ML20009G643
| ML20009G643 | |
| Person / Time | |
|---|---|
| Issue date: | 07/14/1981 |
| From: | Grayson W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20009G631 | List: |
| References | |
| NUDOCS 8108040506 | |
| Download: ML20009G643 (3) | |
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APPENDIX A NOTICE OF VIOLATION 4
Department of the Navy License flo. 53-10226-01 l
Naval Submarine Base l
Repair Department 705 Pearl liarbor, Hawaii - 96860 As a result of the inspection conducted on May 5,1981, and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7,1980), the i
following violations were identified:
A.
10 CFR 34.11(d) states that each applicant will have an internal inspection system adequate to assure that Commission Regulations.
Comission license provisions, and the applicant's operating and emergency procedures are followed by radiographers and radiographers assistants; the inspection system shall include the performance of x '
internal inspections at intervals not to exceed three months and y
s the retention of records'of such inspections for two years.
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Cont:ary to the above requirement, no records of internal inspections:
were available between the last inspection on July 10-11,'1980 and \\
N December 30-31, 1980. This restitive item of noncompliance was also identified in the inspection conducted on July 10-11, 1980.
N Licensee correspondence dated Octgber 31, 1980 indicated that an
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internal audit was conducted in August of 1980, but no record of
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this audit was available at the time el the May 5,1980 inspection.
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This is a Severity Level VI Violatio\\n upplement VII).
i B.
10 CFR 34.33(b) states that pocket dosimeters shall be read'and recorded daily.
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i Contrary to the above requirement, daily pocket dosimeter readings -
s were not maintained for a radiographer who performed radiography on 1/13/81,1/15/81,1/16/81, and 1/23/81. This ' repetitive item of:
l noncompliance was also identified during the July 10-11, 1980 p
inspection.
l This is a Severity Level V Violation (Supplement II).
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C.
10 CFR 34.24 states that each radiation survey instrument shall be N
N calibrated at intervals not to exceed three months.
N' f
Contrary to the above requio,mnb radiation survey instruments
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serial numbers E0994 and
- M e.re calibrated on November 26, 1980 f
yet were utilized whih rej < tre overdue for calibration on March 3, March 4, March 11, ar< m
& 1981.
This is a Severity Leval V V1olatim (Supplement VII).
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Appendix A D.
10 CFR 34.29(c) requires that alam systems in permanent radiographic installations be tested at intervals not to exceed 3 months.
Contrary to the above requirement, the alarm system was not tested between October 9,1980 and April 1,1981 yet radiography was performed on February 3, February 9 Feraury 13, and March 3, l
- 1931, 1
This is a Severity Level IV Violation (Supplement VII).
i E.
License Condition No. 16 (Amendment No. 13) incorporates revised l
Operating and Emergency Procedures, as described in SUBASE INST 9900.2B dated April 7, 1980 which was submitted as a supplement to the i
license application. Chapter 2 item 2(c) of this procedure states that the outer surface of the vault in Building 1341 should be treated as an un estricted area, and that external radiation levels i
be checked by physical radiation survey bi-annually using an uncollimated 100 C1, Iridium-192 source.
l l i Contrary to the above requirement, no bi-annual surveys were perfomed j
between March 31, 1980 and May 5, 1981.
This is a Severity Level V Violation (Supplement VII).
l F.
10 CFR 19.11(a) requires each licensee to pust current copies of l
10 CFR Parts 19 and 20, the license and documents incorporated into i
the license by reference and amendments thereto, operating proce e W3 applicable to licensed activities, and any notices of violation.
iI l t Contrary to the above requirement, 10 CFR Parts 19 and 20 and documents incorporated into the license by reference were neither posted outside the pemanent radiographic facility nor was the alternate posting authorized by 19.11(b) present.
l This is a Severity Level VI Violation (Supplement VII).
.l Pursuant to the provisions of 10 CFR 2.201, the Naval Submarine Base l
Pearl Harbor, Hawaii, is hereby required to submit to this office within l
thirty days of the date of this notice, a written statenent or explanation l
in reply, including:
(1) the corrective steps which have been taken and l
the results achieved; (2) corrective steps which will be taken to avoid l
further items of noncompliance; and (3) the date when full compliance l
will be achieved. Consideration may be given to extending your response j
time for good cause shown.
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Appendix A The responses directed by this flotice are not subject to the Office of Management and Budget as required by the Paperwork Reduction Act of.
f 1989. PL 96-511.
Ofi.S o^l signeci oq i
JUL 141981 LDm. mafL 6aulson j
i dated
- Wm. Mark Grayson Radiation Specialist l
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