ML19344B226
| ML19344B226 | |
| Person / Time | |
|---|---|
| Site: | 07002039 |
| Issue date: | 08/07/1980 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19344B224 | List: |
| References | |
| NUDOCS 8008250776 | |
| Download: ML19344B226 (3) | |
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Appendix A NOTICE OF VIOLATION University of Illinois License No. 12-00088-06 at the Medical Center License No. 12-00088-08 License No. 12-00088-09 License No. SNM-1552 Based on the inspection conducted on July 21-23, 1980, it appears that certain of your activities were in noncompliance with NRC requirements, as noted below.
Items 1 through 5 are infractions, and items 6 and 7 are deficiencies.
1.
Title 10 CFR 20.105(b) requires that radiation levels in unrestricted areas be limited so that if an individual were continuously present in the area, he could not receive a dose in excess of 2 millirems in any hour or 100 millirems in any seven consecutive days.
Contrary to the above, on the day of the inspection, levels in excess of 2 millirems per hour were found in a hallway adjacent to Room 328 (source storage room).
2.
License Condition 24 states that the licensee shall possess and use licensed material in accordaace with statements, representations and procedures listed in letter dated October 18, 1978. This letter states,.
in part, that dose calibrator accuracy tests should be within 110% and l
that fluctuations greater than this value will be reported.
I Contrary to the above, from January 7,1980 to March 17, 1980, ar..:uracy tests fluctuated as much as 34% and no corrective action was taken.
3.
License Condition 24 states that the licensee shall possess and use licensed material in accordance with statements, representations and procedures listed in application dated July 18, 1978.
Item 5 of this application states that all GM counters will be calibrated at six month intervals.
Contrary to the above, no calibration was performed on thirteen GM survey instruments between October 6,1979 and May 23, 1980, nor on three instruments from March 2, 1979 to the date of this inspection, periods greater than six months.
4.
License Condition 24 states that the licensee shall possess and use licensed material in accordance with statements, representations and procedures listed in application dated July 18, 1978. Appendix C of this application states that the nuclear medicine area, including all scanning rooms, hot lab and nuclear pharmacy will be monitored daily.
8ooseso 77f
i 2-Appendix A Contrary to the above, it was learned from statements made by licensee representatives that area surveys are performed an average of two to three times per week.
5.
License Condition 24 states that the licensee shall possess and use licensed material in accordance with statements, representations and procedures listed in Radiation Safety Manual dated 1977.
Item E.2 of this manual states that liquid and solid wastes must be placed in waste containers supplied or approved by the radiation safety office.
Contrary to the above, on the date of this inspection, contaminated waste was found in open cardboard boxes on a lab bench within Room 340.
6.
License Condition 24 states that the licensee shall possess and use licensed material in accordance with statements, representations and procedures listed in letter dated October 18, 1978. This letter states, in part, that results of linearity, constancy and accuracy checks performed on the dose calibrator would be recorded.
Contrary to the above, the results of linearity and accuracy tests performed between May 19 and May 29, 1980 were not recorded for the dose calibrator in use during the inspection, moreover, no record of daily constancy checks has been kept.
7.
Title 10 Code of Federal Regulations Part 20.401(b) requires that each licensee shall maintain records in the same units as used in Part 20.
Part 20.205(b) requires records of results of surveys of packages.
Contrary to the above, survey results of packages received in the Pharmacology Department were recorded in epm instead of microcuries, and no action levels for contamination or information allowing con-version from cpm to microcuries was available.
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6 Appendix B Management Control 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 regulations).
This will include:
3 Delineation of duties and responsibilities of all persons involved a.
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.
Verification, as by checking, auditing and inspecting, that activities c.
affecting safety related functions have been correctly performed. The verifying process should be performed by individuals or groups other than those performing 'he 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 control 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 regulations and license cenditions.
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