ML20004C056
| ML20004C056 | |
| Person / Time | |
|---|---|
| Issue date: | 05/20/1981 |
| From: | Wiedeman D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20004C051 | List: |
| References | |
| NUDOCS 8106010469 | |
| Download: ML20004C056 (3) | |
Text
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O Appendix A O
NOTICE OF VIOLATION Department of the Navy License No. 12-06092-01 l
l As a result of the inspection conducted on April 23, 1981, and in accord-ance with the Interim Enforcement Policy, 45 FR 66754 (October 7,1980),
the following violations were identified:
1.
License Condition No. 18 states that the licensee shall possess and use licensed material in accordance with statements, representations and procedures contained in application received November 27, 1978.
Item 17 of that application specifies weekly wipe tests of laboratory areas other than elution, preparation and injection areas.
Contrary to the above, from 1979 to the date of the inspection, these surveys have only been performed on a six month basis.
This is a Severity Level V violation (Supplement VII).
2.
License Condition No. 18 states that the licensee shall posses and use licensed material in accordance with statements, representations and procedures contained in application received November 27, 1978.
Item 10 of that application specifies a quarterly frequency for the performance of a linearity test on your dose calibrator.
l Contrary to the above, no linearity test was performed on your dose calibrator between September 3,1979 and July 1980, a period in excess of the quarterly frequency.
This is a Severity Level V violation (Supplement VII).
3.
License Condition No. 18 states that the licensee shall possess and use licensed material in accordance with statements representations and procedures contained in application received November 27,. 1978.
Ites 10 of that application specifies an annual calibration frequency for your survey instruments.
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f Appendix A 4 Contrary to the above, survey instruments No. A105 and No. A3752 had not been calibrated between August 1978 and March 1981, a period in excess of the annual frequency requirement.
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4.
License Condition No. 17 requires sealed sources greater than 100 microcuries containing material other than hydrogen-3 with a half-life greater than thrity days be leak tested every six months and that a record of the results of these tests be maintai-sd for in-spection by the Commission in units of microcuries.
Contrary to the above, your 217 microcurie Cs-137 source and your 262 microcurie Ba-133 source were not leak tested between January 1979 and March 1981, a period greater than six months. Results of leak tests that were performed were not recorded in microcuries.
This is a Severity Level V violation (Supplement VII).
5.
License Condition No. 18 states that the licensee shall possess and use licensed material in accordance with statements, representations and procedures contained in application received November 27, 1978.
Item 7 specifies an annual radiation safety review be conducted by the Medical Isotopes Committee.
Contrary to the above, no such reviews have been conducted.
This is a Severity Level V violation (Supplement VII).
6.
10 CFR 35.14(f)(2) requires each licensee who possesses and uses calibration and reference sources pursuant to 10 CFR 35.14(d)(4) to conduct a quarterly physical inventory to account for all sources received and possessed.
Contrary to the above, quarterly physical inventories of your Ba-133 and Cs-137 sealed sources were not conducted between January 1979, and April 1981, a period in excess of the qua tterly frequency requirement.
This is a Severity Level V violation (Supplement VII).
7.
License Condition No. 18 states that the licensee shall possess and use licensed material in accordance with statements, representations and procedures contained in application received November 27, 1978.
l Item 12 of that application specifies monthly radiation safety train-ing lectures.
Contrary to the above, during 1979 and 1980, radiation safety training lectures were provided on an "as needed" basis which did not meet the monthly requirement.
This is a Severity Level V violation (Supplement VII).
1
Appendix A 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 ites 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 com-pliance 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.
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Dated D. G. Wiedeman, Acting Chief Materials Radiatica Protection Section 2 5
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