MATERIALS

INSPECTION

& LICENSING

HANDBOOK

BEST PRACTICES
Paperwork Reduction Act Statement

This generic handbook contains 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, approval 

number 3150‐0011.

The information collections contained in this handbook are 

covered by the requirements of 10 CFR Part 20, which were 

approved by the Office of Management and Budget, approval 

number 3150-0014.

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.
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i MATERIALS INSPECTION & LICENSING HANDBOOK 2008

TA B L E O F C O N T E N T S 

PURPOSE 1

INSPECTION PREPARATION 3

In Office Preparation 3

Personal Safety 4

Entrance Interview 6

CONDUCT OF INSPECTION 9

Performance-Based Inspection 9

Safety 9

Trust but Verify 10

Violations 10

General 10

Normal/Backshift Observations 11

Interface with Licensee 11

Unsafe Acts 11

Inspection Opportunities 12

Inspector’s Behavior and Attitude 12

Interview Skills 14

Cameras 15

Allegations, Concerns, and Complaints 15

Safety Conscious Work Environment (SCWE) 15

Third Party Assistance 16

INSPECTION LICENSING
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Non-Radiological Safety Concerns 16

Facility Emergency 16

Personal Emergency 17

Exit Meeting 17

Functional Areas 19

Radiation Protection 19

Skin Exposure 19

High Dosimeters 19

High Radiation Areas 20

Training 20

Portable Gauges 20

Fixed Gauges 21

Broad Scope 22

Contamination Control 23

Sealed Sources 24

Radiography 24

Medical 27

Supervision 28

Brachytherapy 28

High Dose Rate Afterloader (HDR) 29

Gamma Stereotactic Radiosurgery (GSR or Gamma Knife) 29

Radio-Pharmacies 30

Panoramic Irradiators 30

Self-Shielded Irradiators 31

Well Logging 32

Decommissioning 32

Radiological Instrumentation 32

Surveys 32

Radiation Protection Standards and Practices 33

Sinks, Drains, and Ventilation Systems 33

Vacuums 33

Electrical 34

Scaffolding 34

Heavy Loads 34

Safety 34
iii MATERIALS INSPECTION & LICENSING HANDBOOK 2008

Personal Protective Equipment 35

Fall-Related Injuries 35

Heat Stress Awareness 35

Tanks and Pools 35

Asbestos, Lead, Mercury, PCBs 36

Transportation 36

Event Review 36

Medical Event Follow-Up 37

Service Providers 37

Reciprocity 38

SECURITY ISSUES 41

LICENSING 43

General 43

Medical 43

Service Licenses 44

Nuclear Laundries 44

Decommissioning Contractors 45

Decommissioning 46

Financial Assurance 46

WORKSHEETS 49

INDEX 53

ACKNOWLEDGMENTS 55

SUMMARY THOUGHTS AND SUGGESTIONS 57

FIGURES

Figure 1. Real environment for gauges 5

Figure 2. Gauge in use 7

Figure 3. Good advice 13

Figure 4. Exit sign 18

Figure 5. Survey meter 22

Figure 6. Radiographer preparing for work 26

Figure 7. Laboratory safety 31

Figure 8. Radiography equipment 39

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BEST PRACTICES

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1 MATERIALS INSPECTION & LICENSING HANDBOOK 2008

PURPOSE

The U.S. Nuclear Regulatory Commission (NRC) developed the 

Materials Inspection & Licensing Handbook primarily to help new 

inspectors and reviewers, but the agency also hopes the booklet 

will assist experienced staff. The materials inspector and reviewer 

community is extremely diverse and spread out over a large area 

(four NRC regional offices, NRC Headquarters, 33 Agreement States 

with additional Agreement States expected). This booklet is modeled 

on the NRC Inspector Field Observation Best Practices Manual, 

developed by NRC reactor inspectors, and provides a similar reference 

for the materials area. The material presented in this handbook was 

developed by inspectors and license reviewers and includes best 

practices from all four NRC regions and the Agreement States. The 

authors compiled this information from individual experiences and 

suggestions, a review of generic communications, such as information 

notices, training presentations, and a variety of other sources.
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NOTE: The guidance in this booklet is not intended 

to be all inclusive or to replace policy or guidance. 

It is intended to supplement existing inspection 

procedures, to heighten inspector and reviewer 

awareness of specific issues, and to improve the 

effectiveness of materials inspections and licensing. 

Official policy and guidance are promulgated in 

NRC’s Inspection Manual, licensing guidance, or 

in appropriate documents issued by individual 

Agreement States.
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I N S P E C T I O N 

PREPARATION

In Office Preparation

The amount of time you spend preparing for an inspection depends 

upon your experience level as an inspector and the complexity and 

scope of the licensed activities. The goal of inspection preparation 

is to ensure that you are familiar with the uses of licensed material 

to be inspected and understand the requirements applicable to 

that licensed program. 

» Make every effort to schedule inspections during periods 

when work with licensed materials is most likely to be 

performed.

» Review the license to determine if it has any unusual license 

conditions that would affect the approach to the inspection 

(e.g., authorization for an incinerator).

» Review the licensee’s recent inspection and enforcement 

history (i.e., review the results of the last inspection, nuclear 

material events database (NMED), and any open items to 

determine if any events were reported by the licensee during 

the current inspection cycle). Pay particular attention to 

commitments and corrective actions for past violations.

» Review applicable generic communications to be aware of 

previously identified hazards and issues associated with the 

license type that you will inspect. 

» Review any notes in the licensee’s docket file regarding 

special inspection emphasis (e.g., an amendment for a 
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new medical therapy modality under Title 10 of the Code 

of Federal Regulations (10 CFR), Section 35.1000, “Other 

medical uses of byproduct material or radiation from 

byproduct material,” must be inspected within 12 months of 

the date of the amendment [see Inspection Manual Chapter 

(IMC) 2800, Material Inspection Program).

» Provide a copy of the itinerary to the State radiation control 

agency to give the State personnel an opportunity to 

observe the inspections.

» Assure that appropriate security clearances have been 

provided to the facility prior to the inspection. To avoid 

revealing unannounced inspections, this can often be 

done on a scheduled basis for a 1-year period, allowing 

inspections at any time.

» Assure that the radiation survey instrument planned for 

use is appropriate to the program to be inspected and is 

calibrated commensurate with the applicable calibration 

frequency required for the licensee (e.g., 6 months for 

radiography licensees in accordance with 10 CFR 34.25, 

“Radiation survey instruments”).

Consider preparing a check sheet or “memory jogger” 

which will help to make sure you carry out all planned 

activities. 

Use the appropriate inspection procedure and associated Focus 

Elements as the basis for preparation; in addition ask:

» What are the potential problem areas for this licensed 

activity?

» What actions or inactions could lead to significant 

exposures of workers or the public?

» What actions or inactions could lead to significant releases 

of licensed materials to the environment?

» What actions or inactions could lead to the loss of control of 

significant quantities of licensed material?

Personal Safety

Assure you have appropriate safety equipment. Consider personal 

dosimetry (thermoluminescence dosimeter [TLD] or other), survey 

meter (for independent measurements and personal safety), 
5 MATERIALS INSPECTION & LICENSING HANDBOOK 2008

alarming ratemeter, safety shoes, hard hat, safety glasses, and 

hearing protection. Some sites require special protective gear, 

such as Nomex suits; determine whether the licensee will supply 

the necessary special gear or you need to bring your own. Having 

appropriate safety equipment reduces the amount of time it will 

take to begin the inspection and presents a professional image. 

Learn Occupational Safety and Health Administration (OSHA) and 

Mine Safety and Health Administration (MSHA) regulations so that 

you can recognize when conditions are unsafe, and know what 

safety measures to take. Wear your eye, ear, and foot protection 

when appropriate, even if not required by the licensee.

During the actual inspection: Be careful! Industrial facilities 

present many potential hazards, and most are non-radiological 

(e.g., moving vehicles, machinery, unsafe scaffolding, spills, 

electrical hazards, chemicals, explosives, poor lighting, noise, 

vibration, extreme temperatures, and confined spaces).

Many licensees require completion of site-specific safety training. 

It may be necessary to visit the site in advance of the inspection in 

order to complete safety orientation and training.

Remember that any confined or air restricted space, 

tank, or room may develop a hazardous atmosphere 

or reduced oxygen concentration. Ensure the confined 

spaces you enter are well-ventilated and that the 

entry has been evaluated and approved in accordance 

with an appropriate procedure.

Figure 1. Real environment for gauges
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Entrance Interview

Take the time to do an entrance interview with the most senior 

management representative available, even if it is just the radiation 

safety officer (RSO) or other single licensee representative. Ask if 

there is anyone else in management that they should inform of the 

inspection. 

Let licensee management know:

» that you are there to conduct an inspection and how long 

the inspection will take,

» what kind of inspection you will be doing and what that 

generally entails,

» the unannounced inspection policy, and

» that you will meet with the most senior available 

management representative at the end of the inspection. 

The discussions should include:

» Violations from the last inspection, if any,

» Unresolved items from previous inspections, and

» Bulletins, Orders and other generic communications that 

affect the site.

Identify areas you want to focus on, yet be flexible enough to 

observe other activities occurring during the inspection. Ask what 

activities are planned during the time you are inspecting and 

keep asking throughout the inspection. Sometimes you will learn 

something that management is unaware of and this may lead to 

important insights into the licensee’s program. 

If there is a particular activity you want to see immediately 

upon arriving at the site, say, “I would like to look at ‘X’ as 

soon as possible. Can we go there right now? I will go over the 

inspection plan as we go and then I would like to have a formal 

entrance interview when we are done there.” Most licensees will 

accommodate such requests.

Ask about scheduling problems that the inspection may cause and 

modify your inspection plan, if necessary, to minimize the impact 

on the licensee without compromising the inspection. For example, 
7 MATERIALS INSPECTION & LICENSING HANDBOOK 2008

schedule inspection activities for which a licensee representative 

is not needed (e.g. lunch breaks or record reviews) at times when 

the licensee representative must perform other tasks. 

Figure 2. Gauge in use

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CONDUCT OF INSPECTION

Performance-Based Inspection

A performance-based inspection is an examination and evaluation 

of results or outcome of performance rather than a prescriptive 

process, technique, or procedure. Conduct performance-based 

inspections by observing licensee staff demonstrate their 

understanding of the proper use and handling of licensed material. 

Focus on high-risk and rarely-performed licensed activities, 

activities conducted during backshift hours, and the licensee’s 

response to unusual situations and events. If licensed activities 

are not being conducted, request licensee staff to demonstrate 

how licensed activities have been or would be done. 

Conduct independent measurements as a means of evaluating 

licensee conclusions and identifying opportunities to reduce 

radiation doses consistent with the “as low as reasonably 

achievable” (ALARA) concept. 

Safety

In general, if activities are conducted in accordance with regulatory 

requirements, they should be safe. However, safety doesn’t necess‐

arily mean only “in compliance.” “No violations of regulatory require‐

ments” doesn’t necessarily preclude problems. Assess each situation 

in a holistic fashion, evaluating the state of compliance and whether 

there has been appropriate attention paid to safety and risk.
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Trust but Verify

Trust the licensee to provide you with accurate information; verify 

the accuracy of selected information you obtain from the licensee.

Violations

When you have identified several violations, focus your effort on 

identifying the most safety-significant violations and problems and 

the root causes of the violations (for example, poor management 

oversight). In addition, ensure that the licensee understands your 

findings and implements prompt and effective corrective actions 

to address the violations and the root causes. Do not leave the 

site until the licensee has adequately addressed the violations and 

safety concerns. 

When you think you have identified a violation, take the time 

to obtain the applicable “who, what, why, when, where, and 

how” information and review that information with the radiation 

safety officer. Ask if you have missed anything or if there is an 

alternative explanation. Listen to the RSO’s point of view to avoid 

misunderstandings. Keep licensee staff informed about identified 

violations and concerns throughout the inspection rather than 

withholding the information until the exit interview. 

General

Cross-check records against licensee staff’s statements. Verify 

licensee assumptions (especially by field observation) regarding 

calculations to show compliance with NRC regulatory requirements.

During the inspection, record the name of each person you speak 

with and their title. Get the spelling correct. Document what 

you see and find on your field notes as you are inspecting; avoid 

waiting until later and trying to remember. Have regulations, 

including 10 CFR Parts 19, 20, 30, 34, 35, 40, 70, and 71 as well 

as regulations for other agencies, including 49 CFR Parts 136 and 

190. When you are finished with the inspection, take a few minutes 

and write out your findings before your exit interview with the 

licensee. If you need help before the exit interview, call one of 

the senior health physicists or your Branch Chief to discuss the 

findings of the inspection and your proposed actions.
1 1 MATERIALS INSPECTION & LICENSING HANDBOOK 2008

Normal/Backshift Observations

Inspections conducted during backshifts are often more informative 

than normal shift inspections. It is easy for other employees on the 

backshift to believe that no one will check their peformance as 

long as nothing “bad” happens. 

For a licensee authorized to work at a temporary job site, inspectors 

should make every reasonable attempt to include an unannounced 

inspection of licensed activities at such a locations. Sometimes this 

is as easy as asking the licensee not to tell staff at other locations 

that you are coming. 

Observe selected radiation safety committee meetings and training 

sessions whenever possible. This may provide insights into how 

the licensed program actually functions. 

Ask the licensee if they receive generic communications from 

the NRC (e.g., newsletters). The NRC’s generic communications 

provide an opportunity for licensees to gain insights on operational 

experience, including learning from past incidents and problems. 

Interface with Licensee

Unless an inspector needs to intervene to prevent an unsafe 

situation, direct observation of work activities should not interfere 

with licensed activities. For example, an inspector should not 

insist on interviews when: 

» a worker is delayed in performing scheduled work activities 

(i.e., delayed departure to a temporary job site), 

» a worker is preparing or administering patient doses, 

» a worker is providing patient care, or 

» a licensee is dealing with customers or members of the public.

Unsafe Acts

Take prompt action whenever you identify an unsafe condition 

or a violation that, if not immediately corrected, could result 

in an individual being harmed. Tactfully intervene by promptly 

and effectively informing the appropriate individual that what 

he or she is doing, or is about to do, is contrary to safety or 

regulatory requirements and request that he or she takes 
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corrective actions immediately. If time permits, inform an 

appropriate manager or supervisor of the situation and let them 

give necessary direction to the person who appears to be about 

to take an unsafe action. 

Examples of unsafe conditions and violations that need to be 

immediately corrected include, but are not limited to: 

» failure to conduct an adequate survey after radiography 

source retraction prior to entry into the radiation area, 

» conduct of licensed activities by an unqualified or 

unauthorized individual,

» preparation for administration of licensed material to a patient 

without referencing the required written directive, and 

» non-conservative interpretation of conflicting source 

position indicators prior to entry into an high dose rate 

(HDR) afterloader treatment room. 

Immediately notify licensee management and your supervisor of 

such occurrences. This section is based on the policy in Field Policy 

No. 14 in NUREG-BR/0075, Rev. 4, “NRC Field Policy Manual.”

Inspection Opportunities

During travel, watch for licensed activities being conducted at 

temporary job sites and alter travel or inspection plans to conduct 

unplanned, unannounced inspections at temporary job sites.

Inspector’s Behavior and Attitude 

Do not handle licensed material or operate licensee equipment. 

Instead, observe authorized licensee staff handle licensed material 

and operate equipment. 

Learn by asking! Do not be afraid to ask the licensee questions 

that you cannot answer. Doing so will help you learn more about 

the licensee’s activities and radiation safety program. Maintain 

your integrity and enhance your rapport with licensee staff by 

admitting if you do not know something. 

Watch for, and take advantage of, opportunities to tour 

normally inaccessible areas or observe rarely conducted 

activities or operations.
1 3 MATERIALS INSPECTION & LICENSING HANDBOOK 2008

Under no circumstance should an inspector “test” 

the effectiveness of a licensee’s security systems 

by covert means, such as posing as someone else 

or intentionally causing the actuation of a security 

alarm. All challenges of a licensee’s security system 

must be conducted with the knowledge of appropriate 

licensee supervision.

Be approachable. If people feel intimidated by you, they are far 

less likely to talk to you.

Maintain a questioning attitude and verify information provided by 

the licensee and its contractors. Use all your senses. If something 

is different from what you expected, ask about it.

Use NRC staff colleagues as a resource if you have a question 

during the inspection. 

Figure 3. Good advice
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Interview Skills

Interview licensee staff to determine the status of compliance, 

assess the effectiveness of training, or evaluate an event. Be 

aware of what your objective is and what information you need to 

get from the interview. 

Take the time to loosen up the individual. Ask open-ended 

questions. Avoid leading and “yes or no” questions. Do not try 

to impress interviewees with your knowledge; it is sometimes 

advantageous if they think you are less well informed than you 

actually are. Listen to the interviewee even when you think you 

know what they are going to say. Control the interview, but let the 

individual have some time to talk about what they want to talk 

about. Be prepared to answer appropriate questions. 

Seek privacy for interviews whenever possible; 

interview individuals separately when reviewing 

an event. Expect contradictions in individual 

recollections following an event. Use hard facts and 

techniques such as time-lines to determine the most 

likely course of the event. 

Control your voice and non-verbal communication; remember your 

words carry less than 10 percent of the message, tone and body 

language the rest.

Do not jump all over an employee who gives you the wrong answer 

or provides information which indicates a violation. Do tell him or 

her what you are going to do with the information that he or she 

has provided. 

Users of radioactive material are typically not experts in health 

physics or NRC regulations; sometimes they simply do not 

understand a question, so when you get a “wrong” answer, 

try rephrasing the question in plain language; develop a 

complete picture before you conclude that employees have not 

been properly trained. 

Search for a new or relatively new employee and ask about his or 

her training experiences.
1 5 MATERIALS INSPECTION & LICENSING HANDBOOK 2008

Cameras

Cameras can be a very useful item during inspections to document 

work activities and the condition of rooms and equipment. 

However, always ask the licensee for permission prior to taking any 

photographs. Ask whether photographs taken reveal proprietary 

or other sensitive information. Record the response and the fact 

that you asked. Include something to give scale, but be careful 

about including faces or otherwise identifying information. Be 

aware that many mobile devices now contain cameras and that 

you may not be allowed to carry such mobile devices by some 

licensees or in some areas.

Allegations, Concerns, and Complaints

Consistent with Management Directive (MD) 8.8, “Management 

of Allegations,” licensees should NOT be made aware that you 

are looking into allegations during an inspection. Licensees may 

guess or reasonably conclude that you are, but the inspector should 

never confirm that fact. In this context, it is important to include 

allegation issues within the context of the full inspection and 

investigate non-allegation areas in a comparable level of detail.

During interviews of allegers, follow the same principles as 

discussed in the section on interviews, above, with added care to 

protect their identity.

Inspections resulting from allegations will be documented in 

accordance with MD 8.8. No reference to follow-up of an allegation 

or employee concern will be entered in the inspection records, 

inspection reports, or other documents that will be placed in the 

docket file. 

Safety Conscious Work Environment (SCWE)

Review and be aware of the licensee’s environment for raising 

safety concerns. Licensee employees should be encouraged to 

raise concerns to both their management and to the NRC without 

fear of retaliation. If the environment appears to discourage 

the raising of safety concerns, or a licensee employee states 

a concern in this area, talk with your supervisor to develop an 

approach to the situation.
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Licensees should have a policy for prohibiting harassment 

and retaliation for raising safety concerns. In addition, clear 

communications should be established to allow workers to voice 

concerns regarding safety, job site conditions, problems with 

meeting regulations, or other conditions that would prevent an 

employee from performing work in a safe and timely manner. 

Employee concerns should be addressed and corrective actions 

implemented when appropriate based on the significance of the 

issue.

Third Party Assistance

Be cautious in recommending third party assistance (consultants, 

equipment manufacturers, source manufacturers, etc.) to licensees. 

NRC employees are prohibited from recommending the services 

of any particular person or organization for projects under NRC 

regulatory jurisdiction. Regional procedures govern the appropriate 

process for recommending sources of assistance to licensees. 

Generally, referrals to widely known non-profit organizations are 

allowed (e.g., Health Physics Society, American Association of 

Physicists in Medicine, Society of Nuclear Medicine). Consult with 

your supervisor for further direction.

Non-Radiological Safety Concerns (OSHA Issues)

Memoranda of Understanding dated October 21, 1988, and 

July 26, 1996, between the NRC and OSHA provide for inspector 

involvement during inspections in the identification and 

disposition of safety concerns. Notify licensee management and, 

as appropriate, the NRC regional office OSHA liaison officer of nonradiological hazards personally observed or reported by licensee 

employees. Remember, OSHA regulations apply to you too! 

Facility Emergency

If an emergency or event occurs during an inspection, do not try to 

do the licensee’s job. Stay out of the way, but keep watching. Take 

notes; include times and who did what. Contact your office, but 

make sure the licensee makes all necessary reports. 

What if the licensee asks for advice? Be factual, not directive. 

Demonstrate by example that a calm response is usually the most 
1 7 MATERIALS INSPECTION & LICENSING HANDBOOK 2008

effective one. Ask occasional questions: “Have you reviewed your 

procedure? Is there someone, on your staff or otherwise, available 

to help you?”).

Personal Emergency

If a personal emergency occurs during an inspection, ask for 

appropriate help. Do not try to hide it, tough it out, or ignore a real 

need. Talk to your supervisor, and get advice on how to handle the 

emergency with the licensee. Tell the licensee what you are doing 

(they do not need details, just what is going to happen) or make 

arrangements for someone else to do it. Do not just disappear.

Exit Meeting

Preferably before leaving the site, clearly present possible 

violations to the highest level of management available, confirm the 

licensee’s understanding and agreement that a violation occurred, 

and determine that the licensee’s prompt corrective actions will 

be effective. When the licensee does not agree with your findings, 

make sure you understand their position well enough to argue it 

on their behalf. If you can do that, you will be able to explain the 

licensee’s position to your supervisor. 

The purpose of the exit meeting is to present the PRELIMINARY 

inspection findings and provide the licensee an opportunity to 

provide additional information that could change the findings. 

When possible, brief the RSO first regarding all of the findings.

Meet with the highest management representative available; from 

the NRC standpoint, everyone is welcome. However, remember it 

is their facility and they can control attendance. Outline the specific 

violations, citing the regulatory requirement and your understanding 

of proposed corrective actions, if known. Discuss positive findings 

and observations to send a “balanced” message. 

Give licensee management a chance for rebuttal and questions. If 

the licensee provides a convincing argument or new facts, consider 

it carefully. Do not be too quick to change your position, but do not 

be inflexible either. Make sure you understand and can explain to 

your management the licensee’s position.
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The message you deliver at the exit meeting is important. Make 

certain that you take the time necessary to develop the message. 

Organize your findings, place them in the correct context, and 

identify any additional informational needs you have.

Figure 4. Exit sign
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FUNCTIONAL AREAS

Radiation Protection

❯ Skin Exposure

Licensee staff should be aware of, and familiar with, 

the guidance related to skin exposure and reporting 

requirements, especially if the licensed material they use 

produces beta or low energy radiation. Review the licensee’s 

system for monitoring, controlling, measuring/calculating, 

and reporting skin dose from licensed material. Evaluate 

the appropriate use of dosimeters and dose calculations 

for normal handling of radioactive material and exposures 

from contamination. Personnel contamination monitoring 

(frisking or scanning) should be performed with appropriate 

detection equipment to detect beta radiation energies on a 

consistent frequency.

Evaluations of skin exposures near regulatory limits can be 

difficult. When you need to do such a review, do not hesitate 

to seek advice from an experienced colleague. 

❯ “High” Dosimeters

High or off-scale dosimeter readings must be evaluated by 

the licensee. The evaluation should include a review of the 

work performed during the time the dosimeter was worn, 

exposures received by other workers performing similar 

work, comparison to area monitors or dosimeters posted 
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in the area, all potential sources of higher dose (temporary 

or transient) in the work area, potential problems with the 

dosimeter, and sources of contamination or “false readings” 

on the dosimeter. This review and dose assessment must 

be clearly documented and stored with personnel dosimetry 

records.

High or off-scale dosimeters should be promptly reported to 

the RSO and licensee management. Personnel with high or 

off-scale dosimetry should be restricted in their work with 

radioactive material, or more closely monitored, until the 

review and dose assessment are concluded.

Remember that actual exposures in excess of regulatory 

limits must reported to the NRC Operations Center.

❯ High Radiation Areas:

Effective controls must be in place to warn workers regarding 

the hazard of high radiation areas, including physical 

boundaries, postings, and instructions (where appropriate). 

A dosimeter must be worn by workers entering highradiation areas.

Training

In addition to review of records and attending training sessions, 

evaluate training effectiveness by observing the actual conduct of 

licensed activities and asking questions of those individuals who 

actually perform the activities which are the subject of training. 

Portable Gauges

There is increased emphasis on the security of portable gauges 

both in use and in storage. Plan appropriate time to observe field 

use of gauges and interview the authorized users about their usual 

practices. In accordance with current requirements, 10 CFR Part 

30.34(i), “Security requirements for portable gauges”:

» At least two independent physical controls must be in place 

to prevent unauthorized removal of a portable gauge when 

the gauge is not under the control and constant surveillance 

of an authorized individual. In other words, to be in 

compliance, the physical controls must be arranged such 
2 1 MATERIALS INSPECTION & LICENSING HANDBOOK 2008

that in order to take the gauge an unauthorized individual 

must breach two separate barriers (locks, chains, etc.).

» Simply having two chains or cables with locks does 

not satisfy the security rule unless each chain and lock 

combination is physically robust enough to provide both a 

deterrence and a reasonable delay mechanism. 

» Remember, the NRC interprets “control and maintain 

constant surveillance” of portable gauges to mean being 

immediately present or remaining in close proximity to the 

portable gauge so as to be able to prevent its unauthorized 

removal. The person maintaining control must have the 

gauge within their line of sight and be sufficiently attentive 

to immediately identify an approach to the gauge. 

Determine whether the responsible workers know how to perform 

gauge maintenance without unnecessary exposures. Pay attention 

to the details of how the cleaning and maintenance are done to 

identify gaps in knowledge or poor practices. 

Fixed Gauges

Fixed gauges come in a variety of configurations and are used in 

varied environments. Plan some extra time to fully understand 

the gauges in the environment in which each is used. This will 

provide you with valuable information for future inspections or 

event reviews. 

Observe the licensee performing licensed activities. If no work is 

being done, observe demonstrations (use, leak tests, shutter tests, 

interlock tests, maintenance, surveys, etc.).

Lock-out procedures are key elements of many fixed gauge 

licensee safety programs. Evaluate compliance with lock-out and 

tag-out procedures. Observe staff implementing lock-out and tagout procedures, or observe them demonstrate how they have done 

it in the past or would do it in the future. 

Verify that gauge service and maintenance is conducted by 

authorized persons. Seek opportunities to observe and review the 

activities of the service and maintenance contractor. 

Take the opportunity to review generally licensed gauges which 

are present at the facility being inspected. Ask whether the 
2 2 UNITED STATES NUCLEAR REGULATORY COMMISSION

licensee has received and responded to requests from the NRC 

to register gauges in accordance with 10 CFR Part 31, “General 

domestic licenses for byproduct.” 

Inquire if any new gauges are planned for installation. It is 

often difficult to inspect gauge installations so consult with your 

supervisor about altering your schedule if you have an opportunity 

to conduct such an inspection.

Broad Scope

In large broad scope research and development programs it is 

easy to get lost in the volume of information received. In these 

situations it is most effective to inspect a cross section of the 

program. Be sure to include more than just frequent users or 

users identified by the licensee has having problems. You might 

want to select a few authorized users from each research building 

or department. Review the permits they have received from the 

radiation safety committee or RSO; look at their radioactive 

material receipts (Did the RSO control these purchases?); look at 

the audits which include their areas and travel to the laboratories; 

Figure 5. Survey meter
2 3 MATERIALS INSPECTION & LICENSING HANDBOOK 2008

follow a container of radioactive material from receipt through 

use and disposal. 

Determine if licensed material is secured, labeled, and posted as 

required. Interview the laboratory staff who use licensed material 

to determine if they are adequately trained, have adequate facilities 

and equipment, use the material safely, wear an appropriate 

dosimeter, perform proper surveys, and dispose of radioactive 

waste properly.

Determine where the RSO, radiation safety staff, or auditors have 

identified problems during surveys or audits. Review the licensee’s 

response to the problems and evaluate the effectiveness of actions 

to prevent similar problems. Do not “mine” the licensee’s audit 

reports for potential violations; use the audit findings to determine 

whether the licensee has an effective corrective action program. 

Accompany health physics technicians or the RSO on actual 

laboratory audits. Not only do you learn something about the 

operation of the laboratory, you learn something about the quality 

of the audit and the licensee’s ability to establish and implement 

corrective and preventive actions.

Conduct confirmatory surveys. Unexpected radiation levels or 

contamination can really drive home the importance of following 

safe use and survey procedures.

Evaluate the staff’s understanding of licensee emergency spill 

procedure by asking technologists in the laboratory what they 

would do if they dropped and broke a vial of radioactive material. 

If a technologist in the laboratory tells you they are not authorized 

to use radioactive materials, but they are authorized to work in 

the laboratory with users of radioactive materials, determine that 

they have received training on maintaining laboratory security, on 

segregating cold trash from hot trash, and for avoiding exposure 

to radioactive material.

❯ Contamination Control

Large licensees with many users and many laboratories have 

many opportunities to lose control of contaminated material, 
2 4 UNITED STATES NUCLEAR REGULATORY COMMISSION

particularly in waste. Carefully review the licensee’s 

program for segregating contaminated waste from other 

waste. Assure that the licensee has appropriate criteria and 

instrumentation for free-releasing potentially contaminated 

material. Pay particular attention to the controls on the 

collection of contaminated and non-radioactive waste. Past 

experience has shown that many individuals hired for the 

janitorial staff do not have good English language skills, so it 

is important that contaminated waste containers are clearly 

labeled and that training for service personnel is conducted 

in the appropriate language.

❯ Sealed Sources

Large licensees often do not keep meticulous track of sealed 

sources. Select several sources from the licensee’s inventory 

records and verify that the actual location of each source 

selected corresponds to its location in the record.

Radiography

There are many circumstances that may lead to unsafe conditions 

during radiography. These can be loosely attributed to either human 

performance or equipment performance. In the area of human 

performance, failure to survey with a calibrated and operable 

radiation survey instrument after each exposure to determine 

that the sealed source has returned to its shielded position has 

resulted in numerous exposures in excess of regulatory limits 

(reference 10 CFR 34.49(b), “Radiation surveys”). To be effective, 

such a survey must include the entire guide tube.

While there is no specific requirement controlling hours of work 

for radiographers, they often work long hours under significant 

deadline pressure. During your inspection, be mindful of the 

effect that fatigue and long hours can have on the performance of 

repetitive tasks. 

In addressing safety problems caused by human performance, 

10 CFR 34.41(a),“Conducting industrial radiographic operations,” 

requires that radiography may not be performed if only one qualified 

individual is present. The regulations in 10 CFR 34.46,“Superv

ision of radiographers’ assistants,” require the radiographer to 
2 5 MATERIALS INSPECTION & LICENSING HANDBOOK 2008

directly observe the radiographer’s assistant perform radiographic 

operations. The following brief scenario provides an example of a 

violation caused by deficiencies in human performance.

The radiographer left the immediate vicinity of the radiographic 

operations to perform other tasks or moved a distance away and 

turned his back to the radiographic operation. These actions left the 

radiographer’s assistant alone to monitor the exposed source and 

the radiation area. During the time that the radiographer was not 

in the immediate area, he was not capable of providing immediate 

assistance to prevent unauthorized entry into the radiation area 

and could not directly observe the radiographer’s assistant during 

radiographic operations. 

With regard to equipment performance, ask what the licensee 

does to identify survey instruments in need of repair. Does the 

license ensure that repaired instruments are calibrated prior to 

first use?

Consider the following key points when reviewing equipment 

inspection and maintenance [10 CFR 34.31(b)(1), “Inspection and 

maintenance of radiographic exposure devices, transport and 

storage containers, associated equipment, source changers, and 

survey instruments”]:

» Does licensee staff examine the distal end of drive cable 

(near male connector) for wear? Information Notice 97-

91, Supp. 1, “Recent Failures Of Control Cables Used On 

Amersham Model 660 Posilock Radiography Systems,” 

discusses the need for licensees to inspect and maintain 

drive cables.

» Does licensee staff examine the distal end of the male 

connector for excessive wear and look for the male 

connector being off-axis relative to the drive cable? (One 

manufacturer indicates that if the angle of the male 

connector is >10 degrees, it could cause excessive wear 

of the distal end of the male connector by friction on the 

interior lumen of the guide tube.)

» Does licensee staff verify that following crank maintenance 

all of the parts are installed and all staff are aware of 

changes in the handle configuration?
2 6 UNITED STATES NUCLEAR REGULATORY COMMISSION

» Does the staff check for loose hardware and know what to 

do if it is identified?

» How does the licensee ensure that radiographic equipment is 

maintained in accordance with NRC regulatory requirements?

» One of the major equipment manufacturers instructed 

customers to revise their quarterly inspection program to 

include misconnect tests for each set of drive cables used. 

The basis for the test is that, although wear of specific 

components may be within specifications, a misconnect can 

occur when slightly worn components are used together. 

What was the licensee’s response to this advice?

» Does the staff recognize that noises during cranking 

indicate a potential problem? Do they know how to respond 

appropriately?

» Does the staff use the Posilock indicator or challenge 

Posilock actuation after source retraction?

The NRC does not authorize the use of pipeliner devices because 

these devices do not meet the performance requirements 

in 10 CFR 34.20, “Performance requirements for industrial 

radiography equipment.” A pipeliner device is one that is directly 

connected to the pipe and does not have the “S” tube; the source 

is exposed by moving a lever or rotor. Pipeliners have been used 

on offshore barges and platforms in the past. Some licensees argue 

it is the best device for performing the work in these locations 

Figure 6. Radiographer preparing for work
2 7 MATERIALS INSPECTION & LICENSING HANDBOOK 2008

because quarters are tight and shots must be completed quickly. 

Watch for the presence or use of these devices.

Licensees may, in response to a particular job or other 

circumstance, develop a “Permanent Radiographic Installation.” 

This is defined as an enclosed shielded room, cell, or vault not 

located at a temporary jobsite, in which radiography is performed, 

without meeting the necessary requirements (see 10 CFR 34.33, 

“Permanent radiograhic installations.” Examine facilities where 

radiography is performed to determine whether they should be 

designated as permanent radiographic installations. 

Medical

Unless you need to intervene to prevent an unsafe situation, your 

observation of work activities should not interfere with a patient’s 

care or privacy.

Obtain patient permission before observing dose administrations. 

Observe an authorized individual administer material listed in 10 

CFR 35.300, “Use of unsealed byproduct material for which a written 

directive is required,” or have them demonstrate how it was or would 

be administered. Look for good use of time, distance, and shielding 

to reduce radiation exposure when preparing and administering 

doses. If possible, discuss the written directive components and the 

release criteria with the authorized user. If the licensee is releasing 

a patient to their home, observe the authorized user questioning 

the patient or family about the home environment and compare the 

information collected to the release criteria in NUREG-1556, Volume 

9, “Consolidated Guidance about Materials Licenses Licenses: 

Program-Specific Guidance About Medical Use Licenses.” 

Interview selected staff who care for patients hospitalized 

in accordance with 10 CFR 35.75, “Release of individuals 

containing unsealed byproduct material or implants containing 

byproduct material,” to determine if they are properly trained 

(i.e., size and appearance of sources, safe handling and shielding 

of sources, patient and visitor control, and medical emergency/

death response). Review both the licensees planned and actual 

responses to such emergencies.
2 8 UNITED STATES NUCLEAR REGULATORY COMMISSION

Some key questions:

» Does the licensee understand the definition of a “medical 

event” (with special focus on 10 CFR 35.3045(a)(3), “Report 

and notification of a medical event”)?

» Does the licensee take action to separate exposure from 

x-ray and exposure from licensed material?

» How does the licensee account for variation in dose 

calibrator response due to geometrical variation (differences 

in container size and shape) and differences in container 

composition (plastic vs. glass) for pure beta emitters (e.g., 

strontium-89, phosphorus-32, samarium-153)?

Supervision

There is a wide variety of skill and knowledge level in the staff 

involved with medical programs using licensed material. 

» Does the RSO oversee all aspects of the radiation 

safety program, including those that he or she is less 

comfortable with?

» If the licensee relies on a consultant to complete required 

tasks, what does it do to ensure that the tasks are 

completed as required? Does the licensee audit the 

consultant’s work or observe that the consultant conducts 

the required tasks? 

Brachytherapy

This treatment modality presents many opportunities for medical 

events and radiation safety occurrences such as lost or misplaced 

sources. This is especially true for licensees who employ the 

modality infrequently. 

Does the licensee take actions to ensure that the brachytherapy 

applicator and sources are adequate to deliver the radiation dose 

prescribed on the written directive? For example, does the licensee 

perform acceptance testing to ensure that sources stay in position 

within the applicator? Does the licensee ensure that the dummy 

sources are the same physical size as the actual sources? 

Review written directives and ensure all required components 

are present. If possible, observe an implant after obtaining 

permission from the patient and the authorized user. Confirm that 
2 9 MATERIALS INSPECTION & LICENSING HANDBOOK 2008

written instructions are provided to patients who are released 

with permanent implants. 

Review post-implant dosimetry and note any differences from the 

pre-implant dosimetry. Discuss any differences with the licensee. 

If it appears that a medical event may have occurred, discuss this 

possibility with the licensee and obtain copies of all documentation 

for further review.

High Dose Rate Afterloader

More licensees are using this modality and there are a number of 

considerations that are specific to the use of HDRs.

Ask the licensee to demonstrate its daily checks and compare your 

observations to the license commitments and the regulations. Consider 

asking the licensee to demonstrate that the connector must be fully 

engaged and connected to the correct channel before the treatment 

can begin (a connection failure was the cause of at leat one mammosite 

medical event). Also consider asking the licensee to demonstrate that 

the fitting for the connector is appropriately varied by type of treatment; 

and that the HDR or accelerator switch prohibits dual operation. 

Observe selected staff demonstrate implementation of the licensee’s 

emergency response procedures using different scenarios (e.g., 

stuck source in patient, source does not fully retract into unit at 

end of treatment).

Gamma Stereotactic Radiosurgery (GSR or Gamma Knife)

This is a very complex modality. Great care and consistency are 

needed to avoid medical events.

» Ask the licensee to demonstrate its daily checks; compare 

your observations to their license commitments and the 

regulations. 

» Ask the licensee to demonstrate patient setup and double 

checks. 

» Ask the licensee to describe its procedures for security of 

the unit and the unit’s keys, and how they implement the 

physical presence requirements. 

» Review a sample of treatment plans and ask the authorized 

medical physicist to walk you through the planning stages.
3 0 UNITED STATES NUCLEAR REGULATORY COMMISSION

» Ask what the licensee has done to prevent common medical 

events. For example, a GSR unit A medical event occurred 

with a GSR unit because a microphone clip came off of the 

patient couch and jammed the collimator jaws. What has 

the licensee done to prevent this type of occurrence?

Radio-Pharmacies

These licensees frequently have problems with hand exposures 

and the implementation of their ALARA program. Since speed and 

technique are very important factors in determining the actual hand 

exposure received, look at individual exposures and the licensee’s 

evaluation of and response to them. Also, compare the licensee’s 

instructions for placement of extremity dosimetry to actual 

implementation. Assure that the location of highest exposure is 

measured, and if not, assure that appropriate changes are made.

For pharmacies that dispense beta-emitters, verify that geometry 

dependence tests include appropriate use of calibration factors and 

the entire range of containers and product volumes used. Assure that 

container size (3 ml vs. 30 ml), product volume (1 ml dosage vs. 10 ml 

dosage), and container materials (plastic vs. glass) are considered.

While the constraint rule, 10 CFR 20.1101(d), “Radiation protection 

programs,” applies to most licensees, it is most often an important 

consideration at radio-pharmacies handling iodine-131. Examine 

the licensee’s assumptions, measurements, and calculations to 

demonstrate compliance with the rule. 

Panoramic Irradiators

There are NRC publications (NUREG-1345, “Review of events at 

large pool-type irradiators and lessons learned from accidents 

at industrial radiation facilities, IAEA, 1996,” Information Notice 

89-82, “Recent Safety-Related Incidents at Large Irradiators,” 

Information Notice 91-14, “Recent Safety-Related Incidents 

at Large Irradiators,” Information Notice 94-89, Equipment 

Failures at Irradiator Facilities), and other literature which 

discuss safety hazards, past accidents, and near-misses at large 

panoramic irradiators. Use this guidance to enhance preparation 

for panoramic irradiator inspections. 
3 1 MATERIALS INSPECTION & LICENSING HANDBOOK 2008

Determine by interviewing a sample of operators and maintenance 

personnel if the licensee ever bypasses interlocks or any other 

safety systems. Determine how the licensee either prevents such 

bypasses or exercises appropriate management controls when a 

bypass is deemed necessary. 

Pay particular attention to the procedures for testing interlocks. 

It is difficult to review the actual design and “wiring” of the 

interlock logic when a programmable logic controller is used. This 

makes effective testing of interlocks especially important. Does 

the licensee keep printouts of the interlock tests, showing the date 

and details of completion? Use these to verify other records.

Consider looking closely at the controls over access to handling tools 

for sources. Access to these tools affects both safety and security. 

Self-Shielded Irradiators

Self-shielded irradiators, especially those in which the source itself 

does not move, do not normally present a radiation safety problem. 

However, self-shielded irradiators with moving parts periodically 

require repair, and during repairs there is an increase in the potential 

for dose. Assure that only an authorized service provider has 

performed work which could affect the source shielding. Determine 

whether the licensee has had any mechanical problems with the 

irradiator and who it would call if mechanical problems occur. 

Figure 7. Laboratory safety
3 2 UNITED STATES NUCLEAR REGULATORY COMMISSION

Well Logging

These licensees make frequent transfers of radioactive sources 

from storage containers to logging tools and back to the container 

in field conditions. Past incidents have shown that well logging 

sources do, periodically, fall off the handling tools during source 

transfers. Logging crews usually discover that the source has 

become detached and recover it quickly and safely. However, 

the potential for unnecessary exposures and for exposures 

exceeding the dose limit is high whenever such an event occurs. 

Pay particular attention to the implementation of the licensee’s 

procedures requiring logging personnel to perform a confirmatory 

radiation survey, before leaving the well site, to confirm the proper 

transfer of sealed sources to their shielded containers. Examine 

whether loggers know the procedure and always have a working 

radiation detection meter to perform the survey. 

Decommissioning

These are often complex operations involving a wide range of 

activities and risks. Worker radiation exposures are often not 

significant, but frequent surveys and evaluations are important 

because the licensee often does not have completely reliable 

information about every area of the site. Areas to be considered 

for particular attention are: 

❯ Radiological Instrumentation

Always make sure that the instrument you or the licensee 

is using can adequately measure the isotope of interest. 

Instruments should have a current calibration sticker. 

Verify that a daily source check has been performed prior 

to the use of the instrument. Verify that the licensee has 

taken into consideration that very cold and hot weather can 

affect an instrument’s response. For example, in very cold 

weather, additional detectors may be kept in a warming 

area so they can be changed frequently to keep them as 

warm as possible.

❯ Surveys

Observe workers performing surveys. The licensee should 

be able to provide you with the minimum detectable activity 
3 3 MATERIALS INSPECTION & LICENSING HANDBOOK 2008

(MDA) and scan speed for the detectors being used for the 

survey. As a rule of thumb, gamma scanning soil with a 

sodium iodide (NAI) detector should be performed at about 

0.5 meters per second (1.5 feet per second), depending on 

conditions. When surface scanning with an alpha scintillator, 

the probe should be kept less than 1 cm (0.5 inch) from 

the surface. Hand frisking of skin and clothing should be 

performed with the probe 1 centimeter (0.5 inch) from the 

surface and at a speed of 2 to 5 centimeters per second (1–

2 inches per second). 

❯ Radiation Protection Standards and Practices

Verify that workers are adhering to proper radiation 

protection standards and practices. For example, verify that 

workers are wearing radiation dosimeters in conformance 

with facility-specific requirements and are maximizing the 

use of low-dose waiting areas. During contaminated area 

entries, observe workers and verify that they are properly 

donning anti-contamination clothing before entering the 

area and properly removing their protective clothing upon 

exiting the area. Verify that workers passing tools and 

other equipment across contaminated area boundaries are 

following good radiation protection practices.

❯ Sinks, Drains, and Ventilation Systems

Areas occasionally neglected by a licensee during 

decommissioning activities are the sinks, drains, and 

ventilation systems. Through discussion with the licensee, 

verify that these areas were adequately addressed, including 

the potential for the reconcentration of contamination at 

a downstream location which could lead to a localized hot 

spot. Optimally, the licensee has collected samples at points 

downstream of these locations.

❯ Vacuums

Vacuums with high efficiency particulate–air (HEPA) filters 

are commonly used during decommissioning activities. 

Verify the licensee is regularly checking the dose rates of 

the units containing the filter as well as the hose lines. As 

contamination builds up on the filter, it can result in elevated 
3 4 UNITED STATES NUCLEAR REGULATORY COMMISSION

dose rates around the unit, and occasionally a hot particle can 

lodge in the vacuum hose creating a localized high dose area.

❯ Electrical

Verify that areas are adequately illuminated and sufficient 

electrical outlets are available for the decommissioning work 

being performed. Some decommissioning facilities will install 

a new electrical system and deactivate the existing system 

to minimize the potential for cutting into a “live” wire. Watch 

for electrical cords and equipment that may be located in 

standing water, or in low areas that may flood during rainy 

weather, or that create a tripping hazard for workers.

❯ Scaffolding

Temporary scaffolding may be erected during some 

decommissioning activities. Verify that it is erected 

in accordance with the licensee’s scaffolding erection 

procedures. Verify scaffolding is not directly attached to 

instrument racks or piping supports, does not interfere with 

the operation of equipment such as ventilation dampers, 

and does not block access to fire protection equipment such 

as hose reels, fire extinguishers, and fire doors.

❯ Heavy Loads

The movement of heavy loads, such as sea/land containers, 

B-25 boxes, or other demolition material, can be a significant 

safety concern if these loads were to fall unexpectedly. Keep 

cognizant of heavy load lifts. Verify to the extent practicable 

that they are being conducted safely. Verify that the crane 

or lifting device is rated above the weight of the load being 

lifted. Verify the rigging is in good physical condition and 

has been properly inspected and maintained. Look at the 

general condition of the crane or lifting device. Immediately 

inform licensee personnel about any cracks indicative of an 

overloaded condition.

❯ Safety

During any decommissioning or demolition work, personal 

safety is the number one concern. Verify that an appropriate 

focus on safety exists with management and is consistently 

communicated to the workers.
3 5 MATERIALS INSPECTION & LICENSING HANDBOOK 2008

Inspections of decommissioned sites often entail 

surveys of older and poorly maintained buildings. 

Caution should be exercised any time there is a 

need to conduct surveys on roofs and around rooftop ventilation points. Always discuss the structural 

integrity of roofs and other structures with the 

licensee prior to conducting surveys in any area that 

may pose a safety risk.

❯ Personal Protective Equipment

Verify personnel are wearing all required personal protective 

equipment (PPE) such as hearing protection, eye protection, 

and head protection. Additional protection may be required 

based on local conditions, such as double hearing protection 

in designated areas; the use of a lanyard with a breakaway feature for the display of identification badges and 

dosimetry; tucking in of neckties and other loose clothing 

in the vicinity of rotating equipment; and footwear that 

protects against injury due to falling objects.

❯ Fall-Related Injuries

Verify that ladders are sturdy and do not wobble. Verify 

that licensee personnel are using ladders in a safe manner, 

including the use of ties and blocking. A ladder tender 

can also help avoid a fall. No one should ever stand on the 

top step of a ladder. Another area of concern occurs when 

personnel attempt to carry items up or down a ladder. Be 

aware of this when walking to or from an activity and ensure 

that no one is carrying more than what is safe. Anyone on a 

ladder should have three points of contact at all times (i.e., 2 

feet and 1 hand, or 2 hands and 1 foot). Verify that workers 

use safety harnesses, when required.

❯ Heat Stress Awareness

Some decommissioning work involves high heat and humidity 

levels. Verify that licensee personnel have taken adequate 

precautions to protect workers from heat-related stress.

❯ Tanks and Pools

If tanks or pools contain pumps or hoses for maintaining 
3 6 UNITED STATES NUCLEAR REGULATORY COMMISSION

the cleanliness of the water or for vacuuming, verify that 

an inadvertent drain-down cannot occur from back-suction. 

Temporary hoses should not be left unattended with one 

end underwater. For hoses or lines that will be left in a tank 

or pool for an extended period, verify that the suction line is 

kept near the top of the water. This assures that, in case a 

back-suction event does inadvertently occur, only a minimal 

amount of water will be drained. 

❯ Asbestos, Lead, Mercury, and PCBs

Sites being decommissioned and demolished often contain 

asbestos, switches containing mercury, lead paint, PCBs or 

other hazardous materials. These materials may or may not 

be mixed waste (i.e., are also radiologically contaminated), 

but in either case will require special handling. Verify that 

the licensee is looking for these materials and has a process 

for handling and disposing of them.

Transportation

Carefully review the specific regulatory requirements involved in 

transportation issues, since there are many exemptions, depending 

on the specific circumstances involved. Assure that the licensee 

has considered the appropriate regulatory requirements for the 

materials they are shipping. 

Avoid hasty conclusions regarding radiation or contamination 

levels on packages containing radioactive material from shipper 

to receiver, even if the receiver’s numbers seem to indicate a 

violation. Investigate. Many differences can be explained by 

variation in instrumentation or measurement technique. While 

these differences may indicate a violation, have all the facts and 

understand the situation before you decide. 

Event Review

Follow-up on the licensee’s response to events that occurred since 

the last inspection. Focus on notification, reporting, and corrective 

actions to prevent similar events.

For reenactments, consider using a locking tape measure, a stop 

watch, a still camera (digital, if possible), a video camera (digital, 
3 7 MATERIALS INSPECTION & LICENSING HANDBOOK 2008

if possible), or a tape recorder. Digital video is the most efficient 

way to establish time, sequence of events, and relative locations. 

Multiple reenactments may be necessary, especially if dose rates 

are high and the series of movements is complex.

Fully evaluate the licensee’s corrective actions to prevent 

similar events or violations and observe any licensee equipment 

modifications to determine if there is potential compromise of the 

equipment’s designed safety features. 

Evaluate whether there are generic implications of the event.

Medical Event Follow-Up

Reactive inspections involving a medical event require special 

attention and must be performed using the guidance in MD 8.10, 

“NRC Medical Event Assessment Program.” Take particular care to:

» Obtain all details of the event (i.e., a chronology).

» Identify the root causes and contributing factors.

» Obtain the licensee’s assessment of the effects on the 

patient.

» Understand the licensee’s corrective actions to prevent 

similar medical events or violations.

» Review the licensee’s implementation of procedures 

for administrations requiring a written directive. Do all 

appropriate staff understand what constitutes a written 

directive and when one is necessary?

» Evaluate compliance with medical event notification 

requirements, including proper reporting to the NRC 

Operations Center, referring physician and patient (if 

appropriate) within 24 hours of discovery; 15-day written 

report to NRC, physician, and patient (if requested). 

Service Providers

Analytical laboratories and other licensees authorized to provide 

services using or related to nuclear materials are included in this 

group. During inspection, assess whether licensees are getting 

accurate and reliable services from the providers. Keep in mind 

that it is primarily the customer’s responsibility to assure reliable 

service. The agency often gets information generated by service 
3 8 UNITED STATES NUCLEAR REGULATORY COMMISSION

providers during other inspections and in the licensing process. 

Keep in mind that failing to provide accurate service may not be a 

violation for the service provider. 

When inspecting a licensee conducting inservice leak tests, 

reviewers should scrutinize the details of the equipment and 

procedures so that they can conclude a good leak test analysis can 

be performed for each radionuclide tested. Check their minimum 

detectable activity calculations, and their calibration procedures 

and standards, especially if they are testing for nickel-63 or other 

non-gamma emitters.

Review of calibration is even more important for analytical labs 

that do wipe test analysis, and analysis of water and soil and other 

samples. Review their control charts to ensure that the equipment is 

maintained and operable, check their minimum detectable activity, 

understand the standard geometries for which they are calibrated 

and how they deal with new geometries or sample types, and look 

at their participation and results in cross-check programs.

At instrument calibration facilities, check the National Institute of 

Standards and Technology (NIST)-traceability of sources used to 

calibrate the various meters and detectors. Review the procedures 

for calibrating the very low and very high ranges and verify that 

the calibration facility produces accurate readings (some facilities 

may be narrow with walls that cause too much backscatter). 

For licensees installing or servicing devices containing radioactive 

material, it is very important to observe the activities of service staff 

in the field, and evaluate their radiation safety practices in action. 

Ensure that the individual has adequate survey instrumentation and 

dosimetry, and adequate understanding of safety procedures required 

by the license and of the procedures for servicing the device. 

Reciprocity

Determining whether the NRC or an Agreement State has 

jurisdiction for reciprocity purposes can be complex and confusing. 

In general, Federal licensees are regulated by the NRC; nonFederal licensees operating in areas subject to exclusive Federal 
3 9 MATERIALS INSPECTION & LICENSING HANDBOOK 2008

jurisdiction are also regulated by the NRC. Indian reservations are 

subject to exclusive Federal jurisdiction under most circumstances. 

Non-Federal licensees operating in areas that are not subject to 

exclusive Federal jurisdiction are regulated by the Agreement 

State in which the facility is located.

Experience has shown that the Federal agency responsible for the 

location where the licensed activities occur is the best source for 

a decision about whether the NRC or the Agreement State has 

jurisdiction. It is the responsibility of the licensee to operate in 

compliance with NRC and Agreement State regulations and it 

normally has a relationship with the entity that controls the site 

of the licensed activity. Therefore it is usual to expect that the 

licensee will obtain the information necessary to make a correct 

jurisdictional decision. 

Agreement State licensees will usually be authorized to work within 

NRC jurisdiction if they are authorized to work at temporary job sites 

in their licensing jurisdiction and can comply with the requirements 

of 10 CFR 150.20, “Recognition of Agreement State licenses.” 

Radiography at nuclear power plant sites cannot be performed 

under the 10 CFR Part 50, “Domestic licensing of production and 

utilization facilities,” license and must be performed under a valid 

license which authorizes radiography. Nuclear power plants are not 

areas of exclusive Federal jurisdiction for purposes of reciprocity. 

Therefore, within each state, Agreement States have jurisdiction 

over radiography at nuclear power plants.

Figure 8. Radiography equipment

BEST PRACTICES

MATERIALS

INSPECTION

& LICENSING

HANDBOOK

INSPECTION

4 1 MATERIALS INSPECTION & LICENSING HANDBOOK 2008

SECURITY ISSUES

The public and other governmental bodies have an increased interest 

in the security of licensed material. Therefore, reviewers must assess 

the overall security posture of the licensee as well as security issues 

described in the inspection procedures. Encourage licensees to be 

sensitive to and report unusual events as recommended by NRC 

generic communications. 

There is significant evidence that many violations of the “Orders 

Imposing Increased Controls” (Increased Control Order) are caused 

by licensees not thoroughly understanding the requirements in 

the order and, therefore, not implementing them. Be prepared to 

take additional time to review the bases for any violations of the 

Increased Control Order and assure that the licensee knows where 

to find the implementing guidance. Additional attention during the 

inspection has improved the licensee’s ability to plan, present, and 

implement effective corrective actions. 

Information security has become of even greater importance in the 

post-9/11 environment. In the same way that all licensees have received 

other generic communications from the NRC, be sure that the licensee 

has a copy of and has considered the guidance in Regulatory Issue 

Summary 2005-31, “Control of Security-related Sensitive Unclassified 

Nonsafeguards Information Handled by Individuals, Firms, and 

Entities Subject to NRC Regulation of the Use of Source, Byproduct, 

and Special Nuclear Material.”

BEST PRACTICES

MATERIALS

INSPECTION

& LICENSING

HANDBOOK

LICENSING

4 3 MATERIALS INSPECTION & LICENSING HANDBOOK 2008

LICENSING

General

Re-read a deficiency letter, safety evaluation report, or license after 

a break. Ask yourself whether a reasonable technical person who 

read only the licensee’s correspondence and your letter would 

understand your conclusions and questions. 

Before completing a licensing action ask yourself: 

» What has the licensee requested? 

» Does the package of letter, enclosures, and license respond 

to each of the licensee’s requests?

» Did I recognize and address all potential safety issues?

» Should I ask my colleagues for their insights?

Guidance documents may not address all safety issues. Focus on 

safety issues and ask questions to satisfy the goal of safe operation. 

For example, no rule limits the number of facilities one Radiation 

Safety Officer may service. However, reviewers have recognized 

that it could become a safety issue when a radiation safety officer 

has responsibility for too many facilities and reviewers have 

developed further questions to address that issue. 

Medical

The regulations in 10 CFR Part 35 are largely performance-based 

(except for prescriptive elements of 10 CFR 35.600, “ Use of a sealed 
4 4 UNITED STATES NUCLEAR REGULATORY COMMISSION

source in a remote afterloader unit, teletherapy unit, or gamma 

stereotactic radiosurgery unit”). Therefore, license reviewers have 

few procedures to review. However, confirming that proposed 

authorized individuals meet the necessary requirements is one 

of the most important, potentially safety-significant aspects of 

medical licensing, particularly for authorized users and authorized 

medical physicists associated with therapy authorizations. It is 

also one of the most difficult assignments to complete. Take the 

time to properly review these parts of the licensee’s application. 

Review previous medical enforcement cases to familiarize yourself 

with how qualifications were found deficient. 

Review the licensee’s therapy facilities and procedures against the 

applicable American Association of Physicists in Medicine (AAPM), 

American National Standards Institute (ANSI), and National Council 

on Radiation Protection and Measurements (NCRP) documents. 

There are several new AAPM and NCRP documents that have 

not received program office review (e.g., NCRP Reports No. 147, 

“Structural Shielding Design For Medical X-ray Imaging Facilities,” 

and 151, “Structural Shielding Design And Evaluation For Mega 

Voltage X- And Gamma-ray Radiotherapy Facilities (2005)”). If a 

licensee bases its submission on one of these documents, consider 

preparing a technical assistance request.

Service Licenses

The main guidance document for licensing service providers is 

NUREG-1556, Volume 18, Consolidated Guidance About Materials 

Licenses: “Program-Specific Guidance About Service Providers.” An 

important objective of licensing these organizations is assuring that 

each service provider is prepared to operate safely with respect to its 

own workers, the customer, the general public and the environment. 

However, since other licensees rely on these organizations to 

conduct key activities for them, you should also assess how well 

prepared they are to provide accurate and reliable services. 

❯ Nuclear Laundries

In licensing a nuclear laundry, it is very important to assure 

that the functions of laundering reusable garments and 
4 5 MATERIALS INSPECTION & LICENSING HANDBOOK 2008

other reuseable items does not become confused with with 

the functions of a waste broker. The NRC usually requires 

nuclear laundry licensees to return non-launderable material 

to the customer rather than dispose of it as radioactive 

waste. This discourages customers from including nonlaunderable material in their laundry shipments. However, 

the use of dissolvable garments has caused some blurring 

of this position. See letter from Paul R. Lohaus to UniTech 

Services Group, Inc., dated October 23, 2002 (Agencywide 

Documents Access and Management System (ADAMS) 

Accession No. ML022960614).

Review of a laundry license application should include a 

careful review of the processing and disposal of waste water. 

There is a history of nuclear laundries causing increased 

concentrations of radioactive material at public sewage 

treatment facilities even though they meet all regulatory 

requirements for discharges. 

❯ Decommissioning Contractors:

In addition to NUREG-1556, Volume 18, important guidance 

for licensing decommissioning contractors is found in 

Policy and Guidance Directive FC-94-02, “Licensing Site 

Remediation Contractors for Work at Temporary Job Sites.” 

An important consideration for these licenses is the fact that 

site owners and operators may not have radiation safety 

programs in place that are adequate to ensure safe and 

effective decommissioning of the site. Therefore, it may be 

appropriate for a decommissioning or remediation contractor 

to operate under its own license at temporary job sites and 

provide the radiation safety program under which the work 

is performed.

If the site owner and operator (i.e., the customer) also holds 

a license issued by the NRC or an Agreement State, the 

service license should require the establishment of a written 

agreement between the licensee and the customer. This 

agreement should specify which licensed activities will be 

performed under the customer’s license and supervision, and 

which licensed activities will be performed under the service 
4 6 UNITED STATES NUCLEAR REGULATORY COMMISSION

licensee’s license and supervision. This agreement should 

include commitments by both licensees to ensure safety and 

it should specify whether there are any commitments by the 

service licensee to help the customer clean up the temporary 

job site if there is an accident or event.

Normally licenses authorizing decommissioning or 

remediation activities as a service require that the licensee 

notify the NRC or Agreement State regulator prior to 

beginning activities at a temporary job site. 

Decommissioning

For licensees that have been active for a long time and are now 

decommissioning either all or part of their facilities, reviewers 

should evaluate all old licensing and inspection documentation to 

see what and where radioactive materials were used in the past. 

This documentation may be helpful in evaluating the licensee’s 

historical review for the buildings, rooms, and special facilities 

that the licensee is requesting to be removed from the license. 

The licensee’s current staff may not be familiar with the site 

history, and may lack adequate records of where and what types 

of radioactive material were used in the past. 

The guidance for approving the release of potentially contaminated 

solid material from a decommissioning site is complex. Important 

documents providing part of the guidance are contained in the 

ADAMS package “Update on case-specific licensing decisions 

on controlled release of solid materials from licensed facilities 

(ADAMS Accession No. ML030020655).”

Financial Assurance

When removing facilities or radionuclides from a license and 

reducing the associated financial assurance, the licensee must 

demonstrate that facilities in which these radionuclides were 

or might have been used do not have residual contamination 

exceeding the license termination criteria found in Subpart E of 

10 CFR Part 20, “Radiological criteria for license termination.” The 

licensee may use the a dose assessment method or the screening 

criteria described in NUREG-1757, Vol. 2, Rev. 1, “Consolidated 
4 7 MATERIALS INSPECTION & LICENSING HANDBOOK 2008

Decommissioning Guidance: Characterization, Survey, and 

Determination of Radiological Criteria,” to prepare the assessment 

to demonstrate the facilities meet the regulatory requirement. 

The licensee may be able to use the survey method described in 

NUREG-1757, Vol. 2, Rev. 1, Appendix B, “Simple Approaches for 

Conducting Final Radiological Surveys.” If the licensee’s internal 

survey criteria are more restrictive than the screening values, 

the licensee’s periodic survey results may provide information to 

support a demonstration that a particular facility meets the license 

termination criteria. 

BEST PRACTICES

MATERIALS

INSPECTION

& LICENSING

HANDBOOK

4 9 MATERIALS INSPECTION & LICENSING HANDBOOK 2008

WORKSHEETS

The following pages include simplified worksheets for 

financial assurance (FA).
5 0 UNITED STATES NUCLEAR REGULATORY COMMISSION

License No. ______________________ 

10 CFR 40.36 “Financial assurance and recordkeeping for 

decommissioning, source material in readily dispersible 

form”

Radionuclide 

Authorized

Quantity 

Authorized

Quantity 

Requiring FA

Fraction

uranium - natural 10 mCi

uranium depleted10 mCi

thorium - natural 10 mCi

thorium-230 10 mCi

thorium-232 10 mCi

thorium-230

(from BPM 

license)

10 mCi

If sum of fractions is: 

≤ 1, no FA is required.

> 1 but ≤ 10, $225,000 certification amount is 

required.

> 10, a Decommissioning Funding Plan (DFP) is 

required.
5 1 MATERIALS INSPECTION & LICENSING HANDBOOK 2008

License No. ______________________ 

10 CFR 30.35, “Financial assurance and recordkeeping for 

decommissioning, byproduct material (BPM),

unsealed materials”

Radionuclide

Authorized In 

Unsealed Form

Quantity 

Authorized

Quantity Requiring 

Fa

Fraction

Any BPM 3–83 0.01 mCi 

(Most restrictive 

radionuclide from 

10 CFR Part 30, 

App B)

Any BPM > 83 0.01 mCi

(Most restrictive 

radionuclide from 

10 CFR 30, App B)

hydrogen 3 1000 mCi

carbon 14 100 mCi

strontium 90 0.100 mCi

cesium 137 10 mCi

lead 210 0.01 mCi

polonium 210 0.01 mCi

radium 226 0.01 mCi

americium 241 0.01 mCi

If sum of fractions is:

≤ 1, no FA is required.

> 1 but ≤ 10, $225,000 certification amount is 

required.

> 10 but ≤100, $1,125,000 certification amount is 

required.

> 100, a Decommissioning Funding Plan (DFP) is 

required.
5 2 UNITED STATES NUCLEAR REGULATORY COMMISSION

License No. ______________________ 

10 CFR 70.25, “Financial assurance and recordkeeping 

for decommissioning, special nuclear material, unsealed 

materials”

Radionuclide 

Authorized

Quantity 

Authorized

Quantity 

Requiring 

Fa

Fraction

uranium 233 0.01 mCi

uranium 235 0.01 mCi

Specific Activity of 

uranium 235 = [0.4 + 

0.38(enrichment) + 

0.0034(enrichment)2] 

E-6 curies per gram (see 

Note 3 to Appendix B to 

10 CFR Part 20)

plutonium 238 0.01 mCi

plutonium 239 0.01 mCi

plutonium 240 0.01 mCi

plutonium 241 0.01 mCi

plutonium 242 0.01 mCi

plutonium 244 0.01 mCi

If sum of fractions is:

≤ 1, no FA is required.

> 1 but ≤ 10, $225,000 certification amount is 

required.

> 10 but ≤100, $1,125,000 certification amount is 

required.

> 100, a Decommissioning Funding Plan (DFP) is 

required.
BEST PRACTICES

MATERIALS

INSPECTION

& LICENSING

HANDBOOK

5 3 MATERIALS INSPECTION & LICENSING HANDBOOK 2008

INDEX

B

Brachytherapy 28

C

Contamination 19, 20, 23, 33, 36, 

46

D

Decommissioning 32, 33, 34, 35, 

45, 46, 47, 50, 51, 52

E

Emergency 16, 17

Entrance Interview 6

Event 36, 37

Exit interview 10

Exposure 19

F

Financial Assurance 46

G

Gamma Knife 29

I

Information Security 41

Instrumentation 32

Interview 6, 10, 11, 14, 15, 20, 23, 

27, 31

See Entrance Interview

See Exit Interview

Interview Skills 14

M

Medical Event 27, 28, 29, 30, 37, 

43

medical licensing 44

O

OSHA 5, 16

P

Performance-Based Inspection 9

Personal Emergency 17

Portable 20

Portable Gauge 20, 21

Preparation 3
5 4 UNITED STATES NUCLEAR REGULATORY COMMISSION

R

Radiography 39

Reciprocity 38

S

Safety Conscious

Work Environment (SCWE) 15

Security 41

Supervision 28

T

Training 20

Transportation 36

Trust 10

V

Verify 10, 21, 32, 33, 34, 35, 36

W

Well Logging 32
BEST PRACTICES

MATERIALS

INSPECTION

& LICENSING

HANDBOOK

5 5 MATERIALS INSPECTION & LICENSING HANDBOOK 2008

ACKNOWLEDGMENTS

The NRC acknowledges the efforts of the team who shared their 

experiences and knowledge to put this handbook together. The 

team appreciates the efforts of the many other individuals who 

contributed ideas and material.

Charles L. Cain, Region IV

David J. Collins, Region I

Robert G. Gattone, Region III

John D. Kinneman, Region I

Gregory K. Morell, FSME/DMSSA, HQ

Joseph L. Nick, Region I

BEST PRACTICES

MATERIALS

INSPECTION

& LICENSING

HANDBOOK

5 7 MATERIALS INSPECTION & LICENSING HANDBOOK 2008

SUMMARY THOUGHTS

AND SUGGESTIONS

Stop - Look - Listen - Learn

Stop and stand in an area for 5 to 10 minutes. It is amazing what 

will stand out or who will walk by with an interesting story.

Go to a location where licensed material is in use, and just watch. 

When you know what “normal” looks like, “abnormal” will jump 

out at you.

Watch for and take advantage of opportunities to tour normally 

inaccessible areas or to observe rarely performed activities.

Nothing substitutes for “being there.” You have to get into areas, 

wait for activities, climb, look at things, and get dirty.

Learn by asking! Do not be afraid to ask the licensee questions 

that you cannot answer. Doing so will help you learn more about 

the licensee’s activities radiation and safety program. Maintain 

your integrity and enhance your rapport with licensee staff by 

admitting if you do not know something. 

Suggestions for Improvements or Additions

Please e-mail comments, suggestions for improvement or additions, 

and your best practices relative to materials inspection or licensing 

to R1MatBookCmts@nrc.gov.
5 8 UNITED STATES NUCLEAR REGULATORY COMMISSION

NOTES
5 9 MATERIALS INSPECTION & LICENSING HANDBOOK 2008

NOTES
6 0 UNITED STATES NUCLEAR REGULATORY COMMISSION

NOTES

NUREG/BR-0334

July 2008