IR 07100002/2011009
| ML20236Y505 | |
| Person / Time | |
|---|---|
| Site: | 03018666, 07100002 |
| Issue date: | 12/05/1987 |
| From: | Mallett B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20236Y496 | List: |
| References | |
| NUDOCS 8712140044 | |
| Download: ML20236Y505 (3) | |
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NOTICE OF VIOLATION University of Dayton License No. 34-07958-05 As a result of the inspection conducted on October 2 to November 9,1987, and in accordance with 10 CFR Part 2, Appendix C - General Statement of Policy and Procedure for NRC Enforcement Actions (1987), the following violations were identified:
1.
License Condition No. 23 requires that all licensed matericl be possessed and used in accordance with statements, representations, and procedures contained in application received April 3,1985.
Item No. 7.3 of the referenced application states that the Radiation Safety Committee will meet on a quarterly basis.
Contrary to the above, the Radiation Safety Committee has not met quarterly as required.
Specifically, the Radiation Safety Committee last met in September 1985.
This is a Severity Level IV violation (Supplement VI).
2.
License Condition No.12 states that licensed material shall be used by or under the supervision of individuals designated by the Radiation Safety Connittee.
i Contrary to the above, one individual has used licensed material since March 1987 without receiving Radiation Safety Committee approval.
This is a Severity Level IV violation (Supplement VI).
3.
License Condition No. 23 requires that all licensed material be possessed and used in accordance with statement, representations, and procedures contained in application received on April 3,1985.
Itein No.10.5 of the referenced application states the Radiation Safety Committee will review the entire safety program and NRC required records annually.
Contrary to the above, an annual safety program and record review has not been perfonned as required. Specifically, a safety program and record review has not been performed since at least 1984.
lhis is a Severity Level IV violation (Supplement VI).
4.
License Condition No. 13 requires each sealed source be tested for leakage and/or contamination at intervals not to exceed six months.
8712140044 871207 REG 3 LIC30 PDR 34-079 58-Ob-
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Contrary to the above, each sealed source has not been tested for leakage and/or contamination at the required intervals.
Specifically, your eight millicurie nickel-63 detector contained in the Varian Gas Chromatograph Model Number 3700 has not been tested for leakage and/or contamination since 1984.
This is a Severity Level IV violation (Supplement VI).
5.
License Condition No. 23 requires that all licensed material be possessed and used in accordance with statements, representations, and procedures contained in application received on April 3,1985.
Item No.10.2 of the referenced application requires that surv y instruments be calibrated semi-annually.
Contrary to the above, survey instrumenu have not been calibrated semi-annually as required. Specifically, jour mini-monitor Series 900 survey instrument was last calibrated on Apcil 25, 1985.
This is a Severity Level IV violation (Supplement VI).
6.
10 CFR 20.401(b) requires each licensee to maintain records showing the results of surveys required by 10 CFR 20.201(b).
Contrary to the above, on the day of the onsite inspection, records of wipe tests performed in Room 229 Sherman Hall Research Laboratory, were not maintained.
This is a Severity Level V violation (Supplement IV).
Pursuant to the provisions of 10 CFR 2.201, you are required to submit to this office within thirty days of the date of this Notice a written statement or explanation in reply, including for each violation:
(1) corrective action taken and the results achieved; (2) corrective action to be taken to avoid further violations; and (3) the date when full compliance will be achieved.
Consideration may be given to extending your response time for good cause shown.
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Dated
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B. S. Mallett, Ph.D., Chief
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Nuclear Materials Safety and (
Safeguards Branch
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i Appendix B Management Control _
j In order to provide you with some guidance in assessing the adequacy of your management control program, the NRC Region III office provides the following as the acceptance criteria for adequate management control for materials licensees.
" Management Control" is a system instituted by management to assure that licensed activities are performed safely and in accordance with regulatory requirements (license conditions and applicable re gulations).
This will include:
a.
Delineation of duties and responsibilities of all persons involved in licensed activities, b.
Providing for indoctrination and training of all personnel performing licensed activities, specifically in those areas directly affecting compliance with NRC regulations and license conditions.
c Verification, as by checking, auditing and inspecting, that activi-ties affecting safety related functions have been correctly performed.
The verifying process should be performed by individuals or groups other than those performing the safety related procedures.
d.
Insuring continued compliance of licensed activities throughout periods during which routine activities may be interrupted, such as changes in equipment, personnel or facilities.
Because of the many variables involved, such as the number of personnel, type of activity being performed and the location or locations where activities are performed, the organizational structure for executing the management cont rol program may take various forms ; however, irrespective of the organizational structure, the individual or group responsible for this control should have the flexibility and authority to institute changes or corrections as required to maintain compliance with NRC regu-lations and license conditions.