ML19352B106
| ML19352B106 | |
| Person / Time | |
|---|---|
| Site: | 07001359 |
| Issue date: | 04/22/1981 |
| From: | Mertz R IRT CORP. |
| To: | Book H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML19352B105 | List: |
| References | |
| NUDOCS 8106030100 | |
| Download: ML19352B106 (3) | |
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e : ::::ra.:-na Instrumentation / Research / Technology April 22,1981
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United States Nuclear Regulatory Commission Region V 1990 North California Boulevard Suite 202 Walnut Creek Plaza Walnut Creek, CA 94596 Attention:
Mr. H. E. Book, Chief Radiological Safety Branch Gentlemen:
Subject:
Notice of Violation Dated March 30,1981 l'tc5
Reference:
SNM LicenseJ407 This letter is a response to the violations identified from the license inspection by your office on February 23-24, 1931. The violations are listed in accordance with the subject letter with a response following each listing.
A.
10 CFR 20,207 requires that licensed materials stored in an unresicicted area be secured from unauthorized removal from the place of storage.
Contrary to 10 CFR 20.207, on February 24,2981, a fifty-five gallon drum of waste materials containing 200 micrograms of plutonium and less tha 0.5 grams of uranium-235 was stored outside IRT's controlled areas at the 3vhn J. Hopkins Drive facility.
The waste drum was located outside of IRT's presently controlled area. This was an oversight in that IRT's boundaries were recently changed to accomodate General Atornic Company.
Corrective action: The waste drum was moved within IRT's controlled area on March 26,1981.
j B.
License Condition 8 states that authorized materials may be used in accordance with the statements, representations and conditions specified in the licensce's application dated December 8,1971, and as supplemented by letters dated May 14, 1973, January 15, February 5 and March 14, 1974.
- 1. The letter dated May 14, 1973 states that criticality monitors will be calibrated semiannually.
7650 Convoy Court e P.O. Box 80817 e San Diego, Cahfomia 92138 714 / 565-7171 e Telex: 69-5412 i
8106030l00'
M orporation f
April 22,1981 United States Nudear Regulatory Commission Page 2 Contrary to this requirement, on February 24, 1981, the criticality monitors lo-
' cated at the John 3. Hopkins Drive facility had not been calibrated in over a year. One Eberline RM-12A criticality monitor at the John 3. Mcpkins Drive facility was marked as having been calibrated on 7-18-74 The substantial decrease in activities involving SNM at the Linac Facility,.
essentially stcrage only, resulted in neglecting the calibration schedule. T bse monitors were not carried on the routine schedule for the survey instrumenta.
The tag had just not ben replaced.
Corrective action: The moniters were calibrated on April 8,1981. They are now included on the calibration schedule for our neutron survey instruments.
- 2. Section Vlli, " Instruction of Personnel" of the December 8,1971 application states t: ;t, " Periodic retraining will be conducted as appropriata on an as-needed basis, but spacing will not exceed a period of two years time."
Contrary to this requirement, licensee representativcs stated that three indivi-
-duals who had worked with licensed materials under NRC License SNM-1405 during the calendar year 1980 had not received any radiation safety training since May
'10, 1978.
Retraining of individuals is a non-routine function with a long-time interval. This was simply over-looked in 1980.
Corrective action: Retraining sessions for all IRT authorized personnel are scheduled for May,1981.
i C.
10 CRF 70.24(A)(3) requires that emergency dri!!s to familiarize personnel with the evacuation plan must be cenducted where quantities of licensed special nuclear mat-crial (as designated in 70.24(a)) are authorized to be handled, used or stored.
Contrary to this requirement, no emergency drills have ever been conducted at the John 3. Hopkins Drive facility where special nuclear material in excess of the amount designated in 70.24(a) were stored at the time of the inspection.
Emergency drills as such hav,, not been conducted at the John 3. Hopkins Drive facility since.1979 when operations there were very active. Again, the mostly storage-only nature of the activities since then resulted iri the violation.
Corrective action: At the time of the criticality monitor calibration and testing, I
April 3,1981, an evacuation drill was successfully conducted.
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orporation April 22,1981 United States Nuclea Regulatory Commission r
Page 2 With the exception of B.(2), we are presently in compliance. By the end of May,1981, condi-tion B.(2) will be satisfied and we will be in full compliance.
The subject of these violations was discussed at a special meeting of the Radiation Safety Committee. The Committee directed that the Radiation Safety Officer and Health Physicist make a listing of all routine license-required activities and have them entered into IRT's VAX Computer file to provide automatic reminders of required activities. The program would in-clude scme positive entry satisfying the requirement to halt repeated notices. The program would also include a listing of authorized personnel and their training status. This should be accomplished within the next sixty days and should provide a more effective means of moni-toring the Radiation Safety Program.
If you have any questions or require additional information, please call me at (714) 565-7171 ext. 211.
"I certify that all information in this letter is true and correct to the best of my knowledge and belief."
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Ifeber A crtz N
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President
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