IR 05000827/2010009
| ML20154H107 | |
| Person / Time | |
|---|---|
| Site: | 03012037, 05000827 |
| Issue date: | 02/26/1986 |
| From: | Everett R, Holley W, Ricketson L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20154H094 | List: |
| References | |
| 30-12037-85-01, 30-12037-85-1, NUDOCS 8603100189 | |
| Download: ML20154H107 (5) | |
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l , APPENDIX A
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U.S. NUCLEAR REGULATORY COM11SSION
. REGION IV i
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NRC Inspection Report: 30-12037/85-01 License: 49-17002-01 Docket: 30-12037 i License: Chen and Associates, In Warehouse Road j Casper, Wyoming 82601 Inspections at: Rock Springs, Wyoming and Casper, Wyoming Inspections Conducte': d August 27, 1985 and October 9, 1985
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f Inspectors: - W[[ru ~2-6[Io
: L. T. Ricketson, Radi'ation Specialist Date
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WI 'L. 'Holl y,' Radiation
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/ Wh b ecialist Ddte /
Approved: * * , R. J. Everett, Chief, Nuclear Materials Date , Safety Section
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) Inspection Summary
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Inspection Conducted August 27, 1985 and October 9,1985 (Report: -30-12037/8501) Areas Inspected: A routine, unannounced inspection was performed at two use locations. The inspection included reviews of: (1) Facilities, Posting, and Security of Materials, (2) Personnel Monitoring, (3) Receipt, Use, Inventory, j and Transfer of Materials, (4) Leak Tests, and (5) Training of Personne ' The inspection involved 10 inspector-hours onsite by two NRC inspector ~ Results: Within the areas inspected, eight apparent violations were identified.
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- Failure to properly evaluate the cause of. excessive exposure (Section 4)
Failure to provide appropriate personnel monitoring devices to all
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i individuals working with licensed materials. (Section 4) 8603100189 060303 l REG 4 LIC30 4 49-17002-01 PDR
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3. Failure to adequately train individuals using devices containing licensed j ' material (Section 7) 4. Failure to leak test sealed sources at required interval (Section 6) 5. Failure to secure devices containing licensed materials during transportation. (Section 8) 6. Failure to maintain records of physical inventories of sealed source (Section 5) 7. Failure to maintain records of receipt of licensed materia (Section 5) f 8. Failure to post required document (Section 3)
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DETAILS 1 Persons Contacted
*Raymond Martinez, Radiation Protection Officer * Pat Bullinger, Rock Springs Manager Mark Peloquin Mike Cullum * Denotes those present at exit meeting . Management and Organization The licensee's corporate headquarters are in Denver, Colorado; however, the lead office for radioactive materials used in nonagreement states is Casper, Wyoming. Other permanent storage sites include Rock Springs, Wyoming, and Cheyenne, Wyoming. Approximately 20 people use the devices containing NRC licensed materia . Facilities, Posting, and Security of Materials The facilities were as described in the licensing documents. In both of the sites visited, a storage area was reserved for the devices which was locked at the time of inspectio In the Rock Springs office, copies of 10 CFR Parts 19 and 20, the license and associated documents, and the applicable operating procedures were not posted nor was there a notice posted telling where these documents could be found. This was identified by the NRC inspector as a violation of 10 CFR 19.11(a). Personnel Monitoring Personnel monitoring records'were reviewed at each sit In the Casper office, the badge report showing the totals for the first quarter of 1983 listed the following:
Employee A - 3.070 rems Employee B - 2.640 rems , Employee C - 2.060 rems 1 Employee D - 1.930 rems l Employee E - 2.480 rems Employee F - 1.490 rems Employee G -'1.960 rems None of the individuals had on file an NRC Form 4, documenting the radiation history; therefore, all of the exposures were identified by the NRC inspector as violations of 10 CFR 20.101(a). (Additional information was submitted by the licensee, at a later date, to satisfy the Commission that these were not true exposures and the violation was not cited.)
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, The Radiation Protection Officer did not have in his files a record of an evaluation made when the licensee should have been aware of the apparent overexposures, nor could he remember.one being made. This was identified by the NRC inspector as a violation of 10 CFR 20.201. .The licensee did not " have a copy of a report sent to either the Commission or the individuals involved in the apparent overexposures. There were no copies of such a report in the Region IV file This was identified by the NRC inspector as a violation of 10 CFR 20.405.and 10 CFR 20.409(a), respectively. (After the submission of the additional information referenced earlier, these
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violations were also not cited.)
In the Rock Springs office, the NRC inspectors spoke to an individual who
, stated that he had worked for the company for 6 months using the moisture density gauges and that he had not been given a personnel monitoring devic A check'of the personnel monitoring records confirmed his statement. This i was identified by the NRC inspector as a violation of License Condition 18,.
j which requires the license to follow the procedures and commitments stated in the license applicatio ' 5. Receipt, Use, Inventory, and Transfer of Enterials The office manager in Rock Springs offered nothing when records of receipt
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were requeste This was identified by the NRC inspector as a violation of 10 CFR 30.5 , Records of physical inventories of sealed sources were not available at either offic This was identified by the NRC inspector as a violation of License Condition 1 I Records were available in the Casper office showing utilization and transfer of the device , 6. Leak Tests
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A review of the leak testing records revealed the following: .
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In Casper: The sources in gauge 44 were not leak tested between 01/12/83 and 01/19/8 <
; The sources in gauge 45 were not leak tested between 12/10/82 and 01/24/84, j between 01/24/84 and 11/30/84, or between 11/30/84 and 07/27/85.
- The sources in gauge 50 were not leak tested between 11/30/84 and 10/09/8 ; The sources in gauge 52 were not leak tested between 12/10/82 and 01/24/84, or between 06/08/84 and 07/30/8 In Rock Springs, leak testing had not been performed on any of the sources during the period of December 6, 1984, and August 27, 1985, the day of the
inspectio These were identified by the NRC inspector as violations of License Conoition 13 A., which requires the. leak testing of sealed sources every 6 month ._ - _ - _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ - - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ - _ _ - _ _ - .. . .- - - - - -
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l 5 7. Training of Personnel
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i In Rock Springs, an individual who was interviewed by the NRC inspectors stated that he had never attended a formal training class in the proper handling procedures of the moisture / density gauges, either while employed by the licensee or his previous employer. The office manager stated that j the individual had been employed for about 6 months and that he had been i using the moisture / density gauges during that period. No training records were available either at Rock Springs or Casper for this employe , In the Casper office, names were taken from the utilization records and l checked against the training records. On the following dates, the devices l were used by individuals who had not received training as set forth in the j license application: Individual W used gauge #44 on 08/07/8 Individual X used gauge #44 on 08/15/8 Individual Y used gauge #50 on 08/02/85 and gauge # 44 on 08/08/8 Individual Z used gauge #58 on 08/19/85-08/21/85 and 09/05/85-09/06/8 No training records were available for the people using the devices on these days and the RPO confirmed that the individuals had not received the required formal training course, stating that some of the people were j summer help. This was identified by the NRC inspector as a violation of License Condition 1 . Transportation There were a sufficient number of transport containers for the devices in
- each location. Transportation was not observed, but both the RP0 and the i manager in Rock Springs stated to the NRC inspectors that no means was l currently being used to brace, block, or secure the device when being l transported in open trucks, which is a typical method of transportation.
! This was identified by the NRC inspector as a violation of 10 CFR 71.5(a).
l Examples of proper shipping papers were available.
t 9. Exit Meetings Exit meetings were held at each office at the end of the inspections with the apparent violations being discussed. Apparent violations found in both l locations were discussed with the Radiation Protection Officer. Top management in yasper was not available for the exit meeting, but were { contacted late; by phone and given the inspector's finding I
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