IR 05000626/2007003

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Insp Rept 30-20693/85-01 on 850626-0703.Violations Noted: Failure to Provide Required Training,Transportation of Licensed Matl in Unapproved Package & Failure to Leak Test Sealed Sources
ML20133G090
Person / Time
Site: 03020693, 05000626
Issue date: 07/18/1985
From: Costello F, Dennis N
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20133G079 List:
References
30-20693-85-01, 30-20693-85-1, NUDOCS 8508080552
Download: ML20133G090 (5)


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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report _No. '30-20693/85-01 Docket No. 030-20693 -

License N Priority 3 Category E Licensee: Geo-Tech Associates /Geo-Tech Laboratories

. Facility Name: Geo-Tech Inspection At: Fanwood, New Jersey Inspection Conducted: June 26 and July 3, 1985 Inspector: /%uN)-

Nancy Ann Dennis

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Health Physicist Opte /

Approved by: ArpwE, -

[d hD Frank Costello, Chief da(t6 Nuclear Material Safety Section A Inspection Summary: Routine unannounced inspection of radiation safety program on June 26 and July 3, 198 *

Areas Inspected: Organization,' training, security of materials, transportation, leak tests and record Results: Six apparent violations were identified: unauthorized users of licensed materials (paragraph 2); failure to provide required training (paragraph 3); transportation of licensed material in unapproved package (paragraph 5); failure to leak test sealed sources at the required interval (paragraph 6); failure to maintain records of physical inventories of sources (paragraph 7); failure to post required notices and NRC-Form 3 (paragraph 7).

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G508000552 850718 REG 1 .IC30-29-16205-02 PDR '

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DETAILS Persons Contacted'

Mr. Carmin DeVito, President Mr. Al Farruggia, Engineeing Staff Mr. Jim Lewis, Engineering Staff Organizations The Radiation Safety Officer (R50) named on the license, reports to the President of Geo-Tech. Item 12 of Materials License 29-18205-02 requires that licensed material be used by, or under the supervision and in the physical presence , the RSO. However, the named RSO left the company in November 1984 and a new Radiation Safety Officer has not been appointe Two members of the engineering staff have used the gauges containing licensed materials on numerous occasions since the only authorized user named on the license (the 253) left the compan The finding that individuals used licensed materials without the physical presence of the authorized user named in License 29-18205-02 is an apparent violation of License Condition 1 On June 27, 1985, the NRC issued a Confirmatory Action Letter to the licensee confirming that the licensee would immediately cease using licensed materials without the physical presence of an individual authorized in Condition 12 of License 29-18205-0 Further, the letter confirmed the licensee's plan to submit a request to the NRC to add additional individuals as authorized users to Condition 12 of the licens During inspection of the licensee on July 3,1985 all sources were inven-toried by the inspector and determined to be on the licensee's premises inside a padlocked, plywood cabinet in the basement storage room of the facility. The President of Geo-Tech stated that plans were being made with Troxler Electronic Laboratories, Inc. (the supplier of two of the licensee's three gauges) to obtain appropriate training for himself and the two members of his engineering staff who plan to use the gauges in the future. After successful completion of training, Geo-Tech plans to submit a request for amendment of License Condition 1 . Training An interview was conducted on July 3,1985 with both members of the engineering staff that have been using the gauges since the authorized user and RSO left Geo-Tech. Both individuals were trained by the RSO in how to use the gauges and how to perform associated ra'culations after the RSO had attended a two-day training course for the use of nuclear testing equipment during January, 1980. Both individuals indicated that the RSO spent three to four hours, instructing them in radiation safety principle Each of these individuals had in their possession the Blue series 3400 and 3400B Basic Instruction Manuals published by Troxle * ' .

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Geo-Tech Associates 3

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Discussion with one of the individuals revealed-that he had worked for the licensee for approximately six years, but had used licensed material only in the last two-three years. Upon questioning by the inspector it was found that this individual co@1,not describe the basic types of radiation, the units associated with measuring radiation, the dose limits imposed by NRC regulations, nor was this individual familiar with the license or license application of Geo-Tech or with NRC or DOT regulations. This individual had not participated in any formal radiation protection training program for users of radioactive gauge Discussion with the other individual revealed that this employee has worked for the licensee for approximately 1.5 years and has used licensed materials during that entire period. While this employee was familiar with the basic types of radiation and methods of dose reduction, including time, distance, and shielding, he was unfamiliar with basic properties of radioactive material, was confused about the proper units for measuring radioactivity, and was unfamiliar with Geo-Tech's license and license application. This individual had not participated in any formal radiation protection program for users of radioactive gauge Discussion with the President of Geo-Tech indicated that he was unfamiliar with the requirements of their license, with NRC and DOT regulations and with the need for an amendment to their license since the named author-ized individual was no longer an employee of the compan The finding that source material was used on numerous occasions by individuals not adequately trained in radiation protection practices and in specific conditions and requirements of their NRC license is an apparent violation of 10 CFR 19.1 . Security of Materials The licensee was in possession of two Troxler gauges and one Nuclear-Chicago gauge on both days of inspection. On June 26, 1985 the gauges were stored in an unlocked, plywood cabinet located in an unlocked, basement storage room. The door to the stairway leading to the source storage room was propped open with construction supplies. Immediately adjacent to this doomay was another open doorway which opened onto a narrow, grassy field beside the office building. While it did not appear that access to the building through these open doomays was likely, the gauges containing licensed material were not adequately secured against unauthorized removal from the place of storag The failure to adequately secure licensed materials against unauthorized removal from storage is an apparent violation of 10 CFR 20.20 On July 3, 1985 the inspector verified that the gauges were in possession ,

of the licensee and were contained in the storage cabinet described above l

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Geo-Tech Associates 4

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which was padlocked. The door to the storage room in the basement and the adjacent door that opened to the outside field were unlocked and propped open as befor . Transportation The gauges possessed by the licensee were originally contained in heavy 3/4-1" plywood boxes with pre-formed foam liners for shipping that were manufactured by Troxler. Because of the weight of the wooden cases (es-timated at 60-80 lbs.), the users of these gauges had been transporting the gauges to the job site with associated pre-formed foam liners that normally fit inside the wooden shipping boxes. The foam packing is not an approved Type A package for transport of the licensed material in the gauge The failure to transport licensed materials in an approved Type A package constitutes an apparent violation of 10 CFR 7 ... ,

6 Leak Test Condition 13 of License 29-18205-02 requires that the licensee leak test, at intervals not to exceed six months, each sealed source with half-life greater than thirty days and in any form other than gas. A review of licensee records indicated that no leak tests had been performed since April 30,1984. Discussions indicated that the last employee who knew how to perform a leak test left the company at least two months earlier than the date of inspectio Failure to perform leak tests of sealed sources at the specified frequency is an apparent violation of License Conditions 1 . Records and Postings License Condition 15 requires that physical inventories of licensed material be performed every six months and that records of the inventories be maintaine A review of licensee records and discussions with licensee personnel indicated that no physical inventories had been performed. This is an apparent violation of License Condition 1 The inspector noted that copies of the license, license application, routine operating procedures and 10 CFR Parts 19 and 20, were not posted. Further, no notice describing these documents and stating where they may be examined .

was posted. The inspector also noted that no current NRC Form 3 was poste This is an apparent violation of 10 CFR 19.ll(a), (b) and (c).

Contrary to the above, neither the documents described above nor a current NRC Form 3 were poste This is a violation of 10 CFR 19.ll(a)(b) and (c).

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1 Exit Interview (

- The inspector met with the licensee's President at the conclusion of the 4 inspection on June 26, 1985. The inspector sumarized the scope and

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-findings of the inspection.

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