U.S. Nuclear Regulatory Commission

Installation of Fixed Gauges

HPPOS-305 PDR-93062220177

Title: 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

Applicability: All