ML19340C426
| ML19340C426 | |
| Person / Time | |
|---|---|
| Site: | 07000882 |
| Issue date: | 06/13/1980 |
| From: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Mcgill W COLUMBIA UNIV., NEW YORK, NY |
| Shared Package | |
| ML19340C420 | List: |
| References | |
| NUDOCS 8011170288 | |
| Download: ML19340C426 (4) | |
Text
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UNITED STATES
,, gg a NUCLEAR REGULATORY Commission o.
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- REGION I g
431 PARK AVENUE KING OF PRUSSIA PENNSYLVANIA 19406 gg Docket No.70-882 Columbia University in the City of New York ATTN: Dr. William J. McGill President New York, New York 10027 Gentlemen:
Subject:
Inspection 70-882/78-01 This refers-to your letter dated May 5, 1980, in response to our letters of February 6,1979 and March 31, 1980, and to the May 1,1980, telephone conversation between Mr. W. G. Martin of my staff and Mr. H. Jacobson of your staff.
We have reviewed your May 5 response and have determined that you have not answered the questions required by Section 2.201 of the NRC's " Rules of Practice,"
Part 2, Title 10, Code of Federal Regulations.
The enclosure to this letter provides an analysis of your response.
In accordance with 10 CFR 2.201, you are hereby required to submit to this office, within seven (7) days of your receipt of this letter, a written statement or explanation in reply providing the information identified in the enclosure for each previously identified item of noncompliance.
We are concerned that we were able to obtain your response to our February 6, 1979 letter only after a second letter and a subsequent phone call.
The length I
of time that elapsed and the inadequacy of your reply indicate a lack of concern i
on your part for the responsibilities inherent with receipt of an NRC license.
Accordingly your response to this letter should also address the actions taken to assure that appropriate and prompt corrective action is taken upon receipt of enforcement correspondence from the NRC and that an accurate and complete response
(
is made to the NRC within the allotted time period.
We are particularly concerned about your apparent inability to locate the 58.4 grams of U-233 contained in 60 grams of uranium.
This material was reported as present in your Material Status Report covering the period April 1 - September 30, 1978, and signed by Mr. Paul Carter on October 16, 1978. Howo 3r, our inspector and Mr. Phil Lorio of your staff were unable to locate the great majority of this material during the November 30 - De~cember 1,1978 inspection.
As noted in Inspection Report Number 70-822/78-01, and in a January 26, 1979, l
phone call to Mr. Lorio from the inspector, it was agreed that Columbia University would conduct a complete physical inventory, locate, identify and label all l
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special nuclear material and notify the inapector of the results.
Your May 5,1980, letter indicates that this has not been done. Within seven (7) days of your receipt of this letter ini'.iate a complete physical inventory and make every effort to locate this material.
At the conclusion of the inventory, but no later than June 20, 1980, notify Mr. W. G.
Martin of this office at (215) 337-5230 of the results of the inventory.
In accordance with 10 CFR 2.790, a copy of this letter and the enclosure will be placed in the NRC's Public Document Room.
If this document contains any information that you (or your contractor) believe to be proprietary, it is necessary that you make a written application within 20 days to this office to withhold such information from public disclosure.
Any such application must be accompanied by an affidavit executed by the owner of the information, which identifies the document or part sought to be withheld, and which contains a statement of reasons which addresses with specificity the items which will be considered by the Comnission as listed in subparagraph (b)(4) of Section 2.790.
The information sought to be withheld shall be incorporated as far as possible into a separate part of the affidavit.
If we do not hear from you in this regard within the specified period, the document will be placed in the Public Document Room.
We would again like to call to your attention that our evaluation of your reply to this letter and the results of the physical inventory-will be considered in determining whether any escalation of enforcement action, such as a civil penalty, modification, suspension or revocation of your license, is appropriate.
Sincerely, D
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Boyce H. Grier Director
Enclosure:
Analysis of Columbia University Response cc w/ encl:
Dr. W. W. Havens, Jr., Director of Nuclear Engineering
PJ ENCLOSURE EVALUATION OF COLUMBIA UNIVERSITY RESPONSE
. ITEM 1 Ci ta tion:
Contrary to item 10 of License No. SNM-870, which identifies authorized places of use for plutonium sources possessed by the licensee, a 9 gram PuBe source was found in the Pupin Laboratory building which is an unauthorized storage location.
Evaluation:
The licensee returned the 9 gram PuBe source to the Engineering Terrace Building, which is the authorized storage location. Ilowever, the licensee failed to state corrective steps that would be taken to assure future compliance in this area, and failed to indicate the date that full compliance would be achieved.
ITEM 2 Citation:
Contrary to 10 CFR 40.64(b), which requires the submission of a report each year stating the amount of source material on inventory for those licensee's possessing more thar,1000 kilograms of source material, the licensee failed to submit a source material iriventory report for at least two years.
Evaluation:
The licensee included in his response a source material inventory report which did not meet the intent of the regulations.
An inventory report states the amount of material on hand (i.e., grams, kilograms), not the number of items, as was the case with the report submitted by the licensee.
- Also, the licensee failed to identify the corrective action that would be taken to assure timely submission of a;l future inventory reports, and failed to specify a date when full compliance would be achieved.
ITEM 3 Ci ta tion:
Contrary to Item 12 and Item 14 of License No. SNM-870, which require the licensee to verify the integrity of U-233 plated foils at least once every three months, the licensee was not only unable to provide records documenting the performance of required leak tests but was also unable to locate the U-233 plated foils.
J 2
Evaluation:
The licensee has reportedly attempted, unsuccessfully, to determine final disposition of a major portion of their U-233 inventory.
The licensee's response refers to receipt of 75 milligrams of U-233 which subsequently reportedly leaked from the bottle, was absorbed on a blotter and is presently packaged as waste.
There is no discussion of the 58.4 grams of U-233 which was shown on inventory on the September 30, 1978 Material Status Report.
The majority of this material was reported during the inspection to have been possessed as plated foils.
The licensee's response does not indicate what additional actions will be taken to locate the unaccounted for U-233.
In addition, corrective action has not been taken to assure that a similar situation does not occur in the future.
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