ML20005B633

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Responds to NRC Re Violations Noted in IE Insp of Licenses 21-06885-01 & SNM-454 on 810428.Corrective Actions: Written Instructions for Any Users of Cf-252 Source Have Been Prepared & Revised.Instructions Encl
ML20005B633
Person / Time
Site: 07000498
Issue date: 05/22/1981
From: Silver R
EASTERN MICHIGAN UNIV., YPSILANTI, MI
To: Sreniawski D
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20005B607 List:
References
NUDOCS 8107080460
Download: ML20005B633 (7)


Text

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p Eastern Michigan University Ypsilanti, Michigan 48197 May 22, 1981 Mr. D. J. Sreniawski, Chief Materials Radiation Protection, Section 2 Region III, Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137

Dear Mr. Sreniawski:

The following statements are in response to your Notice of Violation, Appendix A, dated April 28, 1981, for NRC Byproduct Material License No.

21-06885-01 and Special Nuclear Material License No. SNM-454 held by Eastern Michigan University.

1 and 2.

Prior to September 1979 the Cf-252 source was under the direct supervision of Dr. K. Rengan of the Chemistry Depart-ment who is also the University RSO.

Dr. Rengan has been on a research leave from the University since September, 1979 and expects to return in August,1981.

Dr. Brenda Manning of the Chemistry Department was designated by Dr. Rengan to supervise the use of the source in his absence.

As a result of the inspection of January 14 and 15,1981, Dr.

O. Bertrand Ramsay, acting head of the Chemistry department, placed the Cf-252 source on limited use. (See attachment A).

It was further agreed that the limited use would continue until Dr. Rengan returned. Any use of :he source in this interim period ras to be under Dr. Brenda Manning's direct supervision and was to be cleared with Dr. Robert Silver, the acting RSO.

Written ins ru'tions for any users of the Cf-252 source were prepared at.1 ' ave gone through one revision. A copy of the instruction attached as attachment B.

-a u

Follow',ig.

sephone request of February 2,1981 for gamma and n utron survey data of the Cf-252 source room, the room was "arveyed with the source in the activation position and then the source war removed to its packing crate.

During 0 0107080460 810626 iPDR ADOCK 07000498 d.C PDR

~.

a Mr. D. J. Sreniawski 4

May 22, 1981 Page 2 the survey, Drs. Silver and Manning, who conducted the survey, discussed the results, hazards and procedures for minimizing exposure when using the source so that Dr. Manning, who would be nandling the source until Dr. Rengan's return, would be better prepared to do so. Copies of the survey results and instructior,s are posted by the source room.

On two occasions during. the Winter,1981 semester the source was used.

On both occasions Dr. Silver, the acting RSO, was verbally notified and the source was handled by Dr. Manning.

No further use of the source is contemplated before Dr.

Rengan's return. The source will be kept in its packing crate until then.

Dr. Manning has left the University for another position as of the end of April,1981.

Resnonsibility for the source is now directly under the acting-RSO, Dr. Silver, until Dr.

Rengan's return in August, 1981.

Dr. Ramsay, acting head of the Chemistry department, is maintaining a strict control over the nuclear chemistry laboratories and no use of them is expected until Dr. Psengan's return.

~

In summary, with regard to authorization to use and instruction in the use of the Cf-252 source the acting RSO, Dr. Silver, feels we are now in compliance.

However, a further review with 9

the intent to establish more permanent procedures will occer when Dr. Rengan returns.

It should also be noted that the door between rooms B-ll3 and B-ll4 Mark Jefferson building which did not have a lock now has a lock and has the same restricted access as the main hall door to room B-ll4. This had been noted in item 5 of the main inspection report and was a change that was already in progress at the time of the NRC inspection visit.

3.

The nuclear laboratory in the Physics and Astronomy Department, 224 Strong Hall, has two primary survey instruments. One is a gamma and beta instrument and the other a neutron detector.

The gamma and beta instrument is a Nuclear-Chicago (Texas-Nuclear) Model 2650 with maximum ranges from 0.1 to 100 MR/HR.

l It was shipped with a Ra-226 0.9 Ci source (Amersham /Searle, Model 184100) and calibration data dated 5-6-74 for 4.5 MR/HR and 49.0 MR/HR representing the two sides of the source when placed directly against the end window detector. These calibration checks have been made since the insoection visit and show the instrument to be functioning properly and accurately.

I Mr. D. J. Sreniawski May 22, 1981 Page 3 Further, during the survey of the Cf-252 source in the Chemistry Department the above instrument was also'used and good agreement was obtained with the results from the Chemistry department's calibrated gamma detector.

On the basis of these checks, Dr. Silver decided to delay a calibration of the instrument by an outside contractor until after the Winter 1981 semester when the nuclear laboratory would not be in use. The University of Michigan Radiation Control Service has agreed to calibrate this instrument for us, which we expect to have done some time in Jura 1981.

The second instrument requiring calibration is a Nuclear-Chicago (Texas-Nuclear) Model 2673 meter with a Model 2646 Neutron Probe.

Its maximum ranges extend from 25 to 25K neutrons /cm2/sec for fast neutrons and one-third of these quantities for slow neutrons. This instrument was also used during the February survey of the Cf-252 soui-e to compare it to the neutron detector borrowed from the University of Michigan Phoenix Memorial Laboratory. The U of M detector was scaled in MR/HR so a direct comparison was not possible, however, comparable readings on a relative basis were obtained to indicate that our detector was functioning.

The. EMU detector was also used to survey the area around the two Pu-Be neutron sources in the nuclear physics laboratory, 224 Strong Hall (See Attachment C). The surv2y includes fast and slow neutron counts and shows reasonable changes in readings with position. Also the slow neutron flux at the sides of the barrels show approximately the 10:1 ratio expected.

At the time of the inspection in January the fast neutron probe was used and some of the results were obtained for the region between the barrels where a change in flux is not as marked, This may account for some of apparent constant readings.

Now that the Winter semester has ended the neutron detector will be sent out for calibration, however, as of this writing it may have to go back to the manafacturer since the U of M Radiation Control Service is not set up to calibrate neutron detectors.

4.

All laboratories and areas where radioactive materials are stored or used are now posted with Caution: Radioactive Materials signs.

r Mr. D. J. Sreniawski May 22, 1981 Page 4 5.

Posting of NRC-3 have now been made in the Physics Laboratory, 224 Strong. Further a note has been added to the NRC-3 forms in both the Chemistry and Physics Departments referring persons to the respective department offices for copies of 10CRF19, 10CFR20 and our license.

Our response to IE Bulletin No. 79-19 is being prepared and will be submitted within 45 days from the date of your letter as per your instructions.

We hope these responses meet your approval but if you need any additional information or clarification of our responses please contact me at this address or via telephone at 313-487-4144.

Sincer a

h (2,C Dr. Robert Silver, Head (Acting RS0)

Physics and Astronomy Department RS/ab Attachments cc:

Dr. John W. Porter, President Dr. O. Bertrand Ramsay I

Brenda Manning Dr. Krishnaswarmy Rengan Dr. Ronald W. Collins, Associate Vice President for Academic Affairs

RTTAC/unE7/7~

R INSTRUCTIONS FOR USE OF THE Cf SOURCE 1.

Persons must be authorized by K. Rengan or Brenda Manning.

I 2.

Never have any part cf your body directly above the source.

3.

Do not handle the source unless specifically instructed and authorized to do so.

4.

Do not spend more than a total time of two minutes per week within 2 feet of the soun:e:

This is based on the following calculation:

HRC maximum allowable exposure rate = 100 mrem / week (5 Rem /yr) 1/10 x 100 mResVweek = 10 mrem / week At e point directly above the source, i.e. highest level of radiation, neutrons a 200 mrem /hr and gamas a 100 mRenVhr Total = 300 mrem /hr 300 mrem /hr = 5 mrem / min. = 10 mrem /2 min.

5.

Samples should be in test tubes and positioned in the holes surrounding the source. They should be left there for approximately 20 minutes.

6.

When entering and leaving the roem containing the source be sure the door closes completely each tirne.

7.

Any 55 gallon barrels (yellow) teored in the voor. contain tritium waste storage and i.re marked as such.

8.

Prior to woriing in the room contatriing the arce persons should have. read the NRC-3 Notice to Employees pasted on the door.

I have read the above instructions and will ahids by them at all times.

l Signature Date

/

/

l l

This fann will be placed in the Departurnt of Chemistry files. A copy of the i

Instructions should also be retained by the persen signing the fonn.

l 1

l

ATTN CHnWMT 3

To:

faculty & 5:aff

.ruary 20 iHI Acting Capartment He d[,$ ) Q, c/td[

0. Bertrsad i:cmay f

f From:

ad

Subject:

Rad 1 Lic: Safety and U.te.).f the Catt.iOF.1330WC5 !ar Il9/III laboratories As sor a of you know, we hed an inspectica last wack by ther Uni'.ed States fluclear Regulatcry Cc;x tssica based on an anonymu ca.we.ir.+..

Fcrtunately, no sericus violations of our safety regulations wm: fou.11 We w'il, however, be Mvising scc:e of our pro:edures fo;- the hanoibg or adioactive matertals and the training of persons authorized to handle rad 1oactive substances-After consulting with Rangan, it would ceera advisabic not to 'sc the Calafornium aurce for s

the duration of the semester for usa ir. the 131/119 ladw atory experiments in-volving the radioactivity experiments.

It it is.isanttei fe: you to t.se the

.ource, h6 wever, please see tre or Brer:dm ihnning for the proper prucedures that will b2 reoutred.

Our complete respon:c to the fiRC iapection 's'il'.

3 mit the receipt of tecir official report.

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