ML19323G678
| ML19323G678 | |
| Person / Time | |
|---|---|
| Site: | 07000398 |
| Issue date: | 04/22/1980 |
| From: | Bell K NATIONAL INSTITUTE OF STANDARDS & TECHNOLOGY (FORMERL |
| To: | Galen Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19323G676 | List: |
| References | |
| NUDOCS 8006060459 | |
| Download: ML19323G678 (6) | |
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UNITED CTATED DEPARTMENT CF COMMERCE a
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U. S. Nuclear Regulatory Commission Region I Atta:
Mr. George H. Smith Chief, Fuel Facility and Materials Safety Branch 631 Park Avenue King of Prussia, PA 19406 Gentlemen:
Subj ect: Response to Inspection No. 70-398/80-02 This is in response to your letter of March 27, 1980, to Mr. R. P. Bartlett, Jr.,
regarding Inspection No. 70-398/80-02 conducted on February 27-29, 1980, by Mr. J. Roth of your office.
With specific regard to the infraction outlined in the Notice of Violation contained in Appendix A to your letter, please be informed that all Type B and large quantity radioactive materials shipments from NBS have been terminated, effective March 21, 1980, until a Quality Assurt.2ce Program for Shipping is submitted to and approved by the U. S. Nuclear Regulatory Commission.
In effect, this interim action will avoid further items of noncompliance regarding the QAP provisions in question.
The NBS Health Physics Unit is developing a QAP and it will be submitted in May 1980 to the USNRC-NMSS for approval. We are most anxious to be able to resume shipments of the radioactive materials in question and to be in compliance with the applicable USNRC requirem uts therefor.
I Regarding our assumption that the IAEA Certificate of Competent Authority I
referenced in the Notice of Violation constituted a special permit, thus ex-empting NBS frem the requirements specified in 10CFR Part 71.10, that assumption was based on a number of discussions and the results of a past inspection.
These included discussions with the Office of Hazardous Materials (OHM), DOT, at various times, particularly during certificate renewals; a discussion with Mr. Serabian of USNRC Region I, on December 12, 1979, during which our Mr. Hobbs informed him that we were drafting a contingency QAP plan for shipments for which the special permit would not apply; a discussion with Mr. Carrike: of OHM-DOT, on March 3,1980, concerning QAP's, special permits and certificates, during j
which time he agreed with our assumption; and USNRC Inspection No. 70-398/79-02, during which no mention was made of a relationship between a QAP and the docu-ments on which the current inspection is centered. These documents are used for I
recording rentine radioactive materials shipments, other than radioactive wastes, in our materials control program.
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In response to the comment in your letter that certain aspects of training required in IE Bulletin 79-19 had not been conducted for our employees involved in packaging, transfer and transportation of radioactive materials, please be informed that the required training was completed on March 26, 1980.
The enclosure hereto contains copies of documentation on file regarding the type of training given to whom and when it was given.
The additional constructive comments in the details of the inspection report fdr which responses were not requested have been considered and either have been or will be incorporated in our overall radiation safety program as appli-cable.
Thank you for having brought these matters to our attention.
Sincerely, W
7 Karl E. Bell Deputy Director for Administrative Systems Enclosure
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ENCLOSURES 1.
RP Staff Training (March 5, 1980) 2.
Radioactive Waste Training Classes (March 25, 1980) 3.
HP Staff Training (March 26, 1980)
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HP Staff Training 10:00 - 11:30 am, 3/5/80 Trainer:, Hobbs lj[!
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Attendance:
Cassidy, Eggert, Hoaney, Kroll, Moore, Randel, Terry, Tynes Handouts:
- Table of Irradiation Limits information sheet RAM Shipping and Receiving Instructions and information NBS-796, Shipper's Certification for Radioactive Materials
- Deletion of NBS-366, Record of Inspection for Radioactive Materials, information note 12/3/79 memo to users, Interim Procedures for Radiation Safety
- 11/28/79 memo, as above, with revised HP documents and attached HP staff memo of 11/26/79, InterLa Procedures for Radiation Source Control Topics and discussions:
Limits table and 10CFR 19, 20, 30, 31, 32, 33, 40, 50, 70, 71, 73 Shipping and receiving instructions
- Shipper's certification and information sheets i
Quality assurance program; exempt Type A and B shipments 3
Notes, memos, and revised HP documents on source control Need to generate RAW (vaste) instructions, note SNM/ liquid /short-lived / cross-contaminated containers Storage for HP documents in any HP room in 235 or 245 Compactor operators' training to be 3/11/80; 2 to 3:
Paul and Fred show Debbie, George, and Jim; 3 to 4: Keith, Debbie, and George show John K. and Tiny George and Debbie in charge of waste program Need method for checking all trash from controlled areas
- Training plans for HP staff.and users i
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UNITED STATES DEPARTMENT OF COMMERCE M
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washing:en 0.C. 20234 b arss d March 25, 1980 MEMORANDtM FOR Mr. Thomas G. Hobbs Acting Chief, Health Physics Health Physicist [ W From:
Paul R. Cassidy Subj ect:
Radioactive Waste Training Classes Radioactive waste training classes were given by Paul Cassidy and Fred Moore, Jr., on March 11 and March 18, 1980, to the following people:
John Kroll Keith Eggert George Randel Carroll Tynes Jim Terry DeBorah Hoaney The following topics were demonstrated or discussed:
Protective clothing Respirators Air sampling
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Surveys - surface and contamination Documentation Compactor operations Non-compactible waste Labelling, marking Package inspection, closure c
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t UNITED STATES DEPARTMENT OF COMMERCE National Bureau of Standards
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washington. O.C. 20234 March 26, 1980 MEMORANDUM FOR Health Physics File hiY From:
Thomas G. Hobbs Acting Chief, Healt Physics Subj ect: HP Staff Training Attendees:
Cassidy, Eggert., Hoaney, Kroll, Moore, Randel, Terry, Tynes Trainer: Hobbs Topics:
Emergencies - response times and modes, survey meters and monitoring, responsibilities Shipping - Quality Assurance Program, halt on Type B and large quantity RAM, certification form, DOT specifications, DOT regulations i
Surveillance - Moore /Tynes are responsible for 235/245 surveys per draft procedure and floor monitoring, instructions, survey meters, drains and outfalls locations l
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