Installation of Fixed Gauges
See the memorandum from J. E. Glenn to Chiefs of the Division of Radiation Safety and Safeguards of Regions I-V dated September 14, 1990.
This memo refers to a earlier June 22, 1992 memorandum from A. B. Beach to R. E. Cunningham concerning the installation of fixed gauges. The so-called Beach memo indicates that although a standard license condition generally prohibits gauge users from installing specifically licensed gauges, some gauge manufacturers may be instructing customers to mount gauges despite the standard condition.
The standard license condition used in specific licenses for possession and use of such gauges generally prohibit these specific licensees from installing these devices. A typical license condition reads as follows:
Installation, initial radiation survey, relocation, or removal from service of devices containing sealed sources shall be performed by Texas Nuclear Corporation or by persons specifically licensed by the Commission or an Agreement State to perform such services.
Because gauge licensees are not normally required to possess survey instruments nor personnel dosimeters, the licensee has no means of determining the condition of the devices at the time they are uncrated and installed.
In the Beach memo, it is noted that the standard license condition prohibits licensees from mounting and installing fixed gauges unless specifically authorized. Items 7, 10.1, and 10.6 of the licensing guide for nonportable gauging devices generally makes it clear that if the applicant wishes to install gauging devices, the applicant must describe appropriate procedures and employee training provisions. This issue was first raised by TN Technologies, Inc. (formerly Texas Nuclear Corporation) in response to an All Agreement States letter dated April 3, 1987. State Programs, who coordinated the response to TN, was informed by NMSS that mounting or hanging a device was a part of the installation process and that NRC licensees must be specifically authorized to mount gauges. However, State Programs failed to make this position clear in the letter to TN. While the letters to all Agreement States and TN concerned generally licensed devices, NMSS's position also applies to specifically licensed devices.
NRC has allowed 10 CFR 31.5 general licensees to mount devices, provided they follow the manufacturer's instructions; i.e., the gauge source shutter must remain padlocked as received from the manufacturer. NRC is not aware of any significant mishaps resulting from this practice and believes that this procedure should be acceptable for specific licensees. However, NRC believes that the manufacturer should commit, in its service license, to evaluate the licensee's mounting procedures and discuss any additional safety precautions that may need to be considered. It is not clear that the manufacturers have made such commitments. Some regional licensing personnel have suggested that a revised standard condition permitting mounting of locked gauges may be appropriate. If this is deemed acceptable, NRC will revise the standard license condition to allow gauge licensees to mount locked gauges and will revise the licensing guide and standard review plan to clarify these points.
In the Beach memo, a Temporary Instruction for inspecting field installation work by licensed manufacturers / distributors was requested. NRC Headquarters shared Region IV's concern about these activities but in NRC's opinion, there is not sufficient health and safety risks to redirect inspection resources. However, Headquarters noted the procedure that Region IV used with Kerr McGee Refining Corporation, a new licensee, certainly helped to uncover potential gauge installation problems. After a license was issued to Kerr McGee, NRC requested this licensee to notify Region V when TN was to install the gauges at their site so that Region V inspectors could be present to observe the work. Therefore, NRC suggests the other regions consider this procedure when issuing new fixed gauge licenses. This procedure would meet the Manual Chapter criteria that all new fixed gauge licenses be inspected within six months.
Regulatory references: License Conditions
Subject codes: 1.3, 11.3, 12.19