ML19352B056
| ML19352B056 | |
| Person / Time | |
|---|---|
| Site: | 07000498 |
| Issue date: | 05/26/1981 |
| From: | Sreniawski D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Graves B EASTERN MICHIGAN UNIV., YPSILANTI, MI |
| References | |
| NUDOCS 8106030011 | |
| Download: ML19352B056 (1) | |
Text
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- ,..n'o UNITED STATES NUCLEAR REGULATORY COMMISSION g
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799 ROOSEVELT ROAD
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ateu rttvu. ittisois sois7 MAY 2 61981 Bruce B. Graves, Ph.D.
License No. 21-06885-01 1209 Roosevelt Boulevard License No. SNM-454 Ypsilanti, Michigan 48197
Dear Dr. Graves:
This refers to your letters, dated November 21, 1980, and January 19, 1981, in which you expressed concerns regarding the radiation safety program at Eastern Michigan University, Ypsilanti, Michigan.
Enclosed is a copy of our report on an inspection conducted by this office on January 14 and 15, 1981, of activities at Eastern Michigan University authorized by NRC Byproducts Materials License No. 21-06885-01 and Special Nuclear Materials License No. SNM-454. Also enclosed is our letter, dated April 29, 1981, to the licensee concerning the results of that inspection.
Your interest in radiation safety and your bringing specific concerns to our attention are appreciated.
Sincerely,
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D. J. Sreniawski, Chief Materials Radiation Protection Section 2
Enclosures:
As stated cc w/encls, w/ltrs dtd 11/21/80 and 1/19/81:
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APR 2 91981 mar 4
Iastern Michigan University License No.
ATTN: John Porter, Ph.D.
License No. S - 4 President Chemistry and Physics Department Ypsilanti, MI 48197 Gentlemen:
This refers to the special inspection conducted by Ms. E. R. Matson and Mr. C. T. Oberg of this office on January 14 and 15, 1981, and the tele-phone conversations of January 29 and February 2, 1981, of activities at the Eastern Michigan University authorized by NRC Byproduct Material License No. 21-06885-01 and Special Nuclear Materin1 License No. SNM-454 and to the discussion of our findings with Drs. B. Ramsay and R. Silver and other members of your staff at the conclusion of the inspection.
The enclosed copy of our inspection report identifies areas examined during the inspection. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and in-terviews with personnel.
During this inspection, certain of your activities appeared to be in non-compliance with NRC requirements, as specified in enclosed Appendix A.
A written response, submitted under oath or affirmation, is required.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter, the enclosures, and your response to this letter will be placed in the NRC's Public Document Room, except as follows.
If the enclosures contain information that you or your contractors believe to be proprietary, you must apply in writing to this office, within twenty-five days of the date of this letter, to withhold such information from public disclosure. The application must include a full statement of the reasons for which the information is considered proprietary, and should be prepared so that proprietary information identified in the application is contained in an enclosure to the application.
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- Eastern Michigan' University
, APR 2 91981
- According to-our records, you have not yet responded to IE Bulletin No.-79-19.
"We have enclosed a copy of IE Bulletin No. 79-19 which requires action by you
'with regard to both of your licenses. Your response and action 'are requested to.be accomplished within the time specified from the date of receipt of this letter, disregarding the date of issue.of the Bulletin.
We will gladly discuss any questions you have concerning this inspection.
Sincerely, I
D. J. S eniawski, Chief.
Materials-Radiation Protection
[
Section 2
Enclosures:
1.
_ Appendix A, Notice of Violation
[
2.. LIE Bulletin No. 79-19 t
3.' IE Inspection Reports No. 03000818/81-01 and No. 07000498/81-01 cc w/encls:
Dr. R. Silver, Acting RSO Dr. B. Ramsay, Acting
.iead of Chemistry-Dept.
Central Files Reproduction Unit NRC 20b PDR NSIC l
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4 Appendix A NOTICE OF VIOLATION
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t Eastern Michigan University License No. 21-06885-01 License No. SNM-454
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As a result lof the special inspection conducted on January 14, 15, 29, and February-2, 1981, and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7, 1980), the following violations were identified:
License No. 21-06885-ql t'
1.
License Condition No. 12 requires licensed material be used by, or under the supervision of, individuals designated by the Radiation Safety Committee (RSC).
Contrary to this requirement, until January, 1981, individuals were i
permitted to use the sealed Cf-252 source without proper authorization or knowledge of the RGO and RSC.
t This is a Severity Level V violation (Supplement VII).
2.
10 CFR 19.12 requires all individuals working in or frequenting any portion of a restricted area shall be kept informed of the storage, transfer, or use of radioactive materials; and shall also be instructed in.the health protection problems associated with exposure to such radioactive materials or radiation, in precautions or procedures to minimize exposure, and in the purpose and function of protective devices employed.
Contrary to this requirement, until January,1981, individuals were pernitted to use the sealed Cf-252 source and/or frequent the Cf-252 storage area without receiving the information and training specified.
This is a Severity Level V violation (Supplement VII).
3.
License Condition No. 17 requires licensed material to be possessed and used in accordance with statements, representations, and procedures contained in the letter dated October 24, 1977. Appendix C of attach-ments to this letter requires that survey instruments be checked with a calibrated source once each year.
Contrary to this requirement, as of January,1981, survey instruments in the Physics and Astronomy Department had not been checked with a cali-brated source for periods up to two years.
This is a Severity Level V violation (Supplement VII).
An di stoWo44i b A v O C 2 $^'
6 9
Appendix A License No. 21-06885-01 and License No. SNM-454 4.
10 CFR 20.203 requires radiation areas to be conspicuously posted with signs bearing the radiation caution symbol and the words:
CAUTION:
RADIATION AREA. Each high radiation area shall be conspicuously posted with signs bearing the radiation caution symbol and the words:
CAUTION:
HIGH RADIA. TION AREA. Also, each area or room in which licensed material is used_or stored and which contains any radioactive material in amounts exceeding 10 times the quantities specified in Appendix C of Part 20 shall be conspituously posted with signs bearing the radiation caution symbol
~ and the words: CAUTION: RADIOACTIVE MATERIAL (S).
I Contrary to these requirements, until January, 1981, the licensee did not have adequate posting as specified.
Specifically, laboratories in Jefferson and Strong Halls in which radioactive materials readin in excess of five millirem per hour are stored and/or used were not posted as radiation areas. An area in which a source (about five micrograms of Cf-252) reading-in excess of 100 millirem per hour was maintained and i
used was nc. posted as a high radiation area.
Areas in which radioactive materials in excess of ten times the quantities of Appendix C, Part 20, are stored and used are not_ posted as radioactive materials areas.
This is a Severity Level V violation (Supplement IV).
5.
10 CFR 19.11 states: Each licensee shall post current copies of Parts 19 and 20 of the Regulations; the license, license conditions, or documents incorporated into the license; and the operating procedures applicable to the licensed activities. Further, the Form NRC-3 shall be posted by each licensee wherever individuals work in or frequent any portions of a re-stricted area.
Contrary to these requirements, until January,1981, the specified doc-uments were not always posted.
In laboratories B-114/115, Jefferson Hall, only Form NRC-3 was posted.
In the Physics Laboratory, 224 Strong Hall, none of the documents were posted.
This is a Severity Level VI violation (Supplement VII).
Pursuant to the provisions of 10 CFR 2.201, you are required to submit to this office within twenty-five days of the date of this Notice a written statement or explanation in reply, including for each item of noncompliance:
(1) corrective action taken and the results achieved; (2) corrective action to be taken to avoid further noncompliance; and (3) the date when full compliance will be achieved.
Under the authority of Section 182 of the Atomic Energy Act of 1954, as amended, this response shall be submitted under oath or affirmation.
4/as/BI OA k
Date
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-l D. J. S en awski, Chief Materia adiation Protection Section 2
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Accession No: 7908070515 SSINS No: 6820 l
1)NITED STATES i
OTTICE OT INSPECTION AND EhTORCEMENT ;j,
i NUCI. EAR REGULATORY COMMISSION i
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WASHINGTON, D.C.
20555
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August 10, 1979 IE Bulletin No. 79-39 I
PACKAGING OT 10W-IIVEL RADIDACTIVE WASTE FOR TRANSPORT AhT SURIAI.
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Description of Circumstances:
l I,ow-level radioactive vaste is that waste which can be tran,sferred and shipped to one of three waste burial facilities which are located in and licensed by the Agreement States of Nevada, South Carolina, and Washington. On July 10, j
1979, the Governors of the three states notified NRC Chairman Een,drie of the serious and repeated disregard for rules governing the shipments of low-level radioactive wastes to these-burial facilities.
Examples of violations of Agreement State, DOT and NRC rules follow:
Improperly packaged uranius fines igniting packaged liquid scintillation vials in combustible waste is believed to have caused a fire and destruction of a I
truck at the Beatty, Nevada burial facility on May 14, 1979.
j On July 2,1979, three of twelve' steel containers shipped to the Beatty burial facility were found to be leaking radioactive material. The asterial was described on the bill of lading as being a solid inorganic salt (evaporator concentrs,tes solidified with u.es formaldehyde) from a reactor facility. The l
Governor of the State of Nevada ordered the drums to be shipped out of the state and the burial facility was temporarily closed.
t On July 30, the first shipment into the reopened Beatty facility contained free liquid in "aolid" asterial. The radioactive contents were sand filters i
maed at an insitu leaching process at a tranium mill.
Forty-three shipments with sixty-three deficiencies were observed during the I
package inspection program between April 10 and July 5,1979, by the Agreement State of South Carolina, at the Barnwell, S.C. burial facility. The shipments were from reactor, medical, industrial and military facilities.
.? On June 28, 1979, the Federal Righway Administration issued a Botice of "O Tiolation to a reactor facility proposing a $10,000 fine for,"$ruek contamina-
' - - - - - - - ' - - - - - - - gallon drums of MA saterial and shicle.
I adioactive material to burial DUPLICATE DOCUMENT and Agressent State requirements and safety of the public. The Entire document previously d burial facilities have indicated entered into system under:
ey any have to initiate actions which nuo 7%8g7e5/5 No. of pages:
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FUUn UnlulRR
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION III
. Reports No. 03000818/81-01; 07000498/81-01 Docket No. 03000818 License No. 21-06885-01 Priority F(1-B)
Category VI Docket No. 07000498 License No. SNM-454 Priority F Category VI Licensee:
Eastern Michigan University l
Chemistry and Physica Departments Ypsilenti, MI 48197 Inspection Conducted: January 14 and 15, 1981 Inspectors:
C. T. Oberg h
N /9[/
j E.R.Matsonh E V.bl\\
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Approved by:
D. J. Sreniawski, Acting Chief 1
i Materials Radiation Protection l
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Section 2 Inspection Summary Special Inspection on January 14 and 15, 1981 (Reports No. 03000818/81-01; 07000498/81-01)
Areas Inspected: Special, unannounced inspection of licensee Organization; Licensed Program; Internal Audits or Inspections; Training, Retraining and Instructions to Workers; Itadiological Protection Procedures; Instrumentation; Materials; Facilities; Posting and Labeling; Surveys; Radioactive Effluent Control and Waste Disposal; Posting of Notices; Personnel Radiation Protec-tion - External; Confirmatory Measurements; and Independent Inspection Effort.
The inspection involved 20 inspector-hours onsite by two inspectors and nine hours at regional offices by three inspectors.
Results: Of the 16 areas inspected, five violations were identified against License No. 21-06885-01; Severity Level V violation - liransed material was being used by unauthorized personnel; Severity Level V violation - all in-dividuals working in or frequentin
,eptricted areas were not trained in
- g.evel V violation - survey instruments 11owing violations were against both 4; Severity Level V violation - doors DUPLICATE DOCUMENT ately posted with radiation area, high t
Entire document Previously signs; Severity Level VI violation -
entered into system under:
,ately posted with documents required by ANObfhbdb[hb58 N
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Bruod B. Graves.1209 Roosovolt Blvd.
Ypsilanti. Michigen 48197,19 Jan. 1981 (313)483-0058 home Director. Region 3 (313)487-0018 office Office of Inspection and Enforcement Nuclear Regulatory Commission BRUCE B. GRAVES f
799 Roosevelt Road m.,,.k eira.
Glcn Ellyn. Illinois 60137 (312) 932-2500 vew. m= em DCr Director You will recall I wrote you on 21 November 1980. In the meantime. I have j
hOtrd that you have paid an inspection visit to Eastern Michigan Universi-ty. I write you to express my appreciation for your work on this project, ccpecially if it was done in response to my report. I also wish to apolo-gise in the event that my letter (copy of the original one I sent) sent j
to Washington caused you any embarrassment. I samt it because I thought p;rhaps I had misunderstood which regional office to report to and that my criginal letter to you may have been the wrong regional office.
I I did not have them at the time I sent you my original letter, but in tho meantime, the film has been processed for some pictures I took on the cvening of 20 November 1980 in connection with my report on what I thought w3re irregularities. I am enclosing these pit.tures. I retain duplicates as woll, thct is I took at least two pictures of every subject. The numbers 1
rofer to the processing serial numbers on the olide frames. All frames in this set are dated "JAN 81 " by the processor.
13 Dr. Giles Carter (white lab coat) and students in room B-ll3 of Mark Jefferson, presumably part of metallurgy lab instruction. Picture taken through glass window in door (the one without the lock) be-tween B-ll3 and B-ll4. It was this laboratory activity which appears to be the one involved in leaving the hall-access door to B-ll3 gone from the ro/s unlocked at times when all the occupants were openj that i m.
15 same as #13 but a later time, perhaps a few minutes.
using grindurs. Angle through 17 Same as # 13 and #15 except students only,ing a different area of the lab.
the window is slightly different show 19 Picture of the neutron. irradiation source room showing only the doorway and door closed looking from B-ll4. The beaker of iodine sources is viraole on the corner of the green lab bench at lower right as well as a sign I put up on the bench to document the date and time.
21.23 These pictures show the same lab bench, iodine samples and date/ time sign as in 19 above, but they are taken from room B-ll3 through the doorway between for the purpose of documenting the total absence of locking devices on that door. The door to the neutron source room is the same as the door in #19 and is visible on the left. Note the pictures show both sides and the edge of the door between room.s B-ll3 and B-ll4. There is no cylinder lock. no turnbuckle, and no buttons on the edge of the door for locking.
29.31 Pictures of the survey meters I used that evening which I found in the laboratory for that purpose.
33 This is a picture of blackboard information that appeared in the labor-atory. B-ll4. at a time which would indicate it was used to lecture to the Chemistry 132 students involved in the Tg experiment in quest 6on. I did not see Mr. Ketan Trivedi write this erroneous in-formation on the board, but he would be the only one likely to do it since he was doing the demonstrations that day as well as the irradiations. He is the student I referred to earlier as being not qualified for these irradiations although I overlooked mentioning his name in my report. The ? cture clearly shows C&lifornium-256 i
3.41@24" P00R ORIGINAL. gr
i.
GravC3 Cf 19 January 1981 Pcgo two rather than Caglifornium 252 indicating his lack of knowledge. The preeence of this information on this blackboard also probably in-dicates Mr. Trivodi took these Chem.132 students into B-ll4 to i
give them this lec+ure without proper faculty supervicion of per-mission (at least i did not give such permission). I feel these students should have only been allowed to be in B-ll3. I also happen to know Mr. Gary VanGenderen who was the person that was teaching the course last term in radiochemistry, and I know him to be incapable of making such errors as these. He is too intelli-gent and too well trained in this field for that.*It is possible i
that a faculty member wrote this material on the blackboard around this time, but I doubt it. I did not encounter anyons like this in the two or three short trips I made to B-ll3 that afternoon (20 Nov.1980) but most of the time I was on the second floor and could not be sure. Dr. C. Anderson would be the most likely one.
as Me was the one I had heard gave permission for Ketan Trivodi to do ',he irradiations and to have the key to the Neutron source room.
C. Anderson was also in charge of coordinating the Chem 132 labs at the time. I doubt. however,thaf.- he went downstairs and gave this hecture on the T& experiment and irradiat&on.
[ (* ) Besides1 h5 was not on campus that afternoon as I reported
{
earlier.]
i I send you this additional information in the hope that it may assist you in your investigation here. You may keep the slides for your files and need not return them unless they would be discarded. In that event, you may send them back to me at your convenience and without obligation.
Thank you once again for your cooperation and assistance in this matter.
I Sincer y
urs.
acus Bruce B. Graves. (PhD)
(Department of Cher.istry Eastern Michigan Universityg)
Please address any correspondence to my home address only.
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WMk h I$2-52VN73S BRUCE B. GRAVES BRUCE B. GRAVES Department of Chem!:!rr
$ig, Eastern f.'!:higza Uniardty vwn n
BRUCE B. GRi;;is Departtnent of Chemi:try Eastern Michigan University Ypsilanti, Michigan 48197 P00R BRIGILI.
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3ruce 3. Graves 3
Eastern Midu.gan Um.versny 1209 Roosevelt 1va.
i.j Yi.silenti,..'ich 42397 f
Ypsilami, Michigan 4 :97 (313)4S3-005S hcme,or 437-001-8 Friday
' office 21 !!cverber 1950 Director, Region 3 Office of Inspection and 2nforceaent I;uclear Re6ulatcry Commission
~799 Roosevelt Road Glen Ellyn
. Illinois 60137 (312) 932-2500
)
Dear Director:
--I called the Duclear ReSulat:ry Commission in Tiashington at (301) 492-7000 tod.ay to..obtain your mailing address above in connec-tion with the enclosed report.
..I7.im. not responsible for the radiochemical area in our department i
of chemistry, however I have noted certain irregularities which ap-pear to n:e 'to warrant a report. I enclose my report of three paces.
I did not feel the matter of sufficient urgency to make a telephone report, but I do suspect that it i.ay be urgent enough for you to make a prompt luvestigation. I leave t'o you the decisions recarding actions that should be taken, if any. I am not in a position to de-tnnhe.uith certainty whether or not violations exist or actions should be talen. I am cnly Soing by my general sense of the area.
l You-will note I have had considerable experience in radiochemistry
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-as fiot~ed ~-in the report. You ui.11' hote my recommendations on a:e three enclosed.*
i I' would appreciate your holding this report in confidence if possible without nullifying the conclusions or actions you nicht take.
. In that event, you do not have to maintain confidence to that degree
[.j zicessd@.'for your freedom ' of action. I will' appreciate your minimi-e
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zation of 'my involvement in this matter.
Ey' apologies for submission of a hand-lettered report. :e are
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' notj: ell supplied with s.taff support here. I thank you for. cur in-terest and concern regardi-ng problems -we-Tay have here.
Sincerel you s,
- ) cI also enci no a r. n mr n +- +u
. QC ruce B. Graves, Ph.D.
Professor of Chemistry b
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