Security and physical inventories of licensed material

["Jim F. Herrold" <HERROLD@UWYO.EDU>]

I got a copy of the NRC Quarterly Progress Report on Enforcement Actions
(NUREG-0940 Vol. 13, No.3, Part 3, July-September 1994) in the mail today. It
is interesting reading for those of us who like to get our pants scared off by
reading about other poor souls who have received violations during NRC
inspections. One such licensee was dinged because they did not have proper
security for their licensed material. The regulation cited was 10CFR20.207,
which has since been replaced by 20.1801 and 20.1802. This reg states that the
licensee shall secure from unauthorized removal or access licensed materials
that are stored in controlled or unrestricted areas. 20.1802 goes on to say
that the licensee shall maintain constant surveillance of licensed material
that is in a controlled or unrestricted area and that is not in storage.

This is easy if you can honestly say that all your materials are used in
"restricted" areas. The problem is, how do you restrict access or otherwise
maintain constant security or surveillance over materials used in university
research labs? How do you other universities address this problem? The traffic
in these areas is sometimes heavy. Labs are interconnected with as many as four
entrances to some of them. It would not be an easy task to lock up all storage
and waste areas within the lab, but locking the lab doors and keeping track of
who has keys wouldn't be fun either.

The other side of the coin is conducting physical inventories on licensed
materials. This is easy for sealed sources, but how are other universities
addressing this issue for unsealed sources?

In our last internal audit we identified these two areas as ones needing some
attention. It looks like the NRC is paying attention to them.

I appreciate your responses.

Jim Herrold
University of Wyoming
e-mail: herrold@uwyo.edu