ML20012F386
| ML20012F386 | |
| Person / Time | |
|---|---|
| Site: | 03020969 |
| Issue date: | 11/21/1989 |
| From: | Riedlinger B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Heiken D ULTRA TECHNOLOGY, INC. |
| Shared Package | |
| ML20012F382 | List: |
| References | |
| 70947, NUDOCS 9004120134 | |
| Download: ML20012F386 (4) | |
See also: IR 05000233/1963001
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Docket No. :
030-20969
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License No.:
50-23363-01
Control No.:
70M7
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Ultra Technology Inc.
Calgary,ghton Drive N. W.
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3836 Bri
Alberta, Canada T2t IG8
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Attention:
Donald S. Heiken
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Radiation Safety Officer
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Gentlemen:
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This is in reference to your request dated March 20, 1989 for renewal of your
byproduct material license.
In order to complete our review, we need the
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following additional information:
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Item 9 of our
lication specifies that a permanent stora
facility is
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maintained at Pbhoe Bay but no specific addmss was provi$d.
flease
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is located as stated in License Condition 10
confirm that this facility' ARCO MCC contractors camp'approximately 4 mile
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of your current license (
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north of the Deadhorse Airport"), or else provide a description,
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supplemented by a map or drawing, of the specific location of your
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facility.
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r 2.
We are unable to authorize your use of the Bieron Micro Analyst survey
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meter for conducting radiation surveys associated with licensed
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activities.
Although you indicated in Attachment 8.1 of the Radiation
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Safety Manual that the 81cron instrument has a range of Q-1000 mR/hr, the
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specification sheet also submitted with your application indicates a
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maximum range of 0-5000 micro R/hr.
This does not satisfy 10 CFR 34.24
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which requires the use of survey meters with a measurement range of two
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mil 11 roentgen per hour through one roentgen per hour.
Your application
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should be revised to specify that the Bicron instrument will not be used
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for radiation level measurements of the type required for compliance with
3.
On page 5, Chapter 5 of the Radiation Safety Manual you made reference
tosamplecopiesofthe"UtilizationLoo"anda"DallyDosimeterRecord".
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However, You should provide sample copies of the above records as a pa
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review.
of your revised application.
4.
Withregardtoyourradiationsafetytrainingprogram(asdescribedin
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Attachment E of your Radiation Safety Manual):
hC C1
50-23363-01
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In paragraph C. c), you state that your training program for
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Officer.phers will be conducted by either the Radiat'on Safety
radiogra
.. or a person designated by the Radiation Safety Officer
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who is cualified by experience...and training acceptable to the
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NRC." Page 10 of the enclosed licensing <puise states that,
" Individuals who provide instruction in tse use of equipment should
be qualified radiogr hers with at least ) year of emperience in
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perfoming radiograp
The name of each individual who will
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conduct training and he topics in which they will provide
instruction should be specified." Youshouldsubmitthename(s)and
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qualificationsoftheindividual(s)whowillinstructradiography
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personnel for NRC review and approval.
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In paragraph C. d
you indicate that the training programs for
pros>ective radiog)r,aphers,be substituted for traini
b.
offered by F.L. Clifford and by
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Hutciinson Institute any
provided by Ultra in,its Operating and Emer1pency Procedures.
In
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paragraph C. e), you also indicate that instruction in Ultra's
Operating and Emergency Procedures for previously experienced
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radiographers may be " waived" on the basis of satisfactor
documentation from the radiographer's previous esployer. y
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RadiographycoursesapprovedbytheNRCwillstillneed5pbe
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supplemented by company - specific training for both new and
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previously experienced radiographers who have been qualified under a
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different licensed program.
Your training should include formal
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instruction similar to that given to prospective radiography
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assistants, i.e. at least four hours of instruction in the operating
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and emergency procedures specific to your radiography protras.
This
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training is in addition to that which you agreed to provice in the
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use of radiographic equipment as outlined on pape 3 of Attachment E.
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You should revise your application to specify ttis additional
training.
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c.
Your application does not clearly indicate that radiographer
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trainees and previously experienced radiographers wil
be required
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to pass a field examination prior to qualification as a radiographer
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under your program.
You should revise Attachment E ->aragraphs C.
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a) and e) to include this commitment and to specify tse passing
grade that will be required.
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d.
There appears to be en error in the certification form, " Evaluation
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AttachmenthhersandRadiofraphersAssistants",Certificatlon
of Radiogra
on page 7
of your Radia ion Safety Nanual.
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approvalisspecifiedfora"QualifiedOperator";webelievethis
should state Assistant Radiographer."
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Refer to Item 8 of the enclosed guide.
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5.
In Attachment I paragraphs I.3. and K.3. of your Radiation Safety
Manual you stah that the activity of filter paper should not exceed
0.001 di of removable contamination using a filter paper wiped over a
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package surface area of 16 square inches (103 squam centimeters).
This
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activity calculates to be 10 microcurie per square centimeter. However,
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U. S. Department of Transportation regulations (49 CFR 173.443) limits
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renovable contamination to 0.00001 microcurie per sq'uare centimeter.
You
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should revise and resubmit this portion of your app ication.
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5.
Your application should contain a commitment that audits of each
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radiographer and assistant radiographer will be performed under the
following conditions:
a.
At intervals not to exceed three sonths during actual radiographic
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operations.
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b.
When an individual has not performed radiopraphy for more than three
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oonths, the individual will be inspected tw first time that person
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engages in radiographic operations,
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c.
Recerds of the audits will be retained for at least three years,
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You should include the above commitments in your application.
Refer to
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10 CFR 34.11(d), enclosed.
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7.
Your Radiation Safety Manual does not contain any instructions to
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radiography personnel for actions they must take if a pocket dosimeter is
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found to be off scale.
Your emergency procedures should instruct
position in the exposure device, y and place the source in the safeand to no{
personnel to stop work immediatel
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Officer or Supervising Radiographer immediately. Your application should
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also state that the film badge will be immediately sent for processing if
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the pocket dosimeter is found to be off-scale.
Refer to Ites 10.4.11 of
the enclosed guide.
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8.
Your Radiation Safety Manual should contain instructions to radioq1raphy
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personnel to notify management of any malfunctions or defects tha'; are
foundinradiographyequipment.
Refer to Iten 10.4.12 of the enclosed
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guide.
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We will continue the review of your renewal request upon receipt of this
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information.
In order to continue prompt review of your application, we
request that you submit your response to this letter within 30 calendar days
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from the date of this letter.
Please reply in duplicate, and refer to Mail
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Control No. 70947,
Sincerely,
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Beth A. Riedlinged
Health Physicis'; (Licensing) ion
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Nuclear Materials Safety Sect
Enclosures:
Regulatory Guide 10.6
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Distribution
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.bec: License docket folder (original concurrence)(Peggy)
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Inspection folder (Peggy)
Maurice Messie(Frances) MNBB 4503
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