Protecting People and the EnvironmentUNITED STATES NUCLEAR REGULATORY COMMISSION
SSINS: 6835
IN 86-67
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
WASHINGTON, D.C. 20555
August 15, 1986
Information Notice No. 86-67: PORTABLE MOISTURE/DENSITY GAUGES: RECENT
INCIDENTS AND COMMON VIOLATIONS OF
REQUIREMENTS FOR USE, TRANSPORTATION, AND
STORAGE.
Addressees:
All NRC licensees authorized to possess, use, transport, and store sealed
sources contained in portable gauges used to measure the moisture content
and/or density of construction materials.
Purpose:
This notice is intended to bring to the attention of licensees the recent
increase in incidents involving the use, transportation, and storage of
portable gauges and the number of common violations identified during NRC
inspections. It is expected that recipients will review the information for
applicability to their facilities and consider actions, if appropriate, to
preclude similar problems from occurring at their facilities. However,
suggestions contained in this information notice do not constitute NRC
requirements; therefore, no specific action or written response is required.
Description of Circumstances:
An abnormally high number of incidents have occurred recently where portable
moisture/density gauges have been damaged at temporary job sites by heavy
construction equipment or where the gauges have been lost or stolen from
licensee vehicles during transportation. Gauges damaged at construction
sites were left unattended. Gauges lost or stolen from vehicles were not
secured to the vehicle or were stolen while left unattended by the users.
Inspections initiated by these incidents and routine inspections that have
been preformed reveal common violations of NRC requirements. These
violations include failure to:
(1) have a shipping paper in the transport vehicle
(2) transport gauges in authorized packages
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(3) maintain records of tests performed on transport cases and on sealed
sources
(4) use authorized and/or qualified users
(5) use authorized storage locations
(6) conduct leak tests and physical inventories to conduct those tests and
inventories within the required time interval
(7) wear film or TLD badges or estimate doses to personnel who had lost
their badges or evaluate and report possible overexposures
Discussion:
The cause of these incidents, invariably, is the failure of the gauge users
to secure and maintain control over the gauges.
10 CFR 20.207 requires that licensed material (in these cases the sealed
sources in the gauges) must be under the constant surveillance and immediate
control of the licensee or must be secured in storage when in an
unrestricted area. An unrestricted area is defined in 10 CFR 20.3(a)(17) as
any area to which access is not controlled by the licensee for purposes of
protection of individuals from exposure to radiation and radioactive
materials and any area used for residential quarters. A construction site is
usually an unrestricted area; so the licensee must constantly control access
to the gauge while in storage or during use at the site.
NRC licensees transporting portable gauges are subject to 10 CFR 71. 10 CFR
71.5(a) incorporates certain regulations (49 CFR 170-189) of the Department
of Transportation (DOT) to which these licensees are also subject. Licensees
who transport gauges to and from temporary job sites in licensee or private
vehicles are acting as private shippers and, as such, must comply with the
DOT regulations governing shippers. 49 CFR 177.842(d) requires that packages
containing radioactive material (i.e, the gauge in its case and containing
radioactive sealed sources) must be blocked and braced to prevent movement
of the package during transportation. For pickup trucks, this requirement is
usually met when the gauge, in its case, is chained or tied to the bed of
the truck.
Licensees are reminded that they must use, transport, and store the gauges
in accordance with the conditions of their NRC license, other commitments
made to the NRC, and applicable regulations. A discussion of other
requirements and license conditions commonly violated is attached.
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IN 86-67
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No specific action or written response is required by this notice. If you
have any questions regarding this information notice, please contact the
Regional Administrator of the appropriate NRC regional office or this
office.
James G. Partlow, Director
Division of Inspection Programs
Office of Inspection and Enforcement
Technical Contact: J. R. Metzger, IE
(301)492-4947
Attachment:
1. Other Common Violations
2. List of Recently Issued IE Information Notices
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IN 86-67
August 14, 1986
Attachment 1
Page 1 of 2
OTHER COMMON VIOLATIONS
49 CFR 172.201, 172.202, 172.203(d), 172.204, and 177.817(e) specify the
contents of the shipping paper and the location in a vehicle where the
shipping paper must be stored. Shipping papers must not be stored in or on
the case containing the gauge or in the glove compartment of the vehicle.
49 CFR 173.475 requires that before each shipment the shipper ensures by
examination or appropriate test that the proper shipping case or box is
used, that the case is in unimpaired physical condition, and that each
closure device on the case is properly installed, secured, and free of
defects.
49 CFR 172.301, 172.304, 172,308, 172.310, 172.403, and 178.350 specify the
labeling and marking of the case used for shipping. Vehicles transporting
one or more gauges usually do not require placards (49 CFR 172.504, Table
1).
49 CFR 173.415(a) and 173.476(a) require that shippers maintain on file
results of tests conducted on shipping cases and on the sealed sources
contained in the gauges. Licensees can usually obtain these test results
from the manufacturer of the gauges.
Gauges must be used only by properly authorized and trained individuals. A
common license condition usually names individuals who are authorized to use
the gauges or who must be physically present to supervise their use.
Occasionally, licensees are allowed by a license condition to name
authorized users. Authorized users must have successfully completed an
approved training course given by the manufacturer or a consulting firm.
Certain licensees are authorized to provide in-house training. The Radiation
Protection Officer (RPO) also may be named on the license, but is always
specified in documents submitted to the NRC. When this individual is no
longer employed as RPO, the licensee must request an amendment to the
license to name a replacement.
A specific license condition or statement in a submitted document specifies
the temporary and permanent storage facilities for the gauges. Private
residences (including basements and garages) are usually not allowed as
storage facilities. Vehicles used to temporarily store gauges overnight at
private residences must not be used by individuals who are not authorized
users for purposes other than those authorized on the license. For example,
friends or relatives of an authorized user must not use a vehicle containing
a gauge unless those individuals are performing a purpose authorized on the
license as authorized users.
A specific license condition will specify the interval between leak tests.
This interval is usually 6 months and may be greater on some licenses for
gauges that are stored and not being used. Many licensees also are required
by license condition to conduct a physical inventory at 6-month intervals.
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IN 86-67
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Attachment 1
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Licensees are usually committed by a referenced document to wear film or TLD
badges when using or transporting the gauges. When not worn by the users,
the badges must not be stored near or on the gauges. For lost badges, the
licensee is required by 10 CFR 20.201 to estimate the user's dose for the
period for which the badge was lost. For film or TLD badge reports
indicating that doses greater than the limit in 10 CFR 20.101 may have been
received, the licensee must evaluate the reading (10 CFR 20.201) to
determine if it has been caused by an actual exposure to the user. This
evaluation includes, at a minimum, questioning the user about the use of the
gauge and badge and having the film or TLD badge processor reexamine the
badge. Although, true overexposures of gauge users are rare, the occurrences
must be reported to the NRC as required by 10 CFR 20.405.
