U.S. Nuclear Regulatory Commission

Reporting of Damaged Portable Moisture-Density Gauges

HPPOS-322 PDR-9308020160

Title: Reporting of Damaged Portable Moisture-Density

Gauges

See the memorandum from R. E. Cunningham to R. W. Cooper

(and others) dated July 1, 1993. This memo clarifies the

reporting requirements for damaged moisture-density gauges

that often contain up to 10 millicuries of cesium-137

(Cs-137).

Whether licensees must report damaged moisture-density

gauges depends on the extent of damage to the gauge. The

requirement to report also depends on the level of

radiation in an unrestricted area or doses to individuals

resulting from the damaged gauge. The applicable reporting

requirements are given in 10 CFR 20.405 (a) (1), 20.2203

(a), and 30.50 (b). The enclosure to this memo provides a

detailed analysis of the reporting requirements.

In summary, reporting is required in most incidents when

damage to the gauge results in one of several conditions

(see enclosure):

1. The protective housing (shielding) is damaged such

that the source is not fully shielded, or cannot be moved

into the shielded position [10 CFR 30.50];

2. The source is left exposed in an unrestricted area

such that the radiation levels exceed 20 mrem in any one

hour (10 times the limit of 2 mrem in any one hour)

[10 CFR 20.405 and 20.2203]; or

3. The incident results in doses in excess of limits

in Part 20 or in the license [10 CFR 20.405 and 20.2203].

Please note that the method of reporting and the associated

time for the licensee to make the report are different for

conditions 1, 2, and 3 above.

In a more serious case involving a broken sealed source

that leads to contamination, reporting within 24 hours is

required [10 CFR 30.50 (b) (1)]. Likewise, in a case

involving a sealed source that causes, or threatens to

cause, serious overexposures, immediate notification or

24-hour notification and subsequent written reporting may

be required [10 CFR 20.403, 10 CFR 20.2202, and 10 CFR

20.2203]. However, these situations are beyond the scope

of most damaged gauge incidents and will not be discussed

here.

Finally, immediate telephonic reporting of loss or theft of

a portable moisture-density gauge is required in most

cases, and a written report within 30 days is required in

nearly all cases.

Regulatory references: 10 CFR 20.405, 10 CFR 20.2203, 10

CFR 30.50

ubject codes: 2.2, 3.7, 11.2, 11.3

Applicability: Byproduct Material