized removal or 

access, and submit specific information 

demonstrating that the proposed conditions will not 

impact the safety or integrity of the source or 

device. Address any instances in which the 

proposed conditions exceed any conditions listed in 

the SSD registration certificate.

❒

❒

10.1 Radiation 

Safety Program –

Audit Program

The applicant should not submit its audit program 

to the NRC for review during the licensing phase. 

The audit program will be reviewed during NRC 

inspections.

Need not be submitted with 

application.

10.2 Radiation 

Safety Program –

Radiation 

Monitoring 

Instruments

Surveys according to 10 CFR 20.1501 will be 

performed by a person specifically authorized by 

the NRC or an Agreement State to perform these 

surveys.

OR

We will use instruments that meet the criteria in 

Section 8.10.2, “Radiation Monitoring Instruments,” 

in NUREG-1556, Volume 4, Revision 1, 

“Consolidated Guidance About Materials Licenses: 

Program-Specific Guidance About Fixed Gauge 

Licenses” and one of the following two choices:

Each radiation survey meter will be calibrated 

by the manufacturer or other person authorized 

by the NRC or an Agreement State to perform 

radiation survey meter calibrations.

OR

We will implement the model radiation survey 

instrument calibration program in Appendix F, 

“Model Radiation Survey Instrument Calibration 

Program,” in NUREG-1556, Volume 4, 

Revision 1, “Consolidated Guidance About 

Materials Licenses: Program-Specific Guidance 

About Fixed Gauge Licenses.”

❒

❒

❒

❒

❒
B–4

Item No. and Title Suggested Response Yes Alternative 

Procedures 

Attached

10.3 Radiation 

Safety Program –

Material Receipt 

and Accountability

Physical inventories will be conducted every

6 months or at other intervals approved by the NRC 

to account for all sealed sources and devices 

received and possessed under the license.

AND

We will develop, implement, and maintain 

procedures for ensuring accountability of licensed 

materials at all times.

❒ ❒

10.4 Radiation 

Safety Program –

Occupational Dose

We will maintain, for inspection by the NRC, 

documentation demonstrating that unmonitored 

individuals are not likely to receive a radiation dose 

in excess of the limits in 10 CFR 20.1502(a).

OR

We will provide and require the use of individual 

monitoring devices (dosimetry). All personnel 

dosimeters that require processing to determine the 

radiation dose will be processed and evaluated by 

a NVLAP-approved processor.

❒

❒

❒

10.5 Radiation 

Safety Program –

Public Dose

The applicant is not required to submit a response 

to the public dose section in a license application. 

This matter will be examined during NRC 

inspections.

Need not be submitted with 

application.

10.6 Radiation 

Safety Program –

Operating, 

Emergency, and 

Security

Procedures

If the gauge meets one or more of the safety 

conditions specified in the “Discussion” part of 

Section 8.10.6, “Operating, Emergency, and 

Security Procedures,” in NUREG-1556, Volume 4, 

Revision 1, “Consolidated Guidance About 

Materials Licenses: Program-Specific Guidance 

About Fixed Gauge Licenses,” state the following: 

Operating, emergency, and security procedures 

will be developed, implemented, maintained, and 

distributed and will meet the criteria in 

Section 8.10.6, “Operating, Emergency, and 

Security Procedures,” in NUREG-1556, Volume 4, 

Revision 1.

OR

If each gauge requested does not meet any of the 

safety conditions specified in the “Discussion” part 

of Section 8.10.6, “Operating, Emergency, and 

Security Procedures,” in NUREG-1556, Volume 4, 

Revision 1, provide your operating, emergency, 

security, and lock-out (if applicable) procedures.

❒

❒

Procedures 

Attached

❒
B–5

Item No. and Title Suggested Response Yes Alternative 

Procedures 

Attached

10.7 Radiation 

Safety Program –

Leak Tests

Leak tests will be performed at intervals approved 

by the NRC or an Agreement State and specified in 

the SSD registration certificate. Leak tests will be 

performed by an organization licensed by the NRC 

or an Agreement State to provide leak testing 

services to other licensees; or using a leak test 

sample collection kit supplied by an organization 

licensed by the NRC or an Agreement State to 

provide leak test kits and/or sample analysis 

services to other licensees and according to the kit 

supplier’s instructions. Records of leak test results 

will be maintained.

OR

We will implement the model leak test program in 

Appendix I of NUREG-1556, Volume 4, Revision 1, 

“Consolidated Guidance About Materials Licenses: 

Program-Specific Guidance About Fixed Gauge 

Licenses.” Records of leak tests will be 

maintained.

❒

❒

❒For this 

item, 

checking 

this box 

indicates 

that 

alternative 

equipment 

and/or 

procedures 

will be 

provided as 

part of the 

application 

and that 

records of 

leak tests 

will be 

maintained.

10.8 Radiation 

Safety Program –

Maintenance

ROUTINE MAINTENANCE

We will implement and maintain procedures for 

routine maintenance of our gauges according to 

each manufacturer’s or distributor’s written 

recommendations and instructions.

NONROUTINE MAINTENANCE OPERATIONS

The gauge manufacturer, distributor, or other 

person authorized by the NRC or an Agreement 

State will perform nonroutine operations such as 

installation, initial radiation survey, repair and 

maintenance of radiological safety components, 

relocation, replacement, alignment, removal from 

service, and disposal of sealed sources.

❒

❒

❒

❒ The 

information 

listed in 

Appendix J

of this 

NUREG, 

“Information 

Needed to 

Support 

Applicant’s 

Request to 

Perform 

Nonroutine 

Operations,”

is attached.

10.9 Radiation 

Safety Program –

Transportation

The applicant is not required to submit a response 

about transportation during the licensing process. 

The NRC will review this issue during inspection.

Need not be submitted with 

application.
B–6

Item No. and Title Suggested Response Yes Alternative 

Procedures 

Attached

10.10 Radiation 

Safety Program –

Fixed Gauges 

Used at 

Temporary Job 

Sites

We will not use fixed gauges at temporary jobsites.

OR

We will address the use of fixed gauges at 

temporary jobsites in our operating, emergency, 

and security procedures developed in accordance 

with the Criteria in Section 8.10.6, “Operating, 

Emergency, and Security Procedures,” of NUREG1556, Volume 4, Revision 1, “Consolidated 

Guidance About Materials Licenses: ProgramSpecific Guidance About Fixed Gauge Licenses.” 

Copies of these procedures will be provided to all 

gauge users and will be available at all temporary 

jobsites.

❒

❒ ❒

10.11 Radiation 

Safety Program –

Security Program

for Category 1 and 

Category 2 

Radioactive 

Material

The applicant is not required to submit a response 

to the security program section in a license 

application. This matter will be examined during 

NRC inspections.

Need not be submitted with 

application.

11. Waste 

Management –

Gauge Disposal & 

Transfer

The applicant is not required to submit a response 

about waste management during the licensing 

process; however, the licensee should establish 

and include gauge transfer and waste disposal 

procedures in its radiation protection program.

Need not be submitted 

with application.
APPENDIX C

TYPICAL DUTIES AND RESPONSIBILITIES OF THE

RADIATION SAFETY OFFICER

C–1

TYPICAL DUTIES AND RESPONSIBILITIES OF THE

RADIATION SAFETY OFFICER

The radiation safety officer’s (RSO’s) duties and responsibilities (illustrated in Figure 8-2) 

typically include ensuring the following:

• Licensed activities that the RSO considers unsafe are stopped.

• Possession, installation, relocation, use, storage, routine maintenance, and nonroutine 

operations of fixed gauges are consistent with the limitations in the license, the Sealed 

Source and Device registration certificate(s), and the manufacturer’s or distributor’s 

recommendations and instructions.

• Individuals who use fixed gauges are properly trained.

• Radiation exposures are kept as low as is reasonably achievable (ALARA).

• Prospective evaluations are performed to demonstrate that unmonitored individuals are

not likely to receive a radiation dose in excess of the limits in 10 CFR 20.1502(a) or that 

personnel monitoring devices are provided.

• When necessary, personnel monitoring devices are used and exchanged at the proper 

intervals, and records of the results of such monitoring are maintained.

• Up-to-date operating, emergency, and security procedures are developed, implemented, 

maintained, and distributed.

• Safety consequences of nonroutine operations are analyzed before conducting any such 

activities that have not been previously analyzed.

• Nonroutine operations are performed by the manufacturer, distributor, or person 

specifically authorized by the U.S. Nuclear Regulatory Commission (NRC) or an 

Agreement State.

• Documentation is maintained to demonstrate, by measurement or calculation, that the 

dose to the individual member of the public likely to receive the highest dose from the 

licensed operation does not exceed the annual limit in Code of Federal Regulations

10 CFR 20.1301, “Dose limits for individual members of the public.”

• Fixed gauges are properly secured.

• Proper authorities are notified in case of accident, damage to, or malfunction of fixed

gauges, fire, loss, or theft.

• Unusual occurrences involving the fixed gauge (e.g., malfunctions, accident, damage, 

theft) are investigated, cause(s) are determined, and appropriate corrective action(s) are 

identified, and corrective action taken.

• Audits are performed at least annually and documented, and corrective actions 

are taken.
C–2

• When the licensee identifies violation(s) of regulations or license conditions or program 

weaknesses, corrective action(s) are developed, implemented, and documented.

• Licensed material is transported in accordance with all applicable NRC and U.S. 

Department of Transportation requirements.

• Licensed material is disposed of properly.

• All required records are maintained.

• An up-to-date license is maintained, and amendment and renewal requests are 

submitted in a timely manner.

• Documents are posted as required by 10 CFR 19.11, “Posting of notices to workers,” (10 

CFR Part 19, license documents, operating procedures, NRC Form 3, “Notice to 

Employees,”), and 10 CFR 21.6, “Posting Requirements,” (10 CFR Part 21 Section 206 

of the Energy Reorganization Act of 1974, procedures adopted under Part 21), or a note 

is posted indicating where these documents can be examined.
C–3

Model Delegation of Authority to Radiation Safety Officer

Memo To: Radiation Safety Officer

From: Chief Executive Officer

Subject: Delegation of Authority

You, _______________________________, have been appointed radiation safety officer and 

are responsible for ensuring the safe use of radiation. You are responsible for managing the 

Radiation Protection Program; identifying radiation protection problems; initiating, 

recommending, or providing corrective actions; verifying implementation of corrective actions;

stopping unsafe activities; and ensuring compliance with regulations. You are hereby delegated 

the authority necessary to meet those responsibilities, including prohibiting the use of byproduct 

material by employees who do not meet the necessary requirements and shutting down 

operations, when justified, to maintain radiation safety. You are required to notify management 

if staff does not cooperate and does not address radiation safety issues. In addition, you are 

free to raise issues with the U.S. Nuclear Regulatory Commission at any time. It is estimated 

that you will spend _____ hours per week conducting radiation protection activities.

____________________________________ ____________________

Signature of Management Representative Date

I accept the above responsibilities,

_____________________________________ ____________________

Signature of Radiation Safety Officer Date

cc: Affected department heads

APPENDIX D

CRITERIA FOR ACCEPTABLE TRAINING FOR 

AUTHORIZED USERS AND RADIATION SAFETY OFFICERS

D-1

CRITERIA FOR ACCEPTABLE TRAINING FOR

AUTHORIZED USERS AND RADIATION SAFETY OFFICERS

Course Content

Classroom training may be in the form of lectures, videos, computer-based sessions, or 

self-study lessons that emphasize practical subjects important to the safe use of the 

gauge including the following:

Radiation Safety:

• radiation versus contamination

• internal versus external exposure

• biological effects of radiation

• types and relative hazards of radioactive material possessed

• as low as is reasonably achievable (ALARA) concept

• use of time, distance, and shielding to minimize exposure

• location of sealed source within the gauge

Regulatory Requirements:

• applicable regulations

• license conditions, amendments, and renewals

• locations of use and storage of radioactive materials

• material control and accountability

• annual audit of radiation safety program

• transfer and disposal

• recordkeeping

• prior events involving fixed gauges

• handling incidents

• recognizing and ensuring that radiation warning signs are visible and legible

• licensing and inspection by regulatory agency

• need for complete and accurate information

• employee protection

• deliberate misconduct

Practical Explanation of the Theory and Operation for Each Gauge Possessed by the Licensee:

• operating, emergency, and security procedures

• routine versus nonroutine maintenance

• lock-out procedures

Supervised, Hands-On Experience (On-the-Job Training) Involving:

• operating procedures

• test runs of emergency procedures

• routine maintenance

• lock-out procedures
D-2

Note: On-the-job training must be done under the supervision of an authorized user (AU) or 

radiation safety officer (RSO).

Training Assessment

Management will ensure that proposed AUs are qualified to work independently with each type 

of gauge with which they may work. Management will ensure that proposed RSOs are qualified 

to work independently with and are knowledgeable of the radiation safety aspects of all types of 

gauges that may be possessed by the applicant.

Course Instructor Qualifications

Instructors should have, at a minimum, the following:

• successful completion of a fixed gauge manufacturer’s or distributor’s course for users 

(or equivalent)

• successful completion of an 8-hour radiation safety course or RSO training course

• documentation of 8 hours of hands-on experience with fixed gauges

Note: Additional training is required for those applicants intending to perform nonroutine 

operations, such as gauge installation; initial radiation survey; repair and maintenance of 

components related to the radiological safety of the gauge; gauge relocation; replacement, 

and disposal of sealed sources; gauge alignment; or removal of a gauge from service. 

See Appendix J of this NUREG, “Information Needed to Support Applicant’s Request to Perform 

Nonroutine Operations.”
APPENDIX E

FIXED GAUGE AUDIT CHECKLIST

E–1

FIXED GAUGE AUDIT CHECKLIST

Note: All areas indicated in audit notes may not be applicable to every license and may not 

need to be addressed during each audit. For example, licensees do not need to address areas 

that do not apply to their activities, and activities that have not occurred since the last audit need 

not be reviewed during the next audit.

Licensee’s name _____________________ License No. ____________________________

Date of This Audit ____________________ Date of Last Audit _______________________

Audit Date Range _____________________

___________________________ __________________________ __________

Auditor Signature Auditor Printed Name Date

___________________________ __________________________ __________

Management Signature Management Printed Name Date

1. Audit History

A. Were previous audits conducted periodically (at least annually)? 

(10 CFR 20.1101)

B. Were records of previous audits maintained? (10 CFR 20.2102)

C. Were any deficiencies identified during the last two audits or 2 years, whichever 

is longer?

D. Were corrective actions taken? (Look for repeated deficiencies.)

2. Organization and Scope of Program

A. If the mailing address or places of use changed, was the license amended?

[License Condition (L/C)]

B. If ownership changed or bankruptcy was filed, did the licensee obtain prior U.S. 

Nuclear Regulatory Commission (NRC) consent or notify the NRC? [10 CFR 

30.34(b)]

C. If the licensee changed the radiation safety officer (RSO), was the license 

amended? (L/C)

D. Sealed Sources and Devices

1. Does the license authorize all of the NRC-regulated radionuclides 

contained in the gauges possessed? (L/C)

2. Are the gauges as described in the Sealed Source and Device (SSD)

registration certificate? (L/C)
E–2

3. Are copies of (or access to) SSD registration certificates available?

4. Are manufacturers’ or distributors’ manuals for operation and 

maintenance available? (10 CFR 32.210)

5. Are the actual uses of gauges consistent with the authorized uses listed 

on the license? (L/C)

6. Are the locations of the gauges compatible with the “Conditions of Normal 

Use” and “Limitations and/or Other Considerations of Use” on the SSD 

registration certificates? (L/C)

E. Is the current inventory of material below the possession limits listed on the 

license? (L/C)

3. Training and Instructions to Workers

A. Were all workers who are likely to exceed 1 mSv [100 mrem] in a year instructed 

per 10 CFR 19.12? Was refresher training provided, as needed? Were records 

maintained?

B. Did each authorized user (AU) receive training and instruction given at the time 

of gauge installation or equivalent training and instruction before using gauges?

(L/C)

C. Are training records maintained for each AU? (L/C)

D. Did individuals who perform nonroutine operations receive training before 

performing these operations? (L/C)

E. Did interviews with AUs reveal that they know the operating, emergency, and 

security procedures?

F. Did this audit include observations of AUs using the gauge?

G. Did this audit include observations of workers performing routine cleaning and 

lubrication on the gauge?

H. Was U.S. Department of Transportation (DOT) hazardous material (HAZMAT) 

training provided, if required? (49 CFR 172.700, 172.701, 172.702, 172.704)

4. Radiation Survey Instruments

A. If a survey is performed, did the survey meter meet the NRC requirements? 

[10 CFR 20.1501(c)]

B. Are calibration records maintained, if applicable? [10 CFR 20.2103(a)]

C. If the licensee does not possess a survey meter, are specific plans made to have 

one available in the event of an emergency?
E–3

5. Gauge Inventory

A. Is a record kept showing the receipt of each gauge? [10 CFR 30.51(a)(1)]

B. Are all gauges physically inventoried every 6 months or at other intervals 

approved by the NRC? (L/C)

C. Are records of inventory results with appropriate information maintained? (L/C)

6. Personnel Radiation Protection

A. Are considerations for keeping doses as low as is reasonably achievable 

(ALARA) incorporated into the radiation protection program? 

[10 CFR 20.1101(b)]

B. Were prospective evaluations performed showing that unmonitored individuals 

receive less than the limits in 10 CFR 20.1502(a)? Did these evaluations 

consider doses to minors [10 CFR 20.1502(a)(2)] and declared pregnant women 

[10 CFR 20.1502(a)(3)]?

C. Did unmonitored individuals’ activities change during the year in a way that could 

put them over the limits in 10 CFR 20.1502(a)? If yes, was a new evaluation 

performed?

D. If external dosimetry is required [i.e., when individuals are likely to receive 

greater than the limits in 10 CFR 20.1502(a)], is dosimetry provided to these 

individuals? If yes, address the following:

1. Is the dosimetry supplier approved by the National Voluntary Laboratory 

Accreditation Program? [10 CFR 20.1501(c)]

2. Are the dosimeters exchanged at the appropriate frequency?

3. Are dosimetry reports reviewed and signed by the RSO when they are 

received?

4. Are the records based on NRC forms or the equivalent? 

[10 CFR 20.2104(d), 20.2106(c)]

a. Is NRC Form 4, “Cumulative Occupational Exposure History,” 

completed?

b. Is NRC Form 5, “Occupational Dose Record for a Monitoring 

Period,” completed?

E. Are there any declared pregnant workers?

1. If a worker declared her pregnancy, did the licensee comply with

10 CFR 20.1208, “Dose equivalent to an embryo/fetus”?

2. Were records kept of doses to an embryo/fetus per 10 CFR 20.2106(e)?
E–4

F. Are records of exposures, surveys, monitoring, and evaluations maintained? 

(10 CFR 20.2102, 10 CFR 20.2103, 10 CFR 20.2106)

7. Public Dose

A. Is public access to gauges controlled in a manner to keep doses below 1 mSv

[100 mrem] in a year? [10 CFR 20.1301(a)(1)]

B. Has a survey or evaluation been performed per 10 CFR 20.1501(a)? Have there 

been any additions or changes to the storage, security, or use of the surrounding 

areas that would necessitate a new survey or evaluation?

C. Do unrestricted area radiation levels exceed 0.02 mSv [2 mrem] in any one hour? 

[10 CFR 20.1301(a)(2)]

D. Is gauge access controlled in a manner that would prevent unauthorized use or 

removal? (10 CFR 20.1801)

E. Are records of surveys maintained? (10 CFR 20.2103, 10 CFR 20.2107) 

8. Operating, Emergency, and Security Procedures

Note: An ideal way to assess the adequacy and adherence to operating procedures is 

by observing work in progress.

A. Have operating, emergency, and security procedures been developed and 

updated to incorporate any new elements, practices, or requirements?

B. Does each individual working with the gauges have current copies of the 

operating, emergency, and security procedures (including lock-out procedures 

and emergency telephone numbers)?

C. Is a lock-out warning sign posted at each entryway to an area where it is possible 

to be exposed to the beam?

D. Did any emergencies occur?

1. If so, were they handled properly?

2. Were appropriate corrective actions taken?

E. Were gauges properly controlled or secured during use or storage? 

(10 CFR 20.1801, 10 CFR 20.1802)

9. Leak Tests

A. Were sealed source leak tests performed every 6 months or at other authorized

intervals? (L/C)

B. Were leak tests performed in accordance with license requirements? (L/C)
E–5

C. Are records of leak test results retained with all of the required information 

included? (L/C)

D. Were any sources found to be leaking, and if yes, was the NRC notified? (L/C)

10. Maintenance of Gauges

A. Are manufacturers’ or distributors’ procedures followed for routine cleaning and 

lubrication of gauges?

B. Was each on-off mechanism tested for proper operation every 6 months or at 

other approved intervals? (L/C)

C. Are repair and maintenance of components related to the radiological safety of 

the gauge performed by the manufacturer, distributor, or person specifically 

authorized by the NRC or an Agreement State and according to license 

requirements (e.g., extent of work, procedures, dosimetry, survey instrument, 

compliance with 10 CFR 20.1301 limits)? (L/C)

D. Are labels, signs, and postings identifying gauges containing radioactive material,

radiation areas, and lock-out procedures and warnings clean and legible?

11. Transportation

Note: This section will not apply if you have not transported gauges during the period covered 

by this audit.

A. Were U.S. Department of Transportation (DOT)-7A or other authorized packages 

used? (49 CFR 173.415, 49 CFR 173.416)

B. Are Type A package, engineering drawings, and performance test records on 

file? [49 CFR 171.2 (a, b, e), 49 CFR 173.415(a)]

C. For any special form source, is the International Atomic Energy Agency 

Certificate of Competent Authority or other safety analysis documentation 

maintained on file? [49 CFR 173.476(a)]

D. Were packages properly labeled? (49 CFR 172.400, 49 CFR 172.403, 

49 CFR 172.406, 49 CFR 172.407)

E. Were packages properly marked? (49 CFR 172.301, 49 CFR 172.304, 

49 CFR 172.310, 49 CFR 172.324)

F. Were packages closed and sealed before transport? [49 CFR 173.475(f)]

G. Were shipping papers prepared and used? [49 CFR 172.200(a)]

H. Did shipping papers contain proper entries {i.e., proper shipping name, hazard 

class, identification number [United Nations (UN) number], total quantity, 

package type, nuclide, reportable quantity (RQ) (if applicable), physical and 

chemical form, activity (International System of Units required), category of label, 

Transportation Index (TI), shipper’s name, certification and signature, emergency 
E–6

response phone number, cargo aircraft only (if applicable)}? (49 CFR 172.200, 

49 CFR 172.201, 49 CFR 172.202, 49 CFR 172.203, 49 CFR 172.204, 

49 CFR 172.604)

I. Were shipping papers within the driver’s reach and readily accessible during 

transport? [49 CFR 177.817(e)]

J. Were packages secured against movement? (49 CFR 177.834)

K. Were placards on the vehicle, if needed? (49 CFR 172.504)

L. Were overpacks, if needed, used properly? (49 CFR 173.25)

M. Were any incidents reported to the DOT? (49 CFR 171.15, 49 CFR 171.16)

12. Auditor’s Independent Survey Measurements (If Made)

Describe the type, location, and results of the measurements. Does any radiation level 

exceed regulatory limits? [10 CFR 20.1501(a), 10 CFR 20.1502(a)]

13. Notifications and Reports

A. Did any reportable incidents occur? Were the appropriate notifications made to 

the NRC Emergency Operations Center (301-816-5100)? Examples of incidents 

with notification requirements are as follows:

1. Lost or stolen radioactive material (10 CFR 20.2201)

2. Overexposures or high radiation levels (10 CFR 20.2202)

3. Inoperable or “stuck” shutter [10 CFR 30.50(b)(2)]

4. Generic equipment issues identified by the licensee (10 CFR 21.21)

B. Were the required written reports made as followups to the events?

14. Posting and Labeling

A. Is NRC Form 3, “Notice to Employees,” posted? (10 CFR 19.11)

B. Are NRC regulations and license documents posted, or is a notice posted stating 

where these documents are located? (10 CFR 19.11, 10 CFR 21.6)

C. Are any other posting and labeling requirements met? (10 CFR 20.1902, 10 

CFR 20.1904)

15. Decommissioning

A. Were any locations of use or separate buildings decommissioned since the last 

audit? Were appropriate notifications made or license amendments requested? 

(10 CFR 30.36)
E–7

B. Are records kept of information important to decommissioning? 

[10 CFR 30.35(g)]

C. Do records include all information outlined in 10 CFR 30.35(g)?

16. Generic Communications and Newsletter

A. Are NRC Regulatory Issue Summaries, NRC Information Notices, and Office of 

Nuclear Material Safety and Safeguards quarterly newsletters received?

B. Is appropriate training and action taken in response to these?

17. Special License Conditions or Issues

Did the auditor review special license conditions or other issues (e.g., nonroutine 

maintenance)? (L/C)

18. Evaluation of Other Factors

A. Is senior licensee management appropriately involved with the radiation 

protection program and/or RSO oversight?

B. Does the RSO have sufficient time to perform his or her radiation safety duties?

C. Does the licensee have sufficient staff to support the radiation protection 

program?

19. Deficiencies Identified in Audit and Corrective Actions

A. Summarize problems and/or deficiencies identified during the audit.

B. If problems and/or deficiencies were identified in this audit, describe corrective 

actions planned or taken. Are corrective actions planned or taken at all licensed 

locations (not just the location audited)? Include date(s) when corrective actions 

are implemented.

C. Provide any other recommendations for improvement.

D. Describe communication with management about deficiencies.

APPENDIX F

MODEL RADIATION SURVEY INSTRUMENT CALIBRATION PROGRAM

F–1

MODEL RADIATION SURVEY INSTRUMENT CALIBRATION PROGRAM

Training

Before independently calibrating radiation survey instruments, an individual should complete 

both classroom and on-the-job training as follows:

• Classroom training may be in the form of lecture, video, computer-based, or self-study 

and will cover the following subject areas:

− principles and practices of radiation protection

− radioactivity measurements, monitoring techniques, and the use of radiation 

detection instruments

− mathematics related to the use and measurement of radioactivity

− biological effects of radiation

• On-the-job training will consist of the following:

- observed authorized personnel performing radiation survey instrument calibration

- conducted radiation survey meter calibrations under the supervision and in the 

physical presence of an individual already authorized to perform calibrations

Facilities and Equipment

• To reduce doses received by individuals not calibrating radiation survey instruments, 

calibrations will be conducted in an isolated area of the facility or at times when no one 

else is present.

• The calibration source should be well-collimated, and the calibration area should be 

designed to minimize scatter of radiation, which could affect the calibration process.

• The calibration area should be appropriately controlled so that persons entering the area 

will be aware if a radiation source is in use.

• Evaluate posting of the calibration area with appropriate radiation warning signs, as 

required by Subpart J of 10 CFR 20.

• Individuals conducting calibrations of radiation survey instruments will wear 

assigned dosimetry.

• Individuals conducting calibrations will use a calibrated and operable radiation survey 

instrument to ensure that unexpected changes in exposure rates are identified 

and corrected.
F–2

Frequency of Calibration of Radiation Measurement Instruments and Equipment

A licensee committed to a routine or emergency radiation survey program should perform an 

acceptable calibration of all radiation measurement instruments and equipment at the frequency 

specified in NRC regulations, annually, or at the frequency recommended by the manufacturer, 

whichever period is shorter.

Special calibrations should be performed at any time there is reason to believe that the 

operating characteristics of a radiation measurement instrument have changed, by repair or 

alteration, or whenever system performance is observed to change significantly.

Routine maintenance of radiation measurement instruments should be performed as 

recommended by the manufacturer.

Primary or secondary standard instruments used to calibrate radiation measurement

instruments should be inspected frequently for consistency of performance.

Calibration Sources for Dose and Dose Rate Measuring Instruments

A radioactive sealed source(s) will be used for calibrating dose and dose rate measuring 

radiation survey instruments, and this source will have the following characteristics:

• The source should approximate a point source.

• Calibration fields from gamma sources should be known with an accuracy when 

compared to secondary or primary national standards of 5 percent for dose rates greater 

than or equal to 1.0 μGy/h (0.1 mrad/h) and 10 percent for dose rates less than 1.0 

μGy/h (0.1 mrad/h).

• The source should contain a radionuclide that emits radiation of identical or similar type 

and energy as environment in which the calibrated device will be used.

• The source should be strong enough to give an exposure rate of at least 

7.7 microcoulomb per kilogram per hour (30 milliroentgen per hour) at 100 centimeters 

(e.g., 3.1 gigabecquerels (85 millicuries) of cesium-137 or 780 megabecquerels 

(21 millicuries) of cobalt-60).

Note: Inverse square and radioactive decay laws should be used to correct changes in 

exposure rate due to changes in distance or source decay.
F–3

Calibration of Dose or Dose Rate Measuring Instruments

There are three kinds of scales frequently used on dose and dose-rate survey meters. These 

are calibrated as follows:

• Linear readout instruments with a single calibration control for all scales should be 

adjusted at the point recommended by the manufacturer or at a point within the normal 

range of use. Instruments with calibration controls for each scale should be adjusted on 

each scale. After adjustment, check the response of the instrument at approximately 20 

percent and 80 percent of full scale. Instrument readings should be within ± x of the 

conventionally true value for the following ranges:

– Background to 10 μGy/h (1.0 mrad/h); ±x = ±30%

– 10 μGy/h (1.0 mrad/h) to 1.0 mGy/h (100 mrad/h); ±x = ±20%

– 1.0 mGy/h (100 mrad/h) to 10 Gy/h (1,000 Rad/h); ±x = ±10%

• Logarithmic readout instruments, which commonly have a single readout scale 

spanning several decades, normally have two or more adjustments. Adjust the 

instrument for each scale according to site specifications or the manufacturer’s 

specifications. After adjustment, check the calibration at a minimum of one point on 

each decade. Instrument readings should have a maximum deviation from the 

conventionally true value as described for linear readout instruments.

• Digital readout instruments should be calibrated the same as linear 

readout instruments.

Note: Readings above 50 microcoulomb per kilogram per hour (200 milliroentgen per hour)

need not be calibrated, unless the licensee expects to make measurements at higher dose 

rates; regardless, such scales should be checked for operation and response to radiation.

Calibration Records

Calibration records for all radiation survey instruments should indicate the procedure used and 

the results of the calibration. The records should include the following:

• the owner or user of the radiation survey instrument

• a description of the radiation survey instrument that includes the manufacturer’s name, 

model number, serial number, and type of detector

• a description of the calibration source, including the exposure rate at a specified 

distance or activity on a specified date

• for each calibration point, the calculated exposure rate, the indicated exposure rate, the 

deduced correction factor (the calculated exposure rate divided by the indicated 

exposure rate), and the scale selected on the radiation survey instrument

• the exposure reading indicated with the radiation survey instrument in the “battery 

check” mode (if available on the instrument)
F–4

• for radiation survey instruments with external detectors, the angle between the radiation 

flux field and the detector (i.e., parallel or perpendicular)

• for radiation survey instruments with internal detectors, the angle between the radiation 

flux field and a specified surface of the instrument

• for radiation detectors with removable shielding, an indication whether the shielding was 

in place or removed during the calibration procedure

• the exposure rate from a check source, if used

• the name and signature of the individual who performed the calibration and the date on 

which the calibration was performed

The following information will be attached to the radiation survey instrument as a calibration 

sticker or tag:

• the source radionuclide used to calibrate the radiation survey instrument

• for each scale or decade not calibrated, an indication that the scale or decade was 

checked only for function but not calibrated

• the date of calibration and the next calibration due date

• the apparent exposure rate from the check source, if used

Reference: Detailed information about portable radiation survey instrument calibration may be 

obtained by referring to American National Standards Institute (ANSI)-N323AB-2013, 

“American National Standard for Radiation Protection Instrumentation Test and Calibration, 

Portable Survey Instruments.”
APPENDIX G

DOSIMETRY-RELATED GUIDANCE

G–1

DOSIMETRY-RELATED GUIDANCE

Part 1: Guidance for Demonstrating that Unmonitored Workers Are Not Likely To Exceed 

the Limits in 10 CFR 20.1502(a)

Dosimetry is required for individuals likely to receive, from sources external to the body, a dose 

in excess of the limits in Title 10 of the Code of Federal Regulations [(10 CFR) 20.1502(a)]. 

Therefore, a licensee should evaluate the doses its workers receive in performing their duties to 

assess whether dosimetry is required.

Example

Note: The examples in this appendix use conventional units. The conversions to International 

System of Units are as follows: 1 foot = 0.305 meter; 0.01 mSv = 1 mrem.

A gauge manufacturer has estimated the doses to the extremities and whole body of a person 

replacing the assay plate on one of its series of gauges. Each gauge in the series is authorized 

to contain up to 7.4 gigabecquerels [200 millicuries] of cesium-137. The manufacturer based its 

estimate on observations of individuals performing the recommended procedure according to 

good radiation safety practices. The manufacturer had the following information:

• time needed to perform the entire procedure (e.g., 15 minutes)

• expected dose rate received by the whole body of the individual, associated with the 

shielded source and determined using measured or manufacturer-determined data 

(e.g., 0.02 mSv per hour [2 mrem per hour] at 46 centimeters [18.1 inches] from 

the shield)

• time the hands were exposed to the shielded source (e.g., 6 minutes)

• expected dose rate received by the extremities of the individual, associated with the 

shielded source and determined using measured or manufacturer-determined data on 

contact with the shield [e.g., 0.15 mSv per hour (15 mrem per hour)].

From this information, the manufacturer estimated that the individual performing each routine 

cleaning and lubrication could receive the following:

• less than 0.005 mSv [0.5 mrem] to the whole body

• 0.015 mSv [1.5 mrem] to the hands

The applicable whole body dose limit for adult workers is 50 mSv [5 rem] per year, with 

individual monitoring devices required when it is likely that an individual will receive 10 percent 

of that value [i.e., 5 mSv (500 mrem) per year]. If one of these procedures delivers 0.005 mSv 

[0.5 mrem], then an adult worker could perform 1,000 of these procedures each year and 

remain within 10 percent of the applicable limit.

The applicable whole body dose limit for minors is 10 percent of the annual dose limits specified 

for adult workers [i.e., 5 mSv (0.5 rem) per year], with individual monitoring devices required 

when it is likely that a minor will receive a deep dose equivalent in excess of 1 mSv [0.1 rem]. If 

one of these procedures delivers 0.005 mSv [0.5 mrem], then a minor could perform 200 such 

procedures each year without exceeding the individual monitoring device threshold. 
G–2

For declared pregnant women, individual monitoring devices are required when these 

individuals are likely to receive during the entire pregnancy, from radiation sources external to 

the body, a deep dose equivalent in excess of 1 mSv (0.1 rem). If one of these procedures 

delivers 0.005 mSv [0.5 mrem], then a declared pregnant women could perform 200 of these 

procedures during her entire pregnancy without exceeding the individual monitoring 

device threshold. 

The applicable extremity dose limit for adult workers is 500 mSv [50 rem] per year with 

individual monitoring devices required when it is likely than an individual will receive 10 percent 

of that value [i.e., 50 mSv (5 rem or 5,000 mrem) per year]. If one of these procedures delivers 

0.015 mSv [1.5 mrem], then an adult worker could perform 3,333 of these procedures each year 

and remain within 10 percent of the applicable limit.

The applicable extremity dose limit for minors is 10 percent of the annual dose limits specified 

for adult workers [i.e., 50 mSv (5 rem) per year], with individual monitoring devices required 

when it is likely that a minor will receive a dose to the extremities in excess of 5 mSv [0.5 rem]. 

If one of these procedures delivers 0.015 mSv [1.5 mrem], then a minor could perform 333 of 

these procedures each year and remain within 10 percent of the applicable limit.

Declared pregnant women have no requirements concerning dose the extremities or the 

monitoring thereof. 

Based on the specific situation described previously, no dosimetry is required if an adult worker 

performs fewer than 1,000 routine maintenance procedures per year; a minor performs fewer 

than 200 routine maintenance procedures per year; or a declared pregnant woman performs

fewer than 200 procedures during the entire pregnancy.

Guidance to Licensees

Licensees who wish to demonstrate that they are not required to provide dosimetry to their 

workers must prepare a written evaluation similar to that shown in the previous example. The 

expected dose rates, times, and distances used in the above example may not be appropriate 

to individual licensee situations. In their evaluations, licensees must use information 

appropriate to the various types of gauges on which they will perform routine cleaning and 

lubrication. This information is generally available from gauge manufacturers or the SSD 

registration certificate maintained by the U.S. Nuclear Regulatory Commission (NRC) or 

Agreement State.

Table G-1 may be helpful in documenting a licensee’s evaluation.

Licensees should review evaluations periodically and revise them as needed. They should 

check assumptions used in their evaluations to ensure that the assumptions are up-to-date and 

accurate. For example, if workers became lax in following good radiation safety practices in the 

example used previously, the extremities could be closer to the unshielded source, and the 

workers would receive more exposure than 0.15 mSv [15 mrem] per hour. Alternatively, 

workers could perform the task more slowly than the estimated 15 minutes total, and 6 minutes 

with their hands near the unshielded source. Also, using new gauges containing sources of 

different activities, different radionuclides, or different cleaning and lubrication procedures 

requires a new evaluation.
G–3

Table G-1. Dosimetry Evaluation

Dosimetry Evaluation for ___________________ Model ___________ Fixed Gauge

A. Time needed to perform the entire routine 

cleaning and lubrication procedure on the gauge

_________ minutes _________ hour

(divide # of minutes 

by 60)

B. Expected whole-body dose rate that the individual 

will encounter, determined using measured or 

manufacturer-provided data

____________ mrem/hour

C. Time the hands were exposed to the unshielded 

source

_________ minutes _________ hour

D. Expected extremity dose rate that the individual 

will encounter, determined using measured or 

manufacturer-provided data for the unshielded 

source at the typical distance from the hands to 

the unshielded source

____________ mrem/hour

Estimated Whole Body Dose Equivalent*

Formula: (_____hours in Row A) x (______mrem/hour in Row B) = (_____estimated mrem) x (_____# 

of cleaning and lubrications conducted each year) = _______ Whole Body Dose mrem

Estimated Extremity Dose Equivalent†

Formula: (_____hours in Row C) x (______mrem/hour in Row D) = (_____estimated mrem) x (_____# 

of cleaning and lubrications conducted each year) = _______ Extremity Dose mrem

*An expected whole body dose equivalent for adult workers less than 500 mrem requires no dosimetry. The 

corresponding value for minors is 100 mrem. The corresponding value for declared pregnant women during the 

entire pregnancy is 100 mrem.

†An expected extremity dose equivalent for adult workers less than 5,000 mrem requires no dosimetry. 

The corresponding value for minors is 500 mrem. There is no corresponding value for declared pregnant women.
G–4

Part 2: Guidance for Demonstrating that Individual Members of the Public Will Not 

Receive Doses Exceeding the Allowable Limits

Licensees must ensure the following:

The radiation dose received by individual members of the public does not exceed 

1 mSv [100 mrem] in 1 calendar year resulting from the licensee’s possession 

and/or use of licensed materials.

Members of the public include persons who live, work, or may be near locations where fixed 

gauges are used or stored. Employees whose assigned duties do not include the use of 

licensed materials and who work in the vicinity where gauges are used or stored are also 

considered members of the public.

The radiation dose in unrestricted areas does not exceed 0.02 mSv [2 mrem] in 

any one hour.

Typical unrestricted areas may include offices, shops, laboratories, a nearby walkway, areas 

outside buildings, and non-radioactive equipment storage areas. The licensee does not 

control access to these areas for purposes of controlling exposure to radiation or radioactive 

materials. However, the licensee may control access to these areas for other reasons, such 

as security.

Licensees must show compliance with both of these portions of the regulations. 

Calculations and measurements (e.g., using a dosimeter to monitor an area) are often 

used to prove compliance.

Calculational Method

The calculational method takes a tiered approach, using a three-part process starting with a 

worst case situation and moving toward more realistic situations. It makes the following 

simplifications: (1) each gauge is a point source, (2) typical radiation levels encountered when 

the source is in the shielded position are taken from either the SSD registration certificate or the 

manufacturer’s literature, and (3) no credit is taken for any shielding found between the gauges 

and the unrestricted areas.

Part 1 of the calculational method is simple but conservative. It assumes that an affected 

member of the public is present 24 hours a day and uses only the “inverse square law” to 

determine whether the distance between the gauge and the affected member of the public is 

sufficient to show compliance with the public dose limits. Part 2 considers not only distance, but 

also the time that the affected member of the public is actually in the area under consideration. 

Part 3 considers distance and the amount of time that both the gauge and the affected member 

of the public are present. Using this approach, licensees make only those calculations that are 

needed to demonstrate compliance. In many cases, licensees will need to use the calculational 

method through Part 1 or Part 2. The results of these calculations typically result in higher 

radiation levels than would exist at typical facilities but provide a method for estimating 

conservative doses that could be received.
G–5

Note: If calculated potential doses are not within regulatory limits initially, the licensee should 

take into account any shielding from the radiation beam provided by equipment or structures 

between the beam and workers or consider adding other shielding materials to reduce potential 

doses. In order to calculate the effects of any shielding, the licensee should seek the 

assistance of an individual knowledgeable in health physics.

Example 1

To better understand the calculational method, we will look at ABC Bottling, Inc., a fixed gauge 

licensee. Yesterday, the company’s president noted that three new gauges will be very close to 

a bottling control panel where a quality control supervisor—a worker who does not work with 

fixed gauges—works. The company’s president asked Joe, the radiation safety officer (RSO), 

to determine whether the company is complying with the NRC’s regulations.

Joe measures the distances from each gauge to the bottling control panel and looks up in the 

manufacturer’s literature the radiation levels that individuals would encounter for each gauge. 

Figure G-1 is Joe’s sketch of the areas in question, and Table G-2 summarizes the information 

Joe has on each gauge.

Figure G-1. Diagram of Bottling Line and Fixed Gauges. This sketch shows the areas 

described in Examples 1 and 2.
G–6

Table G-2. Information Known About Each Gauge

DESCRIPTION OF KNOWN

INFORMATION

GAUGE 1 GAUGE 2 GAUGE 3

Where gauge is located Gauge on bottling 

line

Gauge on main feed 

line

Gauge on tank

Dose rate in mrem/hour encountered 

at specified distance from the gauge 

(from manufacturer’s literature)

2 mrem/hour at 1 ft 8 mrem/hour

at 1 ft

2 mrem/hour

at 3 ft

Distance in feet to bottling control 

panel

8 ft 12 ft 15 ft

Example 1: Part 1

Joe’s first thought is that the distance between the gauges and the bottling control panel may be 

sufficient to show compliance with the regulation in 10 CFR 20.1301. So, taking a “worst case” 

approach, he assumes that (1) the gauges are constantly present (i.e., 24 hours per day), (2) all 

three gauges are on (i.e., shutters are open), and (3) a quality control (QC) supervisor—a 

worker who does not work with the fixed gauges—is constantly sitting at the control panel 

(i.e., 24 hours per day). Joe proceeds to calculate the dose the QC supervisor might receive 

hourly and yearly from each gauge as shown in Tables G-3, G-4, and G-5 next.

Table G-3. Calculational Method, Part 1–Hourly and Annual Dose Received 

From Gauge 1

Step No. Description Gauge 1

Input Data Results

1 Dose received in an hour at known distance from gauge 

(e.g., from manufacturer’s data), in mrem per hour

2 2

2 Square of the distance (ft) at which the Step 1 rate was measured, 

in ft2

(1)2 1

3 Square of the distance (ft) from the gauge to the bottling control 

panel in an unrestricted area, in ft2

(8)2 64

4 Multiply the results of Step 1 by the results of Step 2 (this is an 

intermediate result)

2 × 1 =2

5 Divide the result of Step 4 by the result of Step 3 to calculate dose 

received by the worker at the bottling control panel = HOURLY 

DOSE RECEIVED FROM GAUGE 1, in mrem per hour

2/64 = 0.031

6 Multiply the result of Step 5 by 24 hours per day × 365 days per 

year = MAXIMUM ANNUAL DOSE RECEIVED FROM GAUGE 1, 

in mrem per year

0.031 × 24 × 365 = 

0.031 × 8,760 = 272
G–7

Table G-4. Calculational Method, Part 1–Hourly and Annual Dose Received From 

Gauge 2

Gauge 2

Step No. Description Input Data Results

1 Dose received in an hour at known distance from gauge 

(e.g., from manufacturer’s data), in mrem per hour

8 8

2 Square of the distance (ft) at which the Step 1 rate was measured, 

in ft2

(1) 2 1

3 Square of the distance (ft) from the gauge to the bottling control 

panel in an unrestricted area, in ft2

(12) 2 144

4 Multiply the results of Step 1 by the results of Step 2 

(this is an intermediate result)

8 × 1 = 8

5 Divide the result of Step 4 by the result of Step 3 to calculate dose 

received in an hour by the worker at the bottling control panel = 

HOURLY DOSE RECEIVED FROM GAUGE 2, in mrem per hour

8/144 = .056

6 Multiply the result of Step 5 by 24 hour per day × 365 days per 

year = MAXIMUM ANNUAL DOSE RECEIVED FROM GAUGE 2, 

in mrem per year

0.056 × 24 × 365 = 

0.056 × 8,760 = 491

Table G-5. Calculational Method, Part 1–Hourly and Annual Dose Received From 

Gauge 3

Gauge 3

Step No. Description Input Data Results

1 Dose received in an hour at known distance from gauge 

(e.g., from manufacturer’s data), in mrem per hour

2 2

2 Square of the distance (ft) at which the Step 1 rate was measured, 

in ft2

(3)2 9

3 Square of the distance (ft) from the gauge to bottling control panel 

in an unrestricted area, in ft2

(15)2 225

4 Multiply the results of Step 1 by the results of Step 2 (this is an 

intermediate result)

2 × 9 =18

5 Divide the result of Step 4 by the result of Step 3 to calculate dose 

received by the worker at the bottling control panel = HOURLY 

DOSE RECEIVED FROM GAUGE 3, in mrem per hour

18/225 = 0.08

6 Multiply the result of Step 5 by 24 hour per day × 365 days per 

year = MAXIMUM ANNUAL DOSE RECEIVED FROM GAUGE 3, 

in mrem per year

0.08 × 24 × 365 = 

0.08 × 8,760 = 701

To determine the total hourly and total annual dose received, Joe adds the pertinent data from 

the preceding tables (see Table G-6).
G–8

Table G-6. Calculational Method, Part 1–Total Hourly and Annual Dose Received From 

Gauges 1, 2, and 3

Step 

No.

Description Gauge 1 Gauge 2 Gauge 3 Sum

7 TOTAL HOURLY DOSE 

RECEIVED from Step 5 of 

Tables G-3, G-4, and G-5, in mrem

per hour

0.031 0.056 0.08 0.031 + 0.056 + 0.08 = 

0.167

8 TOTAL ANNUAL DOSE RECEIVED 

from Step 6 of Tables G-3, G-4, and 

G-5, in mrem per year

272 491 701 272 + 491 + 701 

= 1,464

Note: The sum in Step 7 demonstrates compliance with the 2-mrem-in-any-one-hour limit. 

Reevaluate if assumptions change. If the sum in Step 8 exceeds 100 mrem per year, proceed 

to Part 2 of the calculational method.

At this point, Joe is pleased to see that the total dose that an individual could receive in any 

one hour is only 0.167 mrem, but he notes that an individual could receive a dose of 

1,464 mrem in a year, much higher than the 100-mrem regulatory limit.

Example 1: Part 2

Joe reviews his assumptions and recognizes that the QC supervisor is not at the bottling control 

panel 24 hours per day. He decides to make a realistic estimate of the number of hours the QC 

supervisor would be present at the bottling control panel, keeping his other assumptions 

constant (i.e., the gauges are constantly present 24 hours per day and all three gauges remain 

on (i.e., shutter is open)). He then recalculates the annual dose received (see Table G-7).

Table G-7. Calculational Method, Part 2–Annual Dose Received From Gauges 1, 2, and 3

Step 

No. Description Results

9 A. Average number of hours per day that individual spends in area of 

concern (e.g., worker present at bottling control panel 5 hours per day; 

the rest of the day the worker is away from the area performing other 

duties not in the vicinity of gauges)

B. Average number of days per week in area (e.g., worker is part time 

and works 3 days a week)

C. Average number of weeks per year in area (e.g., worker works all year)

5

3

52

10 Multiply the results of Step 9A by the results of Step 9B by the results of 

Step 9C = AVERAGE NUMBER OF HOURS IN AREA OF CONCERN 

PER YEAR

5 × 3 × 52 = 780

11 Multiply the sum in Step 7 by the results of Step 10 = ANNUAL DOSE 

RECEIVED FROM GAUGES CONSIDERING REALISTIC ESTIMATE OF 

TIME SPENT IN AREA OF CONCERN, in mrem per year

0.167 × 780 = 130
G–9

Note: If Step 11 exceeds 100 mrem in a year, proceed to Part 3 of the calculational method.

Although Joe is pleased to note that the calculated annual dose received is significantly lower, 

he realizes it still exceeds the 100 mrem in a year limit.

Example 1, Part 3

Again Joe reviews his assumptions and recognizes that Gauge 3 will only be used on the 

process line during product changeovers and Gauge 2 has different radiation levels depending 

on whether the gauge is in the “on” or “off” position (i.e., shutter is open or closed). As he 

examines the situation, he realizes he must consider each gauge individually.

Table G-8. Calculational Method, Part 3—Summary of Information

INFORMATION ON GAUGES:

• GAUGE 1 operates continuously (24 hours per day) on the bottling line.

• GAUGE 2 operates (in the “on” position) while the tank is being filled, approximately 1 hour during 

the time the worker is present. When the pipe is not filling the tank, the gauge is in the “off” 

position. While in the “off” position, the radiation level around the gauge drops to 2 mrem per 

hour at 1 foot, 1/4 of the radiation level when the gauge is in the “on” position.

• GAUGE 3 is only used on the process line during product changeovers, 4 weeks per year. While 

affixed, it operates continuously (24 hours per day).

INFORMATION FROM EXAMPLE 1, PART 2, ON WHEN THE WORKER IS PRESENT AT THE 

BOTTLING CONTROL PANEL:

• 5 hours per day

• 3 days per week

• 52 weeks per year
G–10

Table G-9. Calculational Method, Part 3–Annual Dose Received From Gauges 1, 2, and 3

Step 

No. Description Gauge 1 Gauge 2 “On” Gauge 2 “Off” Gauge 3

12 Average number of 

hours per day gauge 

operates when worker 

is present at the bottling 

control panel

5 1 4 5

13 Average number of 

days per week gauge 

operates when worker 

is present at the bottling 

control panel

3 3 3 3

14 Average number of 

weeks per year gauge 

operates when worker 

is present at the bottling 

control panel

52 52 52 4

15 Multiply the results of 

Step 12 by the results 

of Step 13 by the 

results of Step 14 = 

TOTAL HOURS EACH 

GAUGE OPERATED 

PER YEAR WHILE 

WORKER IS PRESENT 

AT BOTTLING 

CONTROL PANEL

5 × 3 × 52 = 780 1 × 3 × 52 = 156 4 × 3 × 52 = 624 5 × 3 × 4 = 60

16 Multiply the results of 

Step 15 by the results 

of Step 7 (for Gauge 2 

in the “off” position, the 

radiation level drops to 

1/4th, so divide the 

results of Step 7 by 4) = 

ANNUAL DOSE 

RECEIVED FROM 

EACH GAUGE, in 

mrem in a year

780 x 0.031 = 24 156 x 0.056 = 8.7 624 x (0.056/4) 

= 8.7

60 x 0.08 

= 4.8 in mrem 

in a year 

17 Sum the results of Step 

16 for each gauge = 

TOTAL ANNUAL DOSE 

RECEIVED 

CONSIDERING 

REALISTIC ESTIMATE 

OF TIME SPENT IN 

AREA OF CONCERN 

AND TIME GAUGE 

OPERATES, in mrem

per year

24 + 8.7 + 8.7 + 4.8 = 46.2

Note: If the result in Step 17 is greater than 100 mrem per year, the licensee must take 

corrective actions.
G–11

Joe is pleased that the result in Step 17 shows compliance with the 100-mrem-per-year limit. 

Had the result in Step 17 been higher than 100 mrem per year, then Joe could have done one 

or more of the following:

• Consider whether the assumptions used to determine occupancy and the time each 

gauge operates are accurate, revise the assumptions as needed, and recalculate using 

the new assumptions.

• Calculate the effect of any shielding located between the gauges and the bottling control 

panel (such calculation is beyond the scope of this appendix).

• Take corrective action (e.g., add shielding, move the bottling control panel), and perform 

new calculations to demonstrate compliance.

• Designate the area outside the storage area as a restricted area and the QC supervisor 

as an occupationally exposed individual. This would require controlling access to the 

area for purposes of radiation protection and training of the QC supervisor as required 

by 10 CFR 19.12, “Instruction to workers.”

Note that in the example, Joe evaluated the unrestricted area at the bottling control panel. 

Licensees also need to make similar evaluations for other unrestricted areas and to keep in 

mind the “as low as is reasonably achievable” (ALARA) principle, taking reasonable steps to 

keep radiation dose received below regulatory limits. In addition, licensees need to be alert to 

changes in situations (e.g., adding a gauge to the process line, changing the QC supervisor’s 

schedule, or changing the estimate of the portion of time spent at the bottling control panel) and 

to perform additional evaluations, as needed.

RECORDKEEPING: 10 CFR 20.2107 requires licensees to maintain records demonstrating 

compliance with the dose limits for individual members of the public.

Combination Measurement–Calculational Method

This method, which allows the licensee to take credit for shielding between the gauge and the 

area in question, begins by measuring radiation levels in the areas, as opposed to using 

manufacturer-supplied rates at a specified distance from each gauge. These measurements 

must be made with calibrated survey meters sufficiently sensitive to measure background levels 

of radiation. A maximum dose of 1 mSv [100 mrem] received by an individual over a period of 

2,080 hours (i.e., a work year of 40 hours per week for 52 weeks per year) is equal to less than 

0.5 microsievert [0.05 mrem] per hour.

This rate is well below the minimum sensitivity of most commonly available survey instruments 

(i.e., Geiger-Mueller or G-M). Instruments used to make measurements for calculations must

be sufficiently sensitive. An instrument equipped with a scintillation-type detector (e.g., a NaI 

(Tl) or a micro-Roentgen or micro-R meter) should be adequate.

Licensees may also choose to use dosimeters specifically engineered for measuring 

environmental dose rates. Dosimeters used for personnel monitoring may not have sufficient 

sensitivity for this purpose. Generally, the minimum reportable dose received by a personnel 

dosimeter is 0.1 mSv [10 mrem]. Suppose a personnel dosimeter monitors dose received and 

is changed once a month. If the measurements are at the minimum reportable level, the annual 
G–12

dose received could have been about 1.2 mSv [120 mrem], a value in excess of the 

100-millirem-per-year limit. If licensees use dosimeters to evaluate compliance with the 

public dose limits, they should consult with their dosimetry supplier and choose more 

sensitive dosimeters.

This direct measurement method would provide a definitive measurement of actual radiation 

levels in unrestricted areas without any restrictive assumptions. Records of these 

measurements can then be evaluated to ensure that rates in unrestricted areas do not exceed 

the 100-mrem-per-year limit.

Example 2

As in Example 1, Joe is the RSO for ABC Bottling, Inc., a fixed gauge licensee. The company 

has three gauges located near a bottling control panel that is operated by a worker who does

not work with the fixed gauges. See Figure G-1 and Table G-2 for information. Joe wants to 

see whether the company complies with the public dose limits at the bottling control panel. Joe 

placed an environmental dosimeter at the bottling control panel for 30 days. The dosimetry 

processor sent Joe a report indicating the environmental dosimeter received 100 mrem in those 

30 days.

Table G-10. Combination Measurement–Calculational Method

Step 

No. Description Input Data and Results

Part 1

1 Dose received by dosimeter, in mrem 100

2 Total hours that dosimeter was exposed 24 hours per day × 30 days = 720

3 Divide the results of Step 1 by the results of Step 2 to 

determine HOURLY DOSE RECEIVED, in mrem per hour

0.14

4 Multiply the results of Step 3 by 8,760 hours in one year = 

MAXIMUM ANNUAL DOSE RECEIVED FROM GAUGES, 

in mrem per year

0.14 × 8,760 = 1,226

Note: For the conditions described in Table G-10, Step 3 indicates that the dose received in 

any one hour is less than the 2-mrem-in-any-one-hour limit. However, if there are any changes, 

then the licensee would need to reevaluate the potential doses that could be received in any 

one hour. Step 4 indicates that the annual dose received would be much greater than the 

100 mrem per year allowed by the regulations.

Part 2

At this point Joe can adjust for a realistic estimate of the time the worker spends at the bottling control 

panel, as he did in Part 2 of Example 1.

Part 3

If the results of Joe’s evaluation in Part 2 show that the annual dose received in a year exceeds 100 mrem, then he 

can make adjustments for realistic estimates of the time of exposure in the area of concern, as in Part 3 of Example 

1. Recall that the dosimeter measurement was made while all the gauges were operating (i.e., 24 hours a day for 

the 30 days that the dosimeter was in place).
APPENDIX H

OPERATING, EMERGENCY, AND SECURITY PROCEDURES

H–1

OPERATING, EMERGENCY, AND SECURITY PROCEDURES

Operating Procedures

• If personnel dosimetry is provided, do the following:

– Always wear your assigned dosimeter when using the gauge.

– Never wear another person’s dosimeter.

– Never store your dosimeter near a gauge.

• Use the gauge according to the manufacturer’s or distributor’s instructions and 

recommendations. Perform routine cleaning and maintenance according to the 

manufacturer’s or distributor’s instructions and recommendations.

• Test each gauge for the proper operation of the on-off mechanism (shutter) and 

indicator, if any, at intervals not to exceed 6 months or as specified in the Sealed Source 

and Device (SSD) registration certificate.

• Do not touch the unshielded source with your fingers, hands, or any part of your body.

• Do not place hands, fingers, feet, or other body parts in the radiation field from an 

unshielded source.

• Post a radiation warning sign at each entryway to an area where it is possible to be 

exposed to the radiation beam.

• Prevent employees from entering the radiation beam during maintenance, repairs, or 

work in, on, or around the equipment on which the device is mounted by developing 

lock-out procedures. These procedures should specify who will be responsible for 

ensuring that the lock-out procedures are followed.

• Provide instructions to prevent unauthorized access, removal, or use of the gauge.

• After making changes affecting the gauge (e.g., changing the location of gauges, 

removing shielding, adding gauges, changing the occupancy of adjacent areas) 

reevaluate compliance with public dose limits and ensure proper security of gauges.

• Conduct a physical inventory every 6 months to account for all devices.

• Require timely reporting to the U.S. Nuclear Regulatory Commission (NRC) pursuant to 

10 CFR 20.2201 and 10 CFR 20.2207, as appropriate.

Emergency Procedures

• If a gauge becomes damaged, a source becomes dislodged, a source is leaking, the 

device fails to function properly, or any other nonradiological emergency (e.g., fire or 

medical emergency) or unusual situation arises, do the following:

— Stop use of the gauge.

— Immediately secure the area, and keep people away from the gauge until the 
H–2

situation is assessed and radiation levels are known. Perform first aid for any 

injured individuals, and remove them from the area when it is medically safe to 

do so.

— If any equipment is involved, isolate the equipment until it is determined there is 

no contamination present.

— Gauge users and other potentially contaminated individuals should not leave the 

scene until emergency assistance arrives.

— Notify the persons, in the order listed next, of the situation:

NAME1 WORK PHONE NUMBER1 HOME PHONE NUMBER1

____________________ _______________________ ________________________

____________________ _______________________ ________________________

____________________ _______________________ ________________________

• Follow the directions provided by the person contacted in the previous list.

Radiation Safety Officer and Licensee Management

• Arrange for a radiation survey to be conducted as soon as possible by a knowledgeable 

person using appropriate radiation detection instrumentation. This person could be a 

licensee employee using a survey meter, a local emergency responder, or a consultant. 

To accurately assess the radiation danger, it is essential that the person performing the 

survey be competent in the use of the survey meter.

• Make necessary notifications to local authorities as well as the NRC as required. 

Appendix L of this NUREG contains typical NRC incident notifications and reporting 

required for fixed gauge licensees.

(Even if not required to do so, you may report ANY incident to the NRC by calling the 

NRC’s Operations Center at 301-816-5100, which is staffed 24 hours a day and accepts 

collect calls.) NRC notification is required when gauges containing licensed material are 

lost or stolen and when gauges are damaged or involved in incidents that result in doses 

in excess of Title 10 of the Code of Federal Regulations (10 CFR) 20.2203 limits. 

Reporting requirements are found in 10 CFR 20.2201-2203 and in 10 CFR 30.50.

Security Procedures

• Address guidelines to meet the security and control requirements of 10 CFR 20.1801, 

10 CFR 20.1802, and any other applicable security and control requirements.

• Provide instructions to prevent unauthorized access, removal, or use of fixed gauges, 

including at temporary jobsites if authorized on the license.

 1 Fill in with (and update, as needed) the names and telephone numbers of appropriate personnel (e.g., the radiation 

safety officer (RSO), authorized users (AUs), or other knowledgeable licensee staff; licensee’s consultant; gauge 

manufacturer, distributor, or representative; fire department or other emergency response organization, as 

appropriate, and the NRC) to be contacted in case of emergency.
APPENDIX I

MODEL LEAK TEST PROGRAM

I–1

MODEL LEAK TEST PROGRAM

Training

Before allowing an individual to perform leak testing, the licensee must ensure that he or she 

has sufficient classroom and on-the-job training to show competency in performing leak testing 

and sample analysis independently.

Classroom training may be in the form of lecture, online, video, hands-on, or self-study and 

should cover the following subject areas:

• principles and practices of radiation protection

• radioactivity measurements, monitoring techniques, and instrument use

• mathematics and calculations used for measuring radioactivity

• biological effects of radiation

Appropriate on-the-job training consists of the following:

• observing authorized personnel collecting and analyzing leak test samples

• collecting and analyzing leak test samples under the supervision and in the physical 

presence of an individual authorized to perform leak testing and sample analysis

Facilities and Equipment

• To ensure achieving the required sensitivity of measurements, analyze leak tests in a 

low-background area.

• Use a calibrated and operable survey instrument to check leak test samples for gross 

contamination before they are analyzed.

• Analyze the leak test sample using an instrument that is appropriate for the type of 

radiation to be measured (e.g., NaI(Tl) well-counter system for gamma emitters, liquid 

scintillation for beta emitters, and gas-flow proportional counter for alpha emitters).

• If the sensitivity of the counting system is unknown, determine the minimum detectable 

activity (MDA). The MDA may be determined using the following formula:

MDA =

2.71 + 4.65 �bkg ×t

t ×E

where: MDA = minimum detectable activity in disintegrations per minute (dpm)

bkg = background count rate in counts per minute (cpm)

t = background counting time in minutes

E = detector efficiency in counts per disintegration
I–2

For example:

where: bkg = 200 cpm

E = 0.1 counts per disintegration (10 percent efficient)

t = 2 minutes

MDA = 

2.71 + 4.65 �200 cpm × 2 minutes

2 × 0.1 = 

2.71 + 4.65 √400

0.2

= 2.71 + 4.65(20)

0.2 = 

2.71 + 93

0.2 = 

95.71

0.2

= 478.55 disintegrations

minute

becquerels (Bq) = 1 disintegration

second

MDA = 

478.55 disintegration

minutes × 

minute

60 seconds = 7.976 Bq

Note: The MDA equation shown assumes that counting times for the background measurement 

and for the sample will be equal. MDA equations for non-equal counting times, as well as 

derivations of equations and discussions of limitations, can be found in “Decommissioning 

Health Physics—A Handbook for MARSSIM Users,” Eric W. Abelquist, published by Taylor & 

Francis Group, 2001.

Frequency for Conducting Leak Tests of Sealed Sources

Leak tests will be conducted at the frequency specified in the respective Sealed Source and 

Device registration certificate. If a sealed source is not registered, leak tests should be 

conducted at 6 month intervals, unless a different interval is established during the licensing 

process. Leak testing of sealed sources may be required by license condition.

Procedure for Performing Leak Testing and Analysis

• For each source to be tested, list identifying information such as the sealed source serial 

number, manufacturer, model number, radionuclide, and activity.

• Use a radiation survey meter to monitor exposure.

• Prepare a separate wipe sample (e.g., cotton swab or filter paper) for each source.

• Number each wipe to correlate with identifying information for each source.

• Wipe the most accessible area where contamination would accumulate if the sealed 
I–3

source were leaking, but do not wipe the surface of a plated or foil source (see 

manufacturer’s instructions).

• Select instrumentation that is sensitive enough to detect 185 becquerels (Bq) 

(0.005 microcurie) of the radionuclide contained in the gauge.

• Using the selected instrument, count and record background count rate.

• Check the instrument’s counting efficiency using a standard source of the same 

radionuclide as the source being tested or one with similar energy characteristics. The 

calibration source should be in the same configuration as the sample. Accuracy of 

standards should be within plus or minus 5 percent of the stated value and traceable to 

primary radiation standards such as those maintained by the National Institute of 

Standards and Technology.

• Calculate the counting efficiency of the detector. 

Efficiency in cpm/Bq = [(cpm from std) – (cpm from bkg)]

activity of std in Bq

where cpm = counts per minute

std = standard

bkg = background

Bq = becquerel

• Count each wipe sample; determine net count rate.

• For each sample, calculate and record estimated activity in becquerels (or microcuries). 

The activity of the sample in becquerels may be calculated using the following formula:

Activity of sample [Bq] = [(cpm from wipe sample) - (cpm from bkg)]

efficiency in cpm/Bq

• Sign and date the list of sources, data, and calculations. Retain records for 3 years

[under Title 10 of the Code of Federal Regulations (10 CFR) 20.2103(a)].

• If the wipe test activity is 185 becquerels (0.005 microcuries) or greater, notify the 

radiation safety officer so that the source can be withdrawn from use and disposed of 

properly. Also, notify the U.S. Nuclear Regulatory Commission.

APPENDIX J

INFORMATION NEEDED TO SUPPORT APPLICANT’S REQUEST TO 

PERFORM NONROUTINE OPERATIONS

J–1

INFORMATION NEEDED TO SUPPORT APPLICANT’S REQUEST TO

PERFORM NONROUTINE OPERATIONS

Applicants should review Section 8.10.8, “Maintenance,” which discusses, in general, licensee 

responsibilities before any maintenance or repair is performed.

Nonroutine operations, which require specific authorization by the U.S. Nuclear Regulatory 

Commission (NRC) or an Agreement State, include gauge installation; initial radiation survey;

repair and maintenance of radiological safety components; gauge relocation; replacement and 

disposal of sealed sources; gauge alignment; or removal of a gauge from service. See 

Figure 8-7 in Section 8.10.8.

Any replacement components, parts, or other materials (e.g., lubricants) other than those 

supplied, specified, or recommended by the manufacturer or distributor need to be evaluated to 

ensure that they do not degrade the engineering safety analysis performed and accepted as 

part of the device’s Sealed Source and Device (SSD) registration certificate. Licensees also 

need to ensure that, after maintenance or repair is completed, the gauge is tested and functions 

as designed before the unit is returned to routine use.

If nonroutine operations are not performed properly with attention to good radiation safety 

principles, the gauge may not operate as designed, and personnel performing these tasks could 

receive radiation doses that exceed the NRC’s regulatory limits. Radionuclides and activities in 

fixed gauges vary widely. For illustrative purposes, in less than 1 minute, an unshielded 

cesium-137 source with an activity of 3.7 gigabecquerels [100 millicuries] can deliver 0.05 Sv 

[5 rem] to a worker’s hands or fingers (i.e., extremities), assuming the extremities are 

1 centimeter from the source. This dose corresponds to the threshold for extremity monitoring. 

Some gauges may contain sources of even higher activities with correspondingly higher 

dose rates.

Thus, applicants wishing to perform nonroutine operations must use personnel with specialized

training for the activities intended to be performed and follow appropriate procedures consistent 

with the manufacturer’s or distributor’s instructions and recommendations that address radiation 

safety concerns [e.g., use of radiation survey meter, shielded container for the source, and 

personnel dosimetry (if required)].

Accordingly, applicants wishing to perform nonroutine operations must provide the following 

information with their license application:

• Describe the types of work, maintenance, cleaning, and/or repair that involve any of 

the following:

– installation, relocation, or alignment of the gauge

– components, including electronics, related to the radiological safety of the gauge 

(e.g., the source, source holder, source drive mechanism, shutter, shutter 

control, or shielding)

– replacement and disposal of sealed sources

– removal of a gauge from service
J–2

– a potential for any portion of the body to come into contact with the primary 

radiation beam

– any other activity during which personnel could receive radiation doses 

exceeding NRC limits

• Identify who will perform nonroutine operations, and describe their training and 

experience. Acceptable training includes manufacturers’ or distributors’ courses for 

nonroutine operations or an equivalent.

• Submit procedures for nonroutine operations. These procedures should ensure 

the following:

– doses to personnel and members of the public are within regulatory limits and 

are kept as low as is reasonably achievable (ALARA) (e.g., use of shielded 

containers or shielding)

– the source is secured against unauthorized removal or access or is under 

constant surveillance

– appropriate labels and signs are used (Lock-out procedures are adequate to 

ensure that no individual or portion of an individual’s body can enter the radiation 

beam.)

– manufacturer’s or distributor’s instructions and recommendations are followed

– replacement components, parts, or other materials (e.g., lubricants) other than 

those supplied, specified, or recommended by the manufacturer or distributor are 

evaluated to ensure that they do not degrade the engineering safety analysis 

performed and accepted as part of the SSD registration certificate

– the gauge, before being returned to routine use, is tested to verify that it functions 

as designed and source integrity is not compromised

• Confirm that individuals performing nonroutine operations on gauges will wear both 

whole body and extremity monitoring devices or perform a prospective evaluation 

demonstrating that unmonitored individuals performing nonroutine operations are not 

likely to receive a radiation dose in excess of the limits in 10 CFR 20.1502(a).

• Confirm possession of at least one survey instrument that is appropriate for measuring 

the types of radiation and expected dose rates from the fixed gauge(s).

• Describe steps to be taken to ensure that radiation levels in areas where 

nonroutine operations will take place do not exceed limits set in 10 CFR 

20.1301(e.g., surveys, calculations).
APPENDIX K

U.S. DEPARTMENT OF TRANSPORTATION REGULATIONS

K–1

U.S. DEPARTMENT OF TRANSPORTATION REGULATIONS

Note: The following list of U.S. Department of Transportation (DOT) regulations is provided to 

inform licensees about typical requirements that apply to the transportation of licensed material 

including the preparation of shipments of licensed material. Licensees should note that the list 

is incomplete in that not all potentially applicable requirements have been included. Also, 

transportation requirements change; therefore, licensees should consult the regulations for 

definitive information about current requirements. Additional information on transportation 

requirements may be found at the DOT Web site: http://www.dot.gov/.

• Table of Hazardous Materials and Special Provisions—49 CFR 172, Subpart B

– 49 CFR 172.101—Hazardous Materials Table [proper shipping name, hazard 

class, identification number]

– 49 CFR 172.101—List of Hazardous Substances and Reportable Quantities, 

Table 2 to Appendix A—Radionuclides

• Shipping Papers—49 CFR 172, Subpart C

– 49 CFR 172.201—Preparation and retention of shipping papers

– 49 CFR 172.202—Description of hazardous material on shipping papers

– 49 CFR 172.203—Additional description requirements

– 49 CFR 172.204—Shipper’s certification 

• Marking—49 CFR 172, Subpart D

– 49 CFR 172.300—Applicability

– 49 CFR 172.301—General marking requirements for non-bulk packagings

– 49 CFR 172.304—Marking requirements

– 49 CFR 172.310—Class 7 (radioactive) materials

– 49 CFR 172.324—Hazardous substances in non-bulk packagings [designation of 

“reportable quantities” with the letters “RQ”]

• Labeling—49 CFR 172, Subpart E

– 49 CFR 172.400—General labeling requirements

– 49 CFR 172.400a—Exceptions from labeling

– 49 CFR 172.401—Prohibited labeling

– 49 CFR 172.403—Class 7 (radioactive) material

– 49 CFR 172.406—Placement of labels

– 49 CFR 172.436—RADIOACTIVE WHITE-I label

– 49 CFR 172.438—RADIOACTIVE YELLOW-II label

– 49 CFR 172.440—RADIOACTIVE YELLOW-III label

• Emergency Response Information—49 CFR 172, Subpart G

– 49 CFR 172.600—Applicability and general requirements

– 49 CFR 172.602—Emergency response information

– 49 CFR 172.604—Emergency response telephone number
K–2

• Training—49 CFR 172, Subpart H

– 49 CFR 172.702—Applicability and responsibility for training and testing

– 49 CFR 172.704—Training requirements

• Shippers—General Requirements for Shipments and Packagings—49 CFR Part 173

– 49 CFR 173.25—Authorized packagings and overpacks

– 49 CFR 173.403—Definitions

– 49 CFR 173.411—Industrial packages

– 49 CFR 173.412—Additional design requirements for Type A packages

– 49 CFR 173.415—Authorized Type A packages

– 49 CFR 173.433—Requirements for determining basic radionuclide values, and 

for the listing of radionuclides on shipping papers and labels

– 49 CFR 173.435—Table of A1 and A2 values for radionuclides

– 49 CFR 173.441—Radiation level limitations and exclusive use provisions

– 49 CFR 173.471—Requirements for U.S. Nuclear Regulatory Commission 

approved packages

– 49 CFR 173.475—Quality control requirements prior to each shipment of Class 7 

(radioactive) materials

– 49 CFR 173.476—Approval of special form Class 7 (radioactive) materials

• Carriage by Public Highway—49 CFR Part 177

– 49 CFR 177.817—Shipping papers

– 49 CFR 177.842—Class 7 (radioactive) material [includes requirement for 

blocking and bracing during transport]

Note: The following reference charts are for reference only and are not a substitute for DOT and 

U.S. Nuclear Regulatory Commission transportation regulations.
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K–4
K–5
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APPENDIX L

INCIDENT NOTIFICATIONS AND REPORTING

L–1

INCIDENT NOTIFICATIONS AND REPORTING

Table L-1. Typical NRC Notification and Reporting Requirements for Incidents

Note: The following list of notification and reporting requirements is provided to inform licensees 

about typical notification and reporting requirements that apply to their licensed activities. 

Licensees should note that the list is incomplete in that not all potentially applicable 

requirements have been included. Also, notification and reporting requirements change; 

therefore, licensees should consult the regulations for definitive information about current 

requirements.

Event

Telephone 

Notification

Written 

Report Regulatory Requirement

Theft or loss of licensed material immediate 30 days 10 CFR 20.2201(a)(1)(i)

10 CFR 20.2201(b)(1)

Whole body dose greater than 0.25 

Sv (25 rems)

immediate 30 days 10 CFR 20.2202(a)(1)(i)

10 CFR 20.2203(a)(1)

Extremity dose greater than 2.5 Gy 

(250 rads)

immediate 30 days 10 CFR 20.2202(a)(1)(iii)

10 CFR 20.2203(a)(1)

Whole body dose greater than 

0.05 Sv (5 rems) in 24 hours

24 hours 30 days 10 CFR 20.2202(b)(1)(i)

10 CFR 20.2203(a)(1)

Extremity dose greater than 0.5 Sv 

(50 rems) in 24 hours

24 hours 30 days 10 CFR 20.2202(b)(1)(iii)

10 CFR 20.2203(a)(1)

Whole body dose greater than 

0.05 Sv (5 rems)

none 30 days 10 CFR 20.2203(a)(2)(i)

Dose to individual member of public 

greater than 1 mSv (0.1 rem)

none 30 days 10 CFR 20.2203(a)(2)(iv)

Defect in equipment that could create 

a substantial safety hazard

2 days 30 days 10 CFR 21.21(d)(3)(i) & (ii)

Event that prevents immediate 

protective actions necessary to avoid 

exposures to radiation or radioactive 

materials that could exceed 

regulatory limits

immediate 30 days 10 CFR 30.50(a) & (c)(2)

Equipment is disabled or fails to 

function as designed when required 

to prevent radiation exposure in 

excess of regulatory limits 

24 hours 30 days 10 CFR 30.50(b)(2) & 

(c)(2)

Unplanned fire or explosion that 

affects the integrity of any licensed 

material or device, container, or 

equipment with licensed material

24 hours 30 days 10 CFR 30.50(b)(4) & 

(c)(2)

Note: Telephone notifications must be made to the U.S. Nuclear Regulatory Commission 

Operations Center at 301-816-5100.

APPENDIX M

SAFETY CULTURE POLICY STATEMENT

M-1

Safety Culture

The safety culture policy statement was published in the Federal Register (76 FR 34773) on 

June 14, 2011, and can be found at: http://www.gpo.gov/fdsys/pkg/FR-2011-06-14/pdf/2011-

14656.pdf. It is also posted in the NRC’s Agencywide Documents Access and Management 

System (ADAMS) and can be found using Accession Number ML11146A047.

Safety Culture Policy Statement

The purpose of this Statement of Policy is to set forth the Commission’s expectation that 

individuals and organizations establish and maintain a positive safety culture commensurate 

with the safety and security significance of their activities and the nature and complexity of their 

organizations and functions. This includes all licensees, certificate holders, permit holders, 

authorization holders, holders of quality assurance program approvals, vendors and suppliers of 

safety-related components, and applicants for a license, certificate, permit, authorization, or 

quality assurance program approval, subject to NRC authority. The Commission encourages 

the Agreement States, Agreement State licensees and other organizations interested in nuclear 

safety to support the development and maintenance of a positive safety culture, as articulated in 

this Statement of Policy.

Nuclear Safety Culture is defined as the core values and behaviors resulting from a collective 

commitment by leaders and individuals to emphasize safety over competing goals to ensure 

protection of people and the environment. Individuals and organizations performing regulated 

activities bear the primary responsibility for safety and security. The performance of individuals 

and organizations can be monitored and trended and, therefore, may be used to determine 

compliance with requirements and commitments and may serve as an indicator of possible 

problem areas in an organization’s safety culture. The NRC will not monitor or trend values. 

These will be the organization’s responsibility as part of its safety culture program.

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

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

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

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

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

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

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

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

with NRC-regulated activities.

Experience has shown that certain personal and organizational traits are present in a positive 

safety culture. A trait, in this case, is a pattern of thinking, feeling, and behaving that 

emphasizes safety, particularly in goal conflict situations, e.g., production, schedule, and the 

cost of the effort versus safety. It should be noted that although the term ‘‘security’’ is not 

expressly included in the following traits, safety and security are the primary pillars of the NRC’s 

regulatory mission. Consequently, consideration of both safety and security issues, 

commensurate with their significance, is an underlying principle of this Statement of Policy.
M-2

The following are traits of a positive safety culture:

(1) Leadership Safety Values and Actions – Leaders demonstrate a commitment to safety in 

their decisions and behaviors;

(2) Problem Identification and Resolution – Issues potentially impacting safety are promptly

identified, fully evaluated, and promptly addressed and corrected commensurate with 

their significance;

(3) Personal Accountability – All individuals take personal responsibility for safety;

(4) Work Processes – The process of planning and controlling work activities is 

implemented so that safety is maintained;

(5) Continuous Learning – Opportunities to learn about ways to ensure safety are sought 

out and implemented;

(6) Environment for Raising Concerns – A safety-conscious work environment is maintained 

where personnel feel free to raise safety concerns without fear of retaliation, intimidation, 

harassment, or discrimination;

(7) Effective Safety Communication – Communications maintain a focus on safety;

(8) Respectful Work Environment – Trust and respect permeate the organization; and

(9) Questioning Attitude – Individuals avoid complacency and continuously challenge 

existing conditions and activities in order to identify discrepancies that might result in 

error or inappropriate action.

There may be traits not included in this Statement of Policy that are also important in a positive 

safety culture. It should be noted that these traits were not developed to be used for inspection 

purposes.

It is the Commission’s expectation that all individuals and organizations, performing or 

overseeing regulated activities involving nuclear materials, should take the necessary steps to 

promote a positive safety culture by fostering these traits as they apply to their organizational 

environments. The Commission recognizes the diversity of these organizations and 

acknowledges that some organizations have already spent significant time and resources in the 

development of a positive safety culture. The Commission will take this into consideration as 

the regulated community addresses the Statement of Policy.
APPENDIX N

CHECKLIST FOR REQUESTS TO WITHHOLD PROPRIETARY 

INFORMATION FROM PUBLIC DISCLOSURE (UNDER 10 CFR 2.390)

N–1

CHECKLIST FOR REQUESTS TO WITHHOLD PROPRIETARY

INFORMATION FROM PUBLIC DISCLOSURE (UNDER 10 CFR 2.390)

In order to request that the U.S. Nuclear Regulatory Commission (NRC) withhold information 

from public disclosure, the applicant or licensee must submit the information, including an 

affidavit, in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, 

“Public Inspections, Exemptions, Requests for Withholding.” The applicant should submit all 

of the following:

 A proprietary copy of the information. Brackets should be placed around the material 

considered to be proprietary. This copy should be marked as proprietary.

 A non-proprietary copy of the information. Applicants should white out or black out the 

proprietary portions (i.e., those in the brackets), leaving the non-proprietary portions 

intact. This copy should not be marked as proprietary.

 An affidavit that:

 Is signed under oath and affirmation (notarization may suffice).

 Clearly identifies (such as by name or title and date) the document to be withheld.

 Clearly identifies the position of the person executing the affidavit. This person 

must be an officer or upper-level management official who has been delegated the 

function of reviewing the information the organization is seeking to withhold and is 

authorized to apply for withholding on behalf of the organization.

 States that the organization submitting the information is the owner of the 

information or is required, by agreement with the owner of the information, to treat 

the information as proprietary.

 Provides a rational basis for holding the information in confidence.

 Fully addresses the following issues:

 Is the information submitted to, and received by, the NRC in confidence? 

Provide details.

 To the best of the applicant’s knowledge, is the information currently available 

in public sources?

 Does the applicant customarily treat this information, or this type of 

information, as confidential? Explain why.

 Would public disclosure of the information be likely to cause substantial harm 

to the competitive position of the applicant? If so, explain why in detail. The 

explanation should include the value of the information to your organization, 

the amount of effort or money expended in developing the information, and the 

ease or difficulty for others to acquire the information.





NUREG

-1556, Vol. 4

Revision 1, Final

Consolidated Guidance About Materials Licenses:

Program-Specific Guidance About Fixed Gauge Licenses