IA-88-424, Advises of Decision to Standardize Incident Response Training Program,Per Federal Field Exercise.Objective Is to Provide Level of Training on 1 to 2 Yr Basis.W/O Encls

Advises of Decision to Standardize Incident Response Training Program,Per Federal Field Exercise.Objective Is to Provide Level of Training on 1 to 2 Yr Basis.W/O Encls

ML20195B327
Person / Time
Issue date:	06/08/1988
From:	Jordan E NRC OFFICE FOR ANALYSIS & EVALUATION OF OPERATIONAL DATA (AEOD)
To:	Davis A, Grace J, Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20155G876	List: IA-88-424, Advises of Decision to Standardize Incident Response Training Program,Per Federal Field Exercise.Objective Is to Provide Level of Training on 1 to 2 Yr Basis.W/O Encls ML20155G873 ML20155G879 ML20155G887 ML20155G892 ML20155G901 ML20155G913 ML20155G925 ML20155G929 ML20195B327
References
FOIA-88-424 NUDOCS 8806210387
Download: ML20195B327 (31)

Text

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JUN 8 G88 MEMORANDUM FOR: Those on the Attached List FROM: Edward L. Jordan, Director Office for Analysis and Evaluation of Operational Data

SUBJECT:

INCIDENT RESPONSE TRAINING PROGRAM As a result of the Federal Field Exercise (FFE), it has been decided to standardize the Incident Response Training program. This effort will be coordinated with the training being developed under the program described in my memorandum of February 17, 1988 to Office Directors and Regional Administrators,

Subject:

Plan for Developing Qualification and Technical Training Programs.

The following are provided for your retention and review:

1. Enclosure 1 shows the response positions and their associated training modules for your team,

2. Enclosure 2 provides the objectives, duration, references, handouts and qualified instructor for each module.

Virtually all of this training is either based on approved training that has been given many times over the past several years or on specific tools or procedures that currently exist.

F Our objective is to provide this level of training on a one to two year basis. There are several modules, but generally each is comprised of only one to two hours of training. Various modules will be grouped together i

to form courses depending on the needs of the team members. The supporting

course materials will be developed by our of fice. The Incident Response Branch, in cooperation with the Technical Training Center (TTC), will provide the training to the Headquarters staff and conduct "train the

, trainers" sessions for the regions on the technical material. Short courses (1 day) will also be offered in the regions on protective measures and reactor safety materials. It will be the regions' responsibility to coordinate additional training for those unable to attend these sessions.

The TTC will conduct most of the 300 series modules concerning reactor

• accident assessment.

The training to be provided to an individual varies depending on the coeplexity of the task performed. For example, on the Protective 14easures Teas the range of time varies from 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> for the Protective Measures Manager to 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> for the State Radiological and Emergency Services Coordinator. These times include participation in a 1 day ,

(8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />) exercise.

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Multiple Addressees ggg The manual chapter on the Incident Response Program is being revised to include the training program requirements. This will be provided to you in draf t for your comment.

hhe are requesting your eminents on both of the enclosures (modules chosen for each position or changes to the description of each module). These  ;

should be forwarded to Karen Jackson by July 1,1988.

Thank you for your assistance.

gitt$ha---

tow rdi Jordan, Director Offic for Analysis and Evaluation of erational Data

Enclosures:

As stated cc: R. J. Summers, RI A. Boland, RII G. Shear, RIII

- E. F. Bates, RIV

E. H. Garcia, RV

- - R. R. Bellamy, RI

' O. M. Collins, RI!

W. D. Shafer, RIII L. A. Yandell, RIV R. F. Fish, RV S. J. Collins, RI

! A. Gooden, RII

N. J. Chrissotinos, RIII

'J. E. Gagliardo, RIV R. G. Gilbert, RV K. A. Raglin, TTC I

C. P. Bassin OP

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- _ _., __ _ _ . _ _ _ _ _ . - , _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ = __ ,

l Addresseess for Memorandum Dated - M 0 M0 Regional Administrators William T. Russell Region !

J. Nelson Grace Region II A. Bert Davis Region III Robert D. Martin Region IV John B. Martin Region V Protective Measures Team (Reactor) Directors '

Brian K. Grimes NRR Frank J. Congel NRR Thomas T. Martin NRR Protective Measures Team (Transportation & Materials) Directors Richard E. Cunningham NHSS Glen L. Sjoblos NHSS Leland C. Rouse HMSS 1

John Hickey NMSS Reactor Safety Team Directors Frank J. Miraglia NRR Ernest C. Rossi NRR Themis P. Speis RES Safeguards Team (Fuel Cycle / Transportation) Directors Robert F. Burnett NMSS Elizabeth Q. Ten Eyck NMSS George W. McCorkle NMSS Safeguards Team (Reactor) Directors Robert A. Erickson NRR Loren L. Bush NRR James G. Particw NRR Brian K. Grimes NRR Liaison Team Directors Joseph J. Fouchard PA i

John C. Bradburne CA Carlton Kannerer SLITP James R. Shea IP Response Coordination Team Director Gary G. Zech AE00 Ahinistrative Support Team Directors '

Gina F. Thoepson AE00 Cherie Siegel AE00 Andrea K. Barnold AE00

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Ptodule Codes:

SXX Senoral.Tranning i 1XX ET/DSO Training (

l 2XX Protective Measures Training Reactor Safety Training d

3XX i

43X Liatson Tratning 4

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SXX Administrative Training r

-> 6XX Safeguards Training t l

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i 8XX HOO Traantng -

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Module Number Module Title 901 General Response Training (Overview)  !

902 Other Responders Tratning (FBI, BIFC, etc.)

003 Team Functions 004 ET/DSO Inf ormation Needs 005 Full Scale Exercise 006 Technical Drill 007 Overview of Our Most Important Response Function "Monttor Severe Reactor Acendent Protective Action Implementation

• 000 Overview of the Federal Radtological Emergency Response Plan l

009 Federal Radiological Emergency Response Workshop 010 Technol-gy Course -

PWR or EWR 011 Radiation Safety "

101 Writing a Status Summary 201 PM Emergency Response Manual and Resources '

(Overview) 202 Assessment of Reactor Accident General Population Protective Actions 203 Overview of Reactor Accident Consequence Assessment Methods '

i 204 Use of Precalculated Methods - 1st Order Dose (

Projections

• l 205 Use of RASCAL and IRDAM - 2nd Order Dose l Assessment '

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206 Use of WASH-1400 Dose Curves - 3rd Order Dmse Assessment l i

007 EFA Role and Applicatten of EF A Atreorne Plume anc '

i Recovery / Reentry PAGs i

Module Number Module Title 208 HHS Role and Application of HHS Food PAGs 209 DOE Rad 4clogical Monitoring and Assessment '

Capabilities and Role '

219 Application of ARAC 211 Access and Use o' ACCU-Weather 212 Using the PC Based Response System 213 Fuel Cycle Accident Overview 214 Radnological Emergency Response Course 215 Radiological Accident Assessment Course 216 Transportation of Radioactive Materials 701 i RS Technical Procedures anc Resources (Overview) '

000 Assessment of the Licensee's Accident Classification 003 Assessment of the Actual or Projected Release '

Pathway Characteristics 304 Emergency Operating Procedures (EOP) Simulater Course - PWR or bWR 305 Severe Accident Overview Seminar -

PWR or BWR 306 Mint-Course (Reactor Technology anc Operations) -

PWR or BWR 501 Create and E-Mail a Status Summary 701 RCT Functional De-onstration 801 HOO Qualificttien Program i

Modul e Ti tl et General Response Training (Overview)

Module Number: 001

'I Ob j ec t i ves Fol l owi ng c omp l e t i on of t h i s c our se , the student should understand Access to the Operations Center day and night Use of Telephones How they will ba notified and their expected actions ,

Information Flow Role of team Coordinators Availabl e resources flesponse secur1 tv 4

Role of NRC, licensee, of f site of ficial s and other Federal Agencies NRC response modes and who has the lead and their location Organt:ation of Headquarters and Regional teams Duratton I hour I

References:

NUREG-1010, Volume 5 Handouts: Copy if slides Qualtited Instructors: All Team Coordinators l

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Title:

Team Functions 1

Module Number: 903 Objectivess l Following completion of this course, the student .

should:

Understand procedures individual team functional Conduct a walk / talk through in context of actual event scenario Duration: 1 - 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> .

References:

Team Functional procedures Handouts: Slides 4

Qualified Instructors: Appropetate Team Coordinators i

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Module

Title:

ET/DSO Information Needs Module Numberi 904 Objectives Following should the completion of this course, the student Understand the inf ormation needs of the ET/DSO to make decisions concerning protective actions Underttand info <r.setton the ET/DSD need for a continual flow of Understand the need for simple briofing with visual atde Understand the bast e ET displ ny systems and capabilities Understand the need for coordinated PM/RS briefings in ET room with demonstration of wall Durations i hour Ref ereneest Handouts: copy of slides Qualified Instructors: ET Coordinator

i Module

Title:

Full Scale Exercise '

Module Number 985 ,

Ota j ec ti ves Participation in full scale exercise perf orming the team f unction (s) to assure an understanding of the l response team environment l

Duration: 4 or more hours I l

Ref erences Handouts: L Qu al i f i ed Instructors i

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Module Title Overview of Our Most Important Response Function "Monitor Severe Reactor Accident Protective Action Implementation" Module Number: 097 Ob j ec t i ves Following completion of thi s course, the student should Know our most important function and how all members in response have a role in its perf ormance Understand the basic severe accident protective action strategy Duration I hour Ref erences: NUREG-1210, Volumes 2 and 4 Handouts: Sl i des Quat t f t ed Instructors '

Tom McKenna Jim Maetan e

6

e Module Title Overview of the Federal Radiological Emergency Response Plan Module Number 698 Objectives Following completion of this course, the student shoulds Understand the scope of the federal response The role of the major response agencies (NRC, DOE, FEMA, EPA) during a severe reactor accident Understand where to interface with these agencies Duration: 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> References FRERP, NUREG-1210, Volume 5 Handouts: Slides Qual t f s ed Instructors:

Bernia Wetss

j Module Titles Writing a Status Summary ,

Module Number 181 Objectives Following the completion of the course, the student shoulde Understand Sunmary the uses and audience of the Status Underutand the need to tell a complete store and keep it sample Demonstrate they can write an adequate Status Summar y Duration: I hour I i

References:

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Handouts:

Qualified Instructors I

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Module Title Assessment of Reactor Accident General Population Protective Actions Modul e Number 292 CD2 j ec ti ve s t Following the completion of this course, the student shoulds ,

Understand the basis for the NRC severe reactor protective action strategy (NUREG-1218, Volume 2) 1 Understand the application of the guidance to include difficulties associated with containment status projection (NUREG-1218, Volume 4)

Understand the role of the licensee and offsite of ficials and the extent of preplanning (NUREG-1219, Volume 3) i Be abl e to apply Procedure PMT-406 "General Population Protective Action Assessment" Durattent 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />

• Ref erences: NUREG-1210, Volumes 2, 3 and 4, FMT-406 1

Handouts

NUREG-1210, PMT-406, slides Ovalifted Instructorst Tom McVerea Jim Martte 1

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e a e Modul e Ti tle Overview of Reactor Accident Consequence Assessment Me thod s Module Number 283 Objectivest Following the completion of thi s course, the student shoulds Understand that protective action assessment starts with plant condi tions/ classification '

Understand projection the uncertainties associated with done List the methods f or source term / dose projections and their basic application Und estand the role of dose projections during core damage and lesser accidents Duratton 30 minutes Ref erences NUREG-1210, Volumes 2 and 4, PMT-481 Handouts: NUREG-1210 Volumes O and 4, PMT-401, sindes Qualtfted Instructors:

Tom McVenna Jim Marttn

Module Titlet Use of Precalculated Method - 1st Order Dose Project 1ons Modul e Number 284 Objectives: Following the completion of this course, the student should Understand the basis and role f or this method Demonstrate that thes correct projection can be selected given plant conditions use the diagrams to explain the results use the basic concepts to Jpply the method to a general problem State the limitations of this method Durattont 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Ref erences: NUREG-1010 Volume 6 (Draft). PMT-492 Handouts NUREG-1210 Volume 6 (Draft), PMT-492, summary slides Qualified Instructors: Tom McKenna

Module Title Use of RASCAL and IRDAN - 2nd Order Dose Assessment Module Number 295 Objectives Following should the completion of thi s c our se , the student Understand IRDAM the capabilities and role of RASCAL and Understand only isotopicthe severe source termlimitation should of beIRDAN used and that Demonstrate using RASCALS calculating a source term using isotopic, plant conditions and gross r.te options calculation of distribution using changing conditions display results create and mani an ASC11 result titerpret all outputs

! State the limitations of these methods

.j Duration: O hours 1

Ref er ences: RASCAL users Manual, FMT-403 (Revised) j Handouts RASCAL users Manual, slides, PNT-493 i Qualtfted Instructorst '

Module Ti tl e Use of WASH-1400 Dose Curves - 3rd Order Dose Assessment Module Number: 296 Ob.iec t i ves t Following the completion of this training, the student should Understand the role of the curves in NUREG-1862 during severe accident assessment Demonstrate the selection of the appropriate curves for various plant and met conditions (using flow chart as an aid - PMT-405)

Interpret the curves to include impact of ground level vs elevated release and protective action assumption State the error (thyroid dose is 10X too low)

State the limitations of this method Duration: 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> Ref erences: NUREG-1062, FMT-405 Handout s : NUREG-1062, PMT-405, slides Qualt J ted Instructors

,tm Martin Tom McKenna I

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Title:

EPA Role and Application of EPA Airborne Plume and Recovery / Reentry PAGc Module Number: 207 Objectives Following the completion of thi s course, the student should Understand the role and interface with EPA during an accident Understand the basis for the EPA PAGs Apply the airborne and recovery and reentry PAGs Duration: 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> Ref erences: Manual of Protective Action Guides and Protective Actions for Nuclear Incidents (including recovery / reentry chapters)

Han suts: Manual, slides Qualified Instructors: EPA

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i Module

Title:

HHS Role and Application of HHS Food PAGe Modul e Number : 208 Objectives: Following the completion of this course, the student should:

Understand the role and interface with HHS during an accident Understand the basis for the HHS PAGs Apply the f ood PAGs Duration 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />

References:

47FR47073 " Accident Radioactive Contamination of Human Food and Animal Feeds; Recommendations for Scte and Local Agencies: HHS FDA-82-8196 "Deckground for Protecti ve Action Recommendau ons: Accident Radioactive Contamination of Food and Animal Feeds Handouts: References, sliocs Qualified Instructorst HHS l

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Module

Title:

DOE Radiological Monitoring and Assessment Capabilities and Rol e Module Number 209 Objectives Following the completion of this course, the student shoul d Understand the role of DOE for radiological '

monitoring and assessment Understand the DOE capabilities and response times Understand how DOE radiological capabilities are requested Understand the rcle, organtration of the FRMAC Understa.id how to interface with DOE at the FRMAC Duration: 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />

References:

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I Module

Title:

Application of ARAC Module Numbert 218 i

Objectives:

Following should the completion of this course, the student Understand the capabilities of ARAC Understand the limitations of ARAC Understand the response time for results '

Be able to request ARAC assistance Be able to interpret ARAC results Duratton: 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />

References:

ARAC Access Procedure (PMT-7)

Handouts: 7 Oualified Instructors:

Tom McLenna ARAC 1

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Module

Title:

Access and Use of ACCU-Weather Modul e Nuater: 211 Objectives: Following the completion of this course, the student should Be able to access ACCU-weather NRC products by PC Interpret ACCU-weather resul ts Duration: 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />

References:

ACCU-Weather Users Manual and ACCU-Weather Access Procedure (PMT-7)

Handouts: references, slides Qualifted Instructors:  ?

, i Module

Title:

Use of PC Based Response System l Module Numbers 212 Objectives: Following the completion of this course, the student should be able to:

Use the PC based response system to:

access ACCU-weather access ARAC -

E-Mail (Di al com) run RASCAL, IRDAM, DW3 produce a DW3 or RASCAL document while holding an E-Mail line and mail the results Duration: 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> References Users Manual Handouts: Users Manual, slides Qualified Instructors: PA1 l

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i Module Title Fuel Cycle Accident Overview Module Number 213 Objectives: Following completion of this course, the student should understand Scope of the risk from fuel cycle accidents That the basic protective action objectives f or fuel cycle accidents is dose reduction That protective actions will be based on PAGs and assessments at time of accident Duration: I hour

References:

NUREG-1140 Handouts: Copy of slides Qualified Instructors:

Tom Mckenna Jim Martin

Module Title Radiological Emergency Response Course CH-3033 Module Number 214 Objectives:

Following the completion of thi s course, the student should Be familiar with the "on scene" response to radiological emergencies involving a nuclear power plant accident , a nuclear materials transportation accident, and a nuclear industrial accident.

Course f ocuses on tt e f ollowing areas

1. Emergency team organization and procedures

2. Emergency team l e ad er shi p

3. Emergency team instruments 4

Anti-contamination equipment and procedures Duratton: 8-1/2 days Ref erences: NRC Guide to Training Opportunities Addendum, 1987-1988, page 7-4 "andcuts:

Cualtfted Inst r uc t or s: DOE /Reynol ds El ec tri cal & Engineering Co.

Module

Title:

Radiological Accident Assessment Course CH-3073 Module Number: 215 Objectives: Following the completion of this course, the student should:

Understand the duties and responsibilities of radiological accident assessment personnel l

l Knowl edge of possible accident scenarios at a l nuclear plant, the time significance of these events and the significant indicators of an accident Ability to perf orm of f-site dose calculations '

given a specific source term and meteorological conditions Ability to utili:e and interpret Federal Protection Action Guides as a basis for recommending appropriate protective measures to state and local officials Curatten 5 days s.cferences: NRC Guide to Training Opportunities Addendum, 1987-1988, page 7-8; EMI Course Catalog, 1987-1988, page 08 H a nd out r.:

Sualified Instructors FEMA f

Module

Title:

Assessment of the Licensee's Accident Classification Modul e Number s 302 Objectives Following the completion of this course, the student should Understand how these assessments will be used by PMT Understand the basis for the event classification system Understand how the requirement has been implemented by the licensee and where to find their EALs Assess the classification using the RS procedure Duration: 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Ref erences: NUREG-1210, Volume !.. RST-7 Handouts: NUREG-1210, Volume 3, RST-?

Oualtfred Instructors: AST Coordinator and Backup J

l o

i i

Module

Title:

Severe Accident Overview Seminar - PWR or BWR Module Numbers 305 Objectives Following the completion of this course, the student shouldt Understand the most important phenomena that will affect severe accident progression and offsite risk in vessel ex vessel containment performance Understand the scope and important points contained in the "Severe Accident Insights Report."

Understand the role and general implementation of EOPs under accident conditions Understand how instrumentation may respond during an accident Durations i day

References:

Severe Accident Insights Reports Handouts Qualified Instructors: TTC Staff

(

l

o Module Ti tle: Create and E-Mail a Status Summary Module Numbers 501 Objectives:

Following should the completion of this course, the student Demonstrate creation of a Status Summary on DW3 and mailing it by Dialcom Demonstrate downloading a Status Summary off of Dialcom into DW3 Duration  ?

References:

Procedure Handouts: slides Qualified Instructors:

Joe Himes Maren Jackson i

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1. %,t UNITED STATES A -

NUCLEAR REGULATORY COMMISSION f i  %

• REolON I Lg ,g  ! MS ALLENDALt MOAD mc or rauss: A, etussytvAwi A mos

'O 6 JUL 1988 Docket No. 030-30161 29-19541-02 C.A.L. Technologies, Inc.

ATTN: Ms. Randy Olsen 19 Ross Street Somerville, New Jersey 08876 Gentlemen:

Subject:

Routine Inspection No.88-001 On April 28, 1988, Cristina Schulingkamp of this office conducted a routine safety inspection at the above address of activities authorized by the above listed NRC license. The inspection was an examination of your licensed activ-ities as they relate to radiation safety and to compliance with the Comission's regulations and the license conditions. The inspection consisted of observations by the inspector, interviews with personnel, and a selective examination of representative records. The findings of the inspection were discussed with Thomas Sabatino at the conclusion of the inspection.

Based on the results of our April 28, 1988 inspection, it appears that your activities were not conducted in full compliance with NRC requirements. A Notice of Violation is enclosed as Appendix A and categorizes each violation by severity Procedure level in accordance for NRC withActions,"

Enforcement the "General 10 CFR Statement of Policy Part 2. Appendix C (and Enforcarent Policy). You are required to respond to this letter and in preparing your response, you should follow the instructions in Appendix A.

Subsequent to the inspection you alleged, in a letter dated May 16, 1988, that my staff had repeatedly contacted you for the same infonnation and had apparently misfiled, misplaced or ignored your responses. In a letter dated June 9,1988, I infomed you ! would look into your concerns and respond by June 30, 1988. This letter constitutes that response.

My staff has prepared a chronology of events related to the items discussed in your letter. The chronology is enclosed as Appendix B. Based on the chronology and review of the matter with the involved merbers of ry staff, plus review of our experiences in the handling of several thousand pieces of correspondence each year, I have concluded that it is extremely unlikely that three difference pieces of correspondence from the same licensee could have been nisplaced or misfiled. I do not know why your letters dated June 10, 1985, Septenber 18, 1986 and August 11, 1987 were not received by our office, but I do not believe that all three could have been lost if they were received. Noretheless, I note that we are not without fault in this natter.

On several occasions over the past three years we have not provided timely followr to contracts with your organization. I do, however, appreciate your providing copies of your earlier letters with your letter dateo May 16, 1988.

n-Alv

-ett'm i v " 1 9g-

. '06 JUL 1988 C.A.L. Technolog'ies, Inc. 2 1 do want to point out, however, that you appear to misunderstand your obli-gations with regard to keeping this office infonned of your activities. Your use of byproduct mate-ial is limited to the materials, forms, activities, places of use and purposes listed on your license. Changes of conditions of use listed on your license require that you make prior written application to this office and receive in writing an amended license showing the changed or additional conditions of iise.

I in particular, you have never adequately responded to the Notices of Violation '

(N0V) sent on May 24, 1985 and July 1, 1986. Therefore, you are required to respond to the NOV enclosed with our April 11, 1988 letter as well as the NOV enclosed with this letter. Your response must include the current status of your possession of material and the locations of use, the date when you achieved or vill achieve compliance with the requirements and the mechanisms you will -

use to assure that these items do not recur.

In accordarice with Section 2.790 of the NRC's "Rules of Practice," Part 2.

Title 10, Coce of Federal Regulations, a copy of this letter and your reply will be placed in the Public Document Room.

The responses directed by this letter and the acccrrpanying Notice are not subject to the clearance procedures of the Of fice of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511. [

i Your cooperetion with us is appreciated. <

, Sincerely, s N

\ \

^Mn G , % .y . .,, -

-Jarres H. Joynd, Chief Nuclear Materials Safety Branch Division of Radiation Safety and Safeguards

Enclosures:

1. Appendix A hotice of Violation

2. Appendix B, Chronology cc:

Public Document Room (PDR)

Nuclear Safety Informaticn Center (t: SIC)

State of hew Jersey bcc:

Region 1 I'ocket Rocr. (w/concurrcrces) l'a na oere n t /,ssistant, DRMA i

a

4 APPENDIX A NOTICE OF VIOLATION C. A.L. Techna .'agies , Inc. Docket No. 030-30161 Somerville, New Jersey 08876 License No. 29-19541-02 As a result of the inspection conducted on April 28, 1988, and in accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions,"

10 CFR Part 2. Appendix C (Enforcerent Policy) (1988), the following violations were identified:

A. 10 CFR 19.11(a) ano (b) require that current copies of Part 19, Part 20, the license, license ccnditions, documents incorporated into the license, license arendments and crerating procedures be posted, or that a notice describing these documents and where they may be examined, be posted.

10 CFR 19.11(c) requires that Fom NRC-3, "Notice of Employees," be posted.

Centrary to the above, on April 28, 1988, neither the documents nor the notices were posted.

This is a Severity Level V violation. (Supplerant VI)

8. Conditier 13A(1) of License No. 29-19541-02 requires that chromatograph detectors containing nickel-63 be tested for leakage and/or contamination at intervals not to exceed six rnonths.

Cor.trary to the above, the chromatograph detector containing rickel-63 was not tested for contamination or leakage from Septerber 1986 to March 1988, an interval in excess of six nonths.

This is a Severity Level IV violation. (Supplement VI)

C. Condition 15 of License No. 29-19541-02 requires the licensee to conduct and docurent a physical inventory of all sealed sources every six months to account for all sealed sources received and possessed under the license.

Contrary to the above, an inventory of sealed sources had not been performed by the licensee since issuance of the license on October 2,1987.

This is a Severity Level IV violation. (Supplement VI)

Pursuant to the provisions of 10 CFR 2.201, C. A.L. Technologies, Inc. is hereby required to submit to this office within thirty days of the date of the letter which transmitted this Notice, a written statement or explanation in reply, including: (1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further violations; anc (3) the date when full compliance will be achieved. Where gcod cause is shown, censideration will be given to extending this rcsponse tint.

APPENDIX B Chronology of Events involving the unauthorized transfer of an electron capture detector from Gow&c Instrument Company [(Gow-Mac) License Number 29-21079-01]

to C. A.L Technologies incorporated [(C. A.L.) License Number 29-19541-01].

1. On January 24,19P,, Judith Joustra of this office contacted Mr. Robert Mathieu of Gow-M' .:. The telephone inouiry was the initial contact with Gow Mac after t'e issuance of the license. It was detemined that the licensee wanter to teminate the license and a Certificate of Disposition of Materi .. Aus sent to the licensee in a letter dated February 1,1965.

2. The licensee completed the Certificate on March 26, 1985. It was received by this office on April 2, 1985. The Certificate listed C. A. L. Technology as the recipient of the Tracor electron capture detector (ECO). The transfer reportedly took place on March 19, 1985.

3. On May 7,1985, Ms. Joustra telephoned Mr. Mathieu and infortred him that temination of the Gow-Mac license would be delayed pending the company's reply to a f:otice of Violation (h0V) that was being issued. He was infomed that the transfer of the Tracor ECD to C. A.L. was not authorized, since C. A.L.'s license did not authorize the possession of a Tracor ECD.

a. On May 24, 1985, a NOV was issued by the Region 1 Office to Cow-Mac. The NOV required c reply from Gow-Mac as to the actions that they would take within thirty days to correct the situation concerning the unauthorized transfer.

5. The licensee submitted a reply to the NOV dated June 12, 1985, which was signed by Mr. Mathieu of Gow Mac. The response stated that he had been in contact with a representative from C. A.L. and that C. A.L. was "submitting an extension of their current license to covar the Tracor detector." This respense was dened to be satisfactory ano a letter acknowledging the response was issued by the Region on July 11, 1985.

6. Based on the above infomation and a confirmatory telephone contact (sce paragraphs 9 and 10A) with a representative from C.A.L., Gow-Mac's license was terininated on July 15, 1985.

7. C. A.L's license was issued on January 16, 1961. The mailing address was listed as 66 Hudson Street, Clif ton, New Jersey 07011. The place of use was listed as 978 Evergreen Drive, Branchburg lownship Somerset Cuunty, New Jersey. The authorized material consisted of not more than 2 milli-curies of nickel-63 in a Hewlett-Packard ECD, Model No. 2-6195.

Appendix B 2

8. Amendment Number 1 to C.A.L's license was issued on January 27, 1982, in response to a request from the licensee to add authority to possess the sources in a Hewlett-Packard Model 5790 gas chromatograph its license.

The gas chromatograph contained two ECD's containing not more than 15 mil 11 curies of nickel-63 per foil. The ECD's are Model No. 18713A.

I

9. On May 7,1985 Ms. Joustra contacted C. A.L. to confirm that the licensee had received the Tracor ECD from Gow-Mac. The licensee representative, Ms.

pandy Olsen, confimed that they possessed the ECD, and would submit a license amendment requ et.

10. A NOV was issued by this office to C.A.L. on May 24, 1985. It was our understandino at that time, based on the May 7,1986 telephone discussion, that the licensee planned to continue possession of the Tracor ECD. The licensee was required to reply te the letter with their cor-rective actions and, as part of those corrective actions, to submit an amendment to include the Tracor ECD on their license. A search of NRC files revealed no evidence of a response ever having been received by the NRC.

11. Mr. Steven Courtemanche of this office contacted Mr. Thomas Sabatino of C.A.L. on June 24, 1986. The licensee was informed that their license had expired en January 31, 1986 and that no renewal application had been received. Mr. Courtemanche understood that the licensee possessed three gas chromatographs and the place of use was 978 Evergreen Drive, Somerville, New Jersey. A comitment was made by the license to renew their license. (Byproduct material in their possession actually included the ECDs in two Hewlett-Packard gas chromatcgraphs anc ene Tracor ECD, based on infomation subsequently obtained on June 7,1988).

12. In an undated note added to Mr. Courtenanche's telephone conversation record of the June 24, 1986 call to Mr. Sabatino, Ms. Joustra recorded that she had contacted the licensee subsequent to June 24, 1986 and detemined that the licensee has changed its mailing address. The new

nailing address was listed in Ms. Joustra's note as 19 Ross Street, Somerville, New Jersey.

j

13. An NOV was issued by the NRC Region ! Office en July 1,1986 to C. A.L..

The NOV required that all licensed material on hand be placed in storage until such time as a new license was issued. A search of NRC files revealed no reply to this NOV ever having been receivec Dy the NRC.

14. Mr. Courtemanche contacted Mr. Sabatino on May 19, 1987 and infomed him that there was no record of a response to either of the NOVs previously issued by the NRC, and that the licenu renewal application had not been l received by the NRC. Mr. Sabatino st & l that he thought Randy Olsen had already sent in a renewal application. 4 agreed that the Tracor ECD required an amendeent in order to be added 'o the license. Lastly, he stated that copics would be r.ade of the rerewal application if it could be ,

! found, othervise a new application would be made.

l

J Appendix B 3

15. On June 12,19M, Mr. Courtemanche contacted Mr. Sabatino. Mr. Sabatino stated that Randy Olsen had sent in the renewal application the previous week. A search of NRC files revealed no evidence of the application having been received by the NRC, at that time.

16. Mr. Courtenanche attempted to conduct an inspection of the facilities listed on the license in 1987. On July 30, he found that the mailing address (66 Hudson Street, Clif ton, New Jersey) was a private home in a residential neighborhood and that the hone no longer belonged to the licensee. He then contacted Mr. Sabatino by phone. He was infonned that the place of use was 19 Ross Street and that activities were no longer being conducted at the 978 Evergreen Drive facilities. The licensee was told that the inspector would arrive at the licensee's facilities the next day.

17. The inspector arrived at 19 Ross Street, Somerville, New Jersey at 9:00 A.M.

on July 31, 1987. The facilities were a converted private home in a resi-dential neighborhood. No licensee representative was available at that tirne to assist Mr. Courtemanche with the inspection. Tim Black, a techni-cian, arrived at the facility at approximately 10:30 A.M. and allowed the inspector into the facilities. Mr. Black accompanied the inspector on a tour of the facilities. The two Hewlett-Packard gas chroratographs were found in the laboratory but the Tracor ECD could not be found. Mr. Black was unfamiliar with the progran and stated that Mr. Sabatino was the only user since Pandy Olsen was on maternity leave. Mr. Black also stated that Mr. Sabatino was at a meeting in Newark. New Jersey and would be unavailable for the rest of the day.

10. Pr. Courtenanche conducted an exit interview with Mr. Black. He was provided with ecpies of the previous NOV's and an NRC Form-3 to post.

Enforcerent options and the urgent need for the licensee to get in an applicaticn for renewal of the license were discussed. Mr. Black was advised that the unresolved matter of the Tracor ECD would need to be addressed in the reply to a new NOV that would be sent to them, and that responses were required to the other outstanding NOVs. The inspector left the licensee's facilities at 11:30 A.M.

, 19. A renewal application was received by the NRC Region i Office on August 14, 1987. Since the license had expired, it was treated as a new license request. The applicatien did not address the rnatter of the Tracor ECD but did address the natters of the new place of use and the expired license.

A new license (No. 29-19541-02) was issued October 2, 1987.

'0.

t Ms. Betsy Ullrich contacted Ms. Randy Olsen of C. A.l.. on February 12, 1988. Ms. Olsen stated that a letter had been sent to the NRC explaining what had happened with the Tracor gas chromatograph. Ms. Ullrich explained that the licensee comitted tc f end a copy of that letter to the NRC.

i i

)

.- l l

. \

Appendix B '4 i

21. On April 11, 1988, a NOV was issued with a cover letter by the Region i Office to C. A.L. The cover letter reviewed the history of past NOV's and that no reply had been received for any of them. The scope of the inspec-tion of July 30 and 31,1987 was addressed. Continued concern about the Tracor ECD and the fact that its whereabouts was uncertain and not addressed in the application was brought to the attention of the licensee.

Possible escalated enforcement actions were addressed for knowing or willful violations and failure to respond to a NOV.

22. Mrs. Christina Schulingkamp conducted a full inspection of License Number 29-19541-02 on April 28, 1988. Mr. Thomas Sabatino was the licensee repre-sentative during the inspection. Three apparent items of ncricompliance were identified during her inspection. 1) failure to post NRC Fortn-3 and other required documents. (The licensee had been su the document to post at the previous inspection); 2)pplied with leak tests of athe copy of ECD's had not been conducted at the required six-month interval,

3) physical inver. tories had not been performed. Mr. Sabatino stated that the Tracor ECD had been shipped out the previous year. No shipping papers were made available to be reviewed by the inspector. Mr. Sabatino also stated that the company would be relocating later in the year.

23. Mrs. Schulingkamp contacted the licensee on April 29, 1988 by telephone.

The licensee was informed that it would be necessary to amend the license tc include the new place of use before they began operations there. Infor-mation was reouested concerning the transfer of the Tracor ECD. The licensee stated that the ECD had been sent back to Gow-Mac and the name of a contact person was supplied.

2t. On April 29, 1988, Mrs. Schulingkamp contacted representatives of Gow-Mac to detemine if they had received the ECD. Representatives of Gow-Mac returned the phcne call on May 1, 1988. The Gow-Mac representative initially said that he knew they were ret licensed to possess the ECO and should not have received it. However, your checking his inventory, he detennined that they had received the ECD in the early part of 1988. They stated that the Gow-l'.ac representative had informed a C. A.L. representa-tive that Gow-Mac did not have a license and that the material should be shipped directly to Western Scientific Instrument, Incorporated (Western), i

25. A response to the NOV issued on April 11, 1988 was dated May 16, 1988.

Enclosures included the letter from the NRC dated April 11, 1986, and apparent copies of letters f rom the licensee dated June 10, 1985 Septer.ber 18, 1986 and August 11. 1987. Objections were made to all the apparent items of noncompliance listed in previous correspondence from the NRC. Request for redress of the above rentioned itens was made by the licensee.

Appendix B 5

26. Mr. Courtemanche contacted Mr. Robert Mathieu of Gow-Mac on June 7,1988 for more infomation regarding the most recent transfer of the ECD. He believed that a representative from C. A.L. had driven te the Gow-Mac facility and left the ECD with with shipping / receiving, despite earlier warnings to C. A.L. that he did not have a license for the ECD. Mr.

Mathieu did not realize that the ECD was in his possession until he had discussed the matter with Mrs. Schulingkamp on May 1,1988. He then had the ECD packaged for shipment to Western, which is an associate company of Gow-Mac's. Western holds California State License No. 2218-07.

27. Mr. Courtemanche contacted Gerald Wong, Ph.D., of the California Department of Health, Radiological Health Section, to detemine if Western has a valid licer.se for the possession of the Tracor ECD. Dr. Wong confimed that the licenseo had a current license on file (LN 2218-07, amendment number 6, issued May,1986) for the possession and use of two Tracor ECD's containing not more than 15 millicuries of nickel-63 per foil.

28. Mr. Courtemanche contacted Mr. Kendell Dempster of Western on June 7,1988.

Mr. Dempster stated that he was expecting the delivery from Gew-Mac but that no record of the ECD arriving at his facility was available. He agreed to send this office a letter confiming the receipt of the source when it arrived.

29. Mr. Courtemanche contacted Mr. Mathieu of Gow-Mac on June 8,1988. Mr.

Mathieu stated that he had been in touch with his shipping department and that the Tracor ECD was still in their possession. The shipping depart-rent is waiting for the proper forms fron UPS so that UPS will accept the shipment and deliver it to Western. Mr. Mathieu comitted to sending a copy of the earliest inventory when they knew that C. A.L. had placed the ECD into their possession and a copy of the shipping papers when the ECD is shipped out.

N y

[ g; UNITED STATES NUCLEAR REGULATGRY COMMISSIEN

REGION I 476 ALLINDALE ROAD

• t

' xlNo oF pmussiA. PENNSYLVANIA 19408

• • • • • JUL. 0 71988 Docket No. 030-05222 License No. 29-00139-02 E. R. Squibb and Sons, Inc.

ATTN: Louis T. DiFazio, Ph.D.

President, Squibb Technical Operations Route 1 and College Fara Road P.O. Box 191 New Brunswick, New Jersey 08903 Gentlemen:

Subject:

Operational Safety Review As a result of the accident involving the release of uranium hexafluoride from Kerr-McGee's Sequoyah Fuels Facility in Gore, Oklahoma, on January 4, 1986, the NRC has been conducting operational safety reviews at selected major fuel cycle and materials facilities. The review at your New Brunswick facilities will be conducted by a team from the NRC, Environmental Protection Agency, Occupational Safety and Health Administration and The Food and Drug Administration. The review has been scheduled for the week of August 8, 1988. The team leader, Dr. John Glenn, will contact your of fice at a later date to arrange a time for the entrance briefing.

During the review, the team will examine existing conditions at your far.ility to identify potential safety hazards that, when combined with facility opera-tions, could impact public health and safety. The team will also examine whether there are systems and procedures in place to identify the use and handling of hazardous materials which could result in radiological safety consequences, and will determine whether these are adequately implemented. The areas to be covered include personnel training, waste management, and operations, including procedure control, equipment meintenance, environmental monitoring, non-radioactive chemical control, fire protection, radiological contingency planning, package certifica-tion and transportation procedures.

After the review, the NRC will determine if measures are necessary to address any safety problems identified during the review. The review is not an inspec-tion; it is intended to provide feedback to both the NRC and fuel cycle and materials licensees. However, if a violation of a federal requirement is iden-tified during the review, it will be cited. Records of: reviews and audits conducted by your personnel i maintenance; training; and contingency plan drills should be niade available for review while the review team is at your facility, in order to facilitate the review, please provide to this office by July 25, 1988, a copy of your existing procedures which cover employee training, waste management, equipment maintenance, nonradioactive chemical control, fire pro-tection, operational safety and contingency planning, environmental monitoring, package certification and transportation of radioactive materials, I

o c.,e,un w .

>.pp.

-u v v o t I W/ r -

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.~<*

'E. R. Squibb and Sons, Inc. '

2 The response requested by this letter is not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.

If you have any questions concerning the review, please contact Dr. Glenn or Dr. Josephine Piccone of my staff at (215) 337-5169.

Thank you for your cooperation.

Sincerely, N AJL /

len L. Sjob , Acting Director Division of Radiation Safety and Safeguards cc:

Public Document Room (POR)

Local Public Docuent Room (Lp0R)

Nuclear Safety Information Center (NSIC)

State of New Jersey (2)

O. K. Balkunew, Radiation Safety Of ficer i

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