Information Notice No. 88-10: Materials Licensees: Lack of Management Controls over Licensed Programs
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS
WASHINGTON, D.C. 20555
March 28, 1988
Information Notice No. 88-10: MATERIALS LICENSEES: LACK OF MANAGEMENT
CONTROLS OVER LICENSED PROGRAMS
All NRC licensees authorized to use byproduct material.
This information notice is provided to remind byproduct material licensees of
their responsibilities for ensuring that radiation safety activities are per-
formed in accordance with license conditions and other regulatory
requirements. It is expected that licensees will review this information for
applicability to their programs, distribute the notice to responsible
radiation safety staff, and consider actions, if appropriate, to prevent
problems from occurring at their facilities. However, suggestions contained
in this Information Notice do not constitute new NRC requirements, and no
written response is required.
Description of Circumstances:
During 1987, there were 56 cases in which the NRC took escalated enforcement
action against byproduct material licensees. Thirty-one of these cases in-
volved a civil penalty, 14 involved Orders to suspend the licenses or to show
cause why the license should not be revoked, and one involved a Demand for
Information. These escalated enforcement actions were taken because various
serious violations of NRC license requirements occurred. These violations
included employees being overexposed to radiation and members of the public
being unnecessarily exposed to radiation. In addition, the financial conse-
quences to the affected licensees have been significant because of the loss of
income from the payment of civil penalties, the suspension or revocation of
the license, and the costs of implementing corrective actions on an expedited
An analysis of the causes of escalated enforcement cases identify three common
reasons for serious violations. These were:
1. Failure of management to read and understand the conditions of the
license. Some licensees were unfamiliar with their license and the
requirement to maintain a radiation safety program. NRC inspectors have
found that some licensee managers have never read their license and have
little understanding of license conditions and commitments.
. Failure to train the workforce properly regarding the requirements of the
license, including required radiation safety procedures.
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March 28, 1988
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. Failure to monitor licensed operations, including failure to assure that
licensee employees follow approved radiation safety procedures.
NRC holds licensee management, not the radiation safety staff or consultants,
responsible for assuring the safe performance of licensed activities and ad-
herence to NRC requirements.
Although there may be a radiation safety officer (RSO) assigned day-to-day
radiation safety responsibilities, management retains responsibility to assure
that radiation safety activities are performed in accordance with both
internal procedures and NRC requirements. The amount of time necessary for
management oversight will depend on the size and scope of the program.
Management should support and monitor the RSO and safety staff to make sure
they have adequate resources to do their jobs, are not devoting an inordinate
amount of time to other duties, and adequately implement all radiation safety
The licensee's responsibility for control of its operations also extends to
consultants and contractors. In certain circumstances, licensees may seek
qualified assistance when the licensee staff does not possess the necessary
experience, training, equipment, or personal dosimetry to perform particular
activities. However, the responsibility for the safety of the operations and
compliance with NRC requirements remains with the licensee.
NRC expects licensees' management to be aware of the conditions of their
license to ensure that they understand their responsibilities under the
license. This should include an examination of the details of their radiation
safety program, to verify that the program complies with all requirements. As
a result, licensees can avoid the serious consequences to their employees and
the public and the significant financial costs that can result from failure to
follow NRC requirements and from subsequent enforcement action by NRC.
No written response is required by this information notice. If you have any
questions about this matter, please contact the appropriate NRC regional
office or this office.
Richard E. Cunningham, Director
Division of Industrial and
Medical Nuclear Safety
Office of Nuclear Material Safety
Technical Contact: Jack R. Metzger, NMSS
Attachment: List of Recently Issued NRC Information Notices
March 28, 1988
Page 1 of 1
LIST OF RECENTLY ISSUED
NRC INFORMATION NOTICES
Information Date of
Notice No._____Subject_______________________Issuance_______Issued to________
87-44, Thimble Tube Thinning in 3/28/88 All holders of OLs
Supp. 1 Westinghouse Reactors of CPs for nuclear
that employ a
88-09 Reduced Reliability of 3/18/88 All holders of OLs
Steam-Driven Auxiliary or CPs for nuclear
Feedwater Pumps Caused power reactors.
by Instability of Woodward
88-08 Chemical Reactions with 3/14/88 All NRC licensees
Radioactive Waste generating or pro-
Solidification Agents cessing low level
88-07 Inadvertent Transfer of 3/7/88 All NRC broad
Licensed Material to licensees and
Uncontrolled Locations licensees
material as sealed
88-06 Foreign Objects in Steam 2/29/88 All holders of OLs
Generators or CPs for PWRs.
88-05 Fire in Annunciator Control 2/11/88 All holders of OLs
Cabinets or CPs for nuclear
88-04 Inadequate Qualification 2/5/88 All holders of OLs
and Documentation of Fire or CPs for nuclear
Barrier Penetration Seals power reactors.
88-03 Cracks in Shroud Support 2/2/88 All holders of OLs
Access Hole Cover Welds or CPs for BWRs.
OL = Operating License
CP = Construction Permit
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