**IMC 1248, Appendix C**

**Training Requirements and Qualification Journal for Materials Exempt Distribution**

**License Reviewers**

1246, APPENDIX B	XI-24	Issue Date: 01/05/01

	APPENDIX C

	TRAINING REQUIREMENTS FOR MATERIALS

	EXEMPT DISTRIBUTION LICENSE REVIEWERS

A.   APPLICABILITY

The training described below is required for all materials license reviewers assigned to perform radiological safety reviews of exempt distribution license applications. 

B.   TRAINING

1.	Required Initial Training

a.	Self Study and on-the job Training

(1)	NRC Orientation

(2)	Code of Federal Regulations

(3)	Office Instructions 

(4)	Regulatory Guidance

(5)	NRC Management Directives

(6)	NUDOCS/ADAMS

(7)	Directed Review of Selected Licensing Case Work

b.	Core Training.  These courses establish minimum formal classroom training requirements.  Refer to Section 1248-11 for exceptions to these requirements. 

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

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

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

c.	Specialized Training.  Additional courses may be required in order to gain knowledge necessary for specialized licensing activities.  Management will make this determination on an individual basis. 

2.	Supplemental Training.  Additional training beyond that identified as Core Training.  This training will be determined by the individual's supervisor and will depend on the individual's previous work experience and planned inspection or licensing activities in specific areas.

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

3.	Refresher Training.  Refresher training will include the following course and other courses as determined by management:

a.	Health Physics Topical Review Course (H-401)

Issue Date:  04/19/13	 C-2	1248

	MATERIALS EXEMPT DISTRIBUTION LICENSE REVIEWER

	NRC LICENSE REVIEWER QUALIFICATION JOURNAL

Applicability

This NRC License Reviewer Qualification Journal implements NRC Manual Chapter 1248, by establishing the minimum training requirements for personnel assigned to perform license reviews for exempt distribution applications. 

The NRC License Reviewer Qualification Journal serves as a guideline for the development of a Qualification Journal, and establishes the minimum training requirements consistent with NRC Manual Chapter 1248.  The Qualification Journal must provide traceable documentation to show that minimum requirements are met for each license reviewer.

The NRC License Reviewer Qualification Journal consists of a series of qualification guides and signature cards.  Each signature card is used to document task completion, as indicated by the appropriate signature blocks.  The corresponding qualification guide establishes the minimum knowledge levels or areas of study that must be completed for each signature card. 

Most of the qualification guides are divided into sections.  The review sections of the qualification guides identify references with general application to the license reviewer's qualification.  The license reviewer is expected to have a general familiarity with these references.  Other sections of the qualification guides identify specific references that have direct application to the license review discipline.  The license reviewer is expected to demonstrate detailed knowledge of the license review specific references.

In order to support the review of upper tier documents, programs, and policies, the license reviewer's immediate supervisor will assign specific materials licenses as reference licenses.  The selection of reference licensees is intended to provide the license reviewer's management with the ability to tailor the qualification process to the experience and training level of the license reviewer, and to meet the needs of the NRC.  The use of specific real world material will reinforce the qualification process.

Issue Date:  04/19/13	C-3	1248

	LICENSE REVIEWER QUALIFICATION JOURNAL

	Materials Exempt Distribution License Reviewer

Name                 Title                       Branch         		 Section	 

To complete your qualification as a Materials Exempt Distribution License Reviewer you are to complete the following signature cards.  All signoffs shall include the signature of the responsible reviewer and the date.  Maintain these cards in a notebook along with any background or written material required by the program.  This notebook will comprise your NRC License Reviewer Qualification Journal.

Signature When CompleteDate

 1.  NRC Orientation                              

First Line Supervisor

 2.  Code of Federal Regulations                  

First Line Supervisor

 3.  Office Instructions                             

First Line Supervisor

 4.  Regulatory Guidance                          

First Line Supervisor

 5.  NRC Management Directives                  

First Line Supervisor

 6.   NUDOCS/ADAMS                           

First Line Supervisor

 7.    Directed Review of Selected

Licensing Case Work                       

First Line Supervisor			

 8.   Formal Training                              

                                                    First Line Supervisor

Qualification Board	

Requirements Met				Second Level Supervisor 

or Board Chairman

Recommended as a qualified

exempt distribution license		

reviewer					Second Level Supervisor

Certification Memo Issued	

granting signature authority		Second Level Supervisor 

Signature Authority

A.	SIGNATURE AUTHORITY[footnoteRef:1] - License signature authority is divided into two phases with reviewers authorized for more routine casework first and more complex casework later.  [1: As the reviewer completes the specific category knowledge and completed case requirements, the reviewer can be delegated signature authority for that specific category.] 

1.	Phase I - Reviewer must demonstrate program knowledge by competent completion of a minimum of 5 - 10 new, renewal or amendment[footnoteRef:2] licensing actions (at least 1 new or renewal licensing action in each category) under the supervision of the assigned senior reviewer in each of the following categories: [2: The amendment would consist of a change of ownership, new product or device review and would be considered of an equivalent difficulty level as a new or renewal licensing action.] 

a.	32.14 (certain items)

b.	32.17 (resins)[footnoteRef:3] [3: When the reviewer meets the 32.14 and 32.18 category requirements, signature authority for 32.17 will be automatically delegated.] 

c.	32.18 (small quantities)

d. 32.21 (carbon-14 urea capsules)

2.	Phase II - Reviewer must demonstrate program knowledge by competent completion of at least 1 new, renewal or amendment3 licensing action in each category under the supervision of the  assigned senior reviewer in each of the following categories:

a.	32.11 (exempt concentrations and items)

b.	32.22 (self-luminous products)

c.	32.26 (smoke detectors)

Competency will be determined by review of completed deficiency letters and licenses, and an oral examination of exempt distribution licensing,  conducted by the Section Leader or the assigned senior health physicist/exempt license reviewer.  The Section Leader or the assigned senior health physicist\exempt license reviewer will complete Qualification Guide 6 for each license reviewed, and will discuss comments with the license reviewer-in-training.

Qualification Card 1

NRC Orientation

A.     Site Orientation							InitialsDate

1.	New employee processing

package completed                         

Employee

2.	Facility tour and introduction   		       								First Line Supervisor  

B.	NRC Organization

1.	Review of NRC headquarters

and regional organization                   

Employee

2.	Discussion of NRC organization

First Line Supervisor 

	Qualification Card 2

	Code of Federal Regulations(CFR)

InitialsDate

A.	Familiarization with selected

CFR parts completed                       

Employee

B.	Discussion completed on CFR

parts related to the materials

license review program 			

First Line Supervisor

	Qualification Card 3

	Office Instructions 

InitialsDate

A.	Familiarization with office

policies and procedures                     

Employee

B.	Discussion completed on

office policies and procedures		

First Line Supervisor

	Qualification Card 4

	Regulatory Guidance

InitialsDate

A.	Review of regulatory guidance

1.   Regulatory Guides		_________________	       ______

Employee

2.   Information Notices	

/Bulletins					_________________	       ______

Employee

3.   NUREGs					_________________	       ______

Employee

4.  Generic Letters		_________________	       ______

Employee

5.  Federal Register Notices

_________________	       ______

Employee

6.  NRC Branch Technical Positions

_________________	       ______

Employee

7.  Policy and Guidance Directives

_________________	       ______

Employee

8.  Standard Deficiency Paragraphs

_________________	       ______

Employee

9.   Standard License Conditions		_________________	       ______

Employee

10.  Licensing Checklists		_________________	       ______

Employee

11.  Standard Review Plans		_________________	       ______

Employee

12.  Sealed Source and

Device Registry				_________________	       ______

Employee

13.	Technical Assistance Requests             _________________	       ______

Employee

B.	Discussion of regulatory guidance

with application to the materials

license review program			        _________________	       ______

        First Line Supervisor 

	Qualification Card 5

	NRC Management Directives

InitialsDate

A.	Review of selected portions of

the NRC Management Directives 

completed						_________________	       ______

Employee

B.	Discussion of the application

of the NRC Management Directives

to the materials license review

program						___________________     ______

First Line Supervisor

	Qualification Card 6

	NUDOCS/ADAMS

InitialsDate

A.	Review of selected portions of

the NUDOCS/ADAMS User's Manual and  

system access completed			_______________________	       ______

First Line Supervisor or 

Senior license reviewer

B.	Familiarization with NUDOCS/ADAMS

station(s) and operation                     

Employee 

	Qualification Card 7

	Directed Review of Selected Licensing Case Work

InitialsDate

A.	Review of selected licensing

Casework                                         _______ 

                                            Employee			

B.	Completion[footnoteRef:4] of Phase 1 (QG 7)/ [4: As the reviewer completes the specific category knowledge and completed case requirements, the reviewer can be delegated signature authority for that specific category.] 

Discussion by First Line

Supervisor of directed review of the

selected casework and its 

relation to exempt distribution

license review program                     _________________	      _______

First Line Supervisor

C.	Completion1 of Phase 2 (QG 7)/

Discussion by First Line

Supervisor of directed review of the

selected casework and its relation

to the exempt distribution license

review program				_____________________	      _______

First Line Supervisor

	Qualification Card 8

	Formal Training

InitialsDate

A,	CORE TRAINING:

1.	Health Physics Technology

Course (H-201) (or classification

as a 1306)						____________________	_____

Training Coordinator

2.	Licensing Practices and Procedures

Course (G-109)					____________________	_____

Training Coordinator

3. NMSS Radiation Worker Training 

Course (H-102)	

Training Coordinator

B. SPECIALIZED TRAINING:

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

Course TitleCourse #InitialsInitialsDate

___	

             Supervisor	  Training Coordinator 

___	

             Supervisor	  Training Coordinator 

___	

             Supervisor	  Training Coordinator 

	Qualification Guide 1

	NRC Orientation

 A.	Site Orientation

1.	The qualifying individual should read and complete, as appropriate, the following forms for processing into the NRC:

a.	Personnel information

b.	Health insurance elections

c.	Retirement plan elections

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

e.	Fitness for Duty requirements and physical examination

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

Human Resources

g.	Forms for issuance of tagged, controlled NRC equipment

h.	Payroll forms and time cards

i.	Regulatory Information Tracking System (RITS)

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

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

b.	Indicate to the qualifying individual the location of controlled documents, reference material, supplies, office equipment, classrooms, etc.

B.	NRC Organization

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

a.	Organizational charts of division, NMSS, regions and headquarters and overall NRC organization (NUREG 0325)

b.	Role of Headquarters in policy and interpretation of regulations

c.	Role of NRC General Counsel

d.	Role of NRC Inspector General

e.	Role of NRC Public Affairs

f.	Role of NRC Office of Investigations

g.	Role of NRC Office of Enforcement

h.	Physical location of NRC offices and regions

i.	Role of NRC as a regulatory agency 

(1)	10 CFR Part 1 (Organization)

(2)	Atomic Energy Act of 1954, as amended

(3)	Energy Reorganization Act of 1974, as amended

(4)	NRC Enforcement Policy (NUREG 1600)

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

(6)	Energy Policy Act of 1992

2.	The First Line Supervisor should discuss NRC organization and role with the qualifying individual to ensure the qualifying individual has a full understanding of NRC's organization and mission and the role of the license reviewer in that mission.

	Qualification Guide 2

	Code of Federal Regulations (CFR)

A.	A selection of currently applicable CFR Parts should be made by the First Line Supervisor. The selection should include the references listed below and be documented.  The qualifying individual should be expected to have a general knowledge of the topics addressed in the references.  This review may be accomplished by self-study, study-quizzes, briefings, or discussions. 

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

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

3.	10 CFR Part 9		Public Records

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

5.     10 CFR Part 20  	Standards for protection against radiation (includes selected Questions and Answers, Q & As)

6.	10 CFR Part 21	Reporting of defects and noncompliance	

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

licensing of byproduct material

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

9.     10 CFR Part 32  	Specific domestic licenses to manufacture or transfer certain items containing byproduct material

10.	10 CFR Part 40	Domestic licensing of source material

11	10 CFR Part 70	Domestic licensing of special nuclear material

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

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

14.    10 CFR Part 170 	Fees for facilities, materials, import and export licenses and other regulatory services under the Atomic Energy Act of 1954, as amended

15.    10 CFR Part 171 	Annual fees for reactor operating licenses, and fuel cycle licenses and materials licenses, including holders of certificates of compliance, registrations, and quality assurance program approvals and government agencies licensed by NRC

16.    49 CFR Part 		Transportation

173.421

17.    10 CFR Parts		Statements of Consideration

30, 31, and 32

B.	Following completion of the qualifying individuals self study of the listed 10 CFR Parts, a discussion will be held with the qualifying license reviewer by the First Line Supervisor to test the qualifying license reviewers knowledge of these Parts.  To the extent possible, recent application of various sections, new regulatory initiatives, and current industry issues should be emphasized.

Qualification Guide 3

Office Instructions

A.	Office/Division Policies and Procedures

1.	Read the Office/division Policy and Procedures Manual

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

practices on:

a.	Travel, including Management Directive 14.1 Official Temporary Duty Travel

b.	Telephone use

c.	Policies on use of annual leave and sick leave and excused leave, including Bulletin 4135, Leave Administration.

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

 	Premium Pay

e. Use of government equipment, including computers (NUDOCS and ADAMS) and Management Directive 13.1, Property Management

Union activities, including Management Directive 10.102, Labor-Management Relations Program for Federal Employees

g.	Communications outside NRC

h.	Policies on outside employment and acceptance of gifts

i.	Participation in political activities

j.	Routing of mail and procedures for sending mail and materials (via U.S. Mail, Federal Express, etc.), including Management Directive 3.23, Mail Management

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

l.	Division emergency and evacuation procedures

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

Employee trial period (Management Directive 10.14 Employment and Staffing)

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

o.	Differing Professional Views or Opinions (Management Directive

10.159, General Personnel Management Provisions) 

B.	The First Line Supervisor should discuss these policies and practices with the qualifying individual to ensure that the qualifying individual has a full and complete understanding.

	Qualification Guide 4

	Regulatory Guidance

A.	A selection of currently applicable regulatory guidance should be identified by the First Line Supervisor.  These references should include those listed below and should be documented. The qualifying individual should be expected to have a general knowledge of the topics addressed in the references. The review may be accomplished by self-study, study-quizzes, briefings, or discussions.  Note that many Regulatory Guides reference or endorse industry codes and standards listed in Qualification Guide 6.  Study of corresponding and sub-tier codes and standards is recommended. 

1.	Regulatory Guides (use latest revision)

6.6	Acceptance Sampling Procedures for Exempted and Generally Licensed Items Containing Byproduct Material

6.9	QA Programs for Manufacture & Distribution of Sealed Sources and Devices Containing Byproduct Material

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

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

Others as selected by the First Line Supervisor

3.	NUREGs (latest revision, where applicable)

NUREG 1460	Guide to NRC Reporting and Recordkeeping Requirements

NUREG 1556	Consolidated Guidance About Materials Licenses:

Vol. 3:		Applications for Sealed Source and Device Evaluation 

	and Registration

Vol. 8:		ProgramSpecific Guidance About Exempt Distribution 	Licenses

Vol. 15:		ProgramSpecific Guidance About Changes of Control and 	About Bankruptcy Involving Byproduct, Source, or Special 	Nuclear Material Licenses 

NUREG/CR 1775	Environmental Assessment of Consumer Products Containing Radioactive Material

Others as selected by the First Line Supervisor

4.	Generic Letters (GL)

GL 88-004	Distribution of Gems Irradiated In Research Reactors

Others as selected by the First Line Supervisor

5.	Policy and Guidance Directives

6.	Standard Deficiency Paragraphs

7.	Standard License Conditions

8.	Licensing Checklists

9.	Sealed Source and Device Registry

10.	Technical Assistance Requests

As selected by the First Line Supervisor 

B.	The application of these guidance documents to the materials license review program should be studied in detail by the qualifying individual and covered by the First Line Supervisor in discussions, interviews, or oral quizzes. 

	Qualification Guide 5

	NRC Management Directives

A.	A selection of currently applicable NRC Management Directive (MD)references should be identified by the First Line Supervisor.  These references should include those listed below and be documented.  The qualifying license reviewer should be expected to have a general knowledge of the topics addressed in the references.  This review may be accomplished by self-study, study-quizzes, briefings, or discussions.  The selection should include:

1.  NRC MD 9.1	Organization Management

2.  NRC MD 9.29 	Organization and Function of Regional Offices

3.  NUREG 0325 	USNRC Functional Organization Chart

4.  NRC MD 3.2 	Privacy Act

5.  NRC MD 3.1 	Freedom of Information Act

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

7.  NRC MD 14.1 	Official Temporary Duty Travel

8.  NRC MD 10.159  	Differing Professional Views or Opinions

9.  NRC MD 10.42 	Hours of Work and Premium Pay

10. NRC MD 10.43 	Time and Attendance Reporting

11. NRC MD 10.67 	Non-SES Performance Appraisal System

12. NRC MD 10.101 	Employee Grievances

13. NRC MD 8.8 	Management of Allegations

B.	Application of the selected NRC Management Directives to the materials license review program will be discussed with the qualifying individual by the First Line Supervisor to test the qualifying individual's knowledge.

	Qualification Guide 6

	NUDOCS/ADAMS

The use and training for NUDOCS/ADAMS will consist of a PDC course in using ADAMS; review of the NUDOCS User Manual;  ADAMS USER GUIDE;  knowledge of NUDOCS station(s), access, and operation to locate NRC (Non-ADAMS) document records; knowledge of capturing and retrieving ADAMS documents. 

Qualification Guide 7

Certification - Directed Review of Selected Licensing Case Work

Amendment No.: 		Control No.:  

Licensee Name:	

Address:		

License No.:		 Docket No.:	

Reference No.:	 Expiration Date:	

Action Type:	New License				New License/Licensee	

Renewal				Product Transfer		

Amendment                 		Termination			

Program Code/Type:	

Exempt Concentrations (Gemstones)		03251/32.11		

Certain Items (Electron tubes, Watches)		03251/32.14		

Resins 						03252/32.17		

Small Quantities (Check sources)			03253/32.18		

Carbon-14 urea capsules                        	03256/32.21	

Self Luminous Products (Watches, Gunsights)	03254/32.22		

Gas & Aerosol Detectors (Smoke detectors)	03255/32.26		

I certify that I have reviewed the licensee's request dated  as supplemented by any letters referenced in the license and in accordance with guidance provided by the Office of Nuclear Material Safety and Safeguards applicable Standard Review Plans and the attached checklist.

  REVIEWER				DATE

  PERSON SIGNING THE LICENSE	DATE

GENERAL COMMENTS:  

Issue Date:  04/19/13	 C-26	1248

	Qualification Guide 8

	Formal Training

The standards for each Training Course are provided in the NRC Technical Training Center Course Catalog and will not be duplicated in the Qualification Guide.

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

Attachment 1

Revision History for IMC 1248, Appendix C

Issue Date:  04/19/13	Att11	1248