ML20029A072
| ML20029A072 | |
| Person / Time | |
|---|---|
| Site: | 07001167 |
| Issue date: | 01/28/1991 |
| From: | Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Struckle J NORTHWESTERN OKLAHOMA STATE UNIV., ALVA, OK |
| References | |
| NUDOCS 9102040014 | |
| Download: ML20029A072 (2) | |
Text
{{#Wiki_filter:- -__ _ _.. _.- e JAN 2 81991 In Reply Refer To: License: $NM-1101 Docket: 070-01167/90-01 Northwestern Oklahoma State University ATTN: Dr. Joe J. Struckle, President Alva, Oklahoma 73717 Gentlemen: Thank you for your letter of January 8,1991, in response to our letter and attached Notice of Violation both dated December 24, 1990. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. Your response indicated that you intend to transfer the neutron source, and we presume that your intent is to afterward request termination of your NRC license. Af ter transfer of the source, you should submit to us a completed NRC Form 314 (enclosed) in order to accomplish the termination request. If you have not divested yourself of licensed material within 90 days of the date of this letter, then you must provide a written response to each of the violations in the Notice of Violation previously sent to you. You are also reminded of the requirement to leak test the source within 6 months prior to its transfer. Any questions in regard to these matters should be directed to Mr. C. L. Cain of my staff at (817) 860-8186. Sincerely, Orir,inal Smned Dy: LAWRENCE A. h~lLL M A. Bill Beach, Director Division of Radiation Safety and Safeguards
Enclosure:
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Mr. A. Bill Beach, Director 3 Division of Radiation Safety and Safeguards U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 Ret License SNM-1101 and Docket 070-01167/90-01
Dear Mr. Beach:
I am in receipt of your letter dated December 24, 1990, con-corning a routine inspection by Mr. Richard A. Leonardi, Jr., from your office on November 28, 1990. Correspondence is in reference to License SNM-1101 and Docket 070-01167/90-01. The referenced plutonium-beryllium (Pu-B6) neutron source for academic instruction has been cited for minor violations of said license. Mr. Darrell Wiersig has informed me that he has been in contact with Ms. Billie Grusznski of Dallas, Texas, on this date, January 8, 1991, concerning the disposal of said neutron source. We are doing everything in our power to eliminate the neutron source and are currently working with the Department of Energy for such disposal. We hope to have the neutron source completely off campus in the next 60-90 days. Proper precautions have been taken so that no one will be allowed to handle the neutron source except Darrell Wiersig and his staff. If further information is needed, please do not hesitate to call upon me. Sincerely,
- [% M Joe J. Struckle President JJSilpt y_,.47 "TC l
TG ~91-0/0
DEC 2 41990 In Reply Refer To: License: SNM-1101 Docket: 070-01167/90-01 Northwestern Oklahoma State University ATTN: Dr. Joe J. Struckle President Alva, Oklahoma - 73717 Gentlemen: This refers to the routine, unannounced radiation safety inspection conducted by Mr. Richard A. Leonardi, Jr., of this office on November 28, 1990, of the activities authorized by NRC Byproduct Material License No. SNM-1101, and to L the discussion of our findings held by the inspector with members of your staff at the conclusion of the inspection. The inspection was an examination of the activities conducted under the license as they relate to radiation safety and to compliance with the Commission's rules and regulations'and the conditions of the license. The inspection consisted of selective examinations of procedures and representative records, interviews' of personnel, independent measurements, and observations by the inspector. The inspector determined that the licensee has possessed a 5 curie plutonium-beryllium (Pu-Be) neutron source contained in a howitzer since April 1970 for the purposes of academic instruction and for conducticg occasional activation studies. The inspector noted that the storage area for the howitzer was adequate and the door leading to the storage area was locked and properly posted. Although the use of the howitzer is limited to a single use each year, the NRC is concerned about the continued safety of the nectron source as evidenced by.the nature of the violations identified. The inspector further noted that during a conversation with a licensee representative, the' licensee is considering the transfer or disposal of the neutron source. The licensee should consider amending its license to authorize the po. session of the neutron source for storage only until a decision is made regarding the final disposition of-the neutron source. During this inspection, certain of your activities were found not to be conducted in full compliance with NRC requirements. Consequently, you are required to respond to this matter in writing, in accordance with the provisions of Section 2.201 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations. Your response should be based on the specifics contained in the Notice of Violation enclosed with this letter. O RLeonardi:Im[ RIV:NMSISAtT C:NMSI
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Northwestern Oklahoma State University In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter, the enclosure, and your response to this letter will be placed in the NRC Public Document Room. The response directed by this letter and the accompanying Notice is not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96 111. Should you have any questions concerning this letter, we will be pleased to discuss them with you. Sincerely, Unginal S#A U' pt, B. BEACH A. Bill Beach, Director Division of Radiation Safety and Safeguards
Enclosure:
Appendix - Notice of Violation ec: Oklahoma Radiation Control Program Director bec: DMB - Original (IE-07) RDMartin ABBeach LAYandell MRodriguez, OC/LFDCB (4503)
- WLFisher "CLCain
- RAleonardi
- NMSIS
- MIS System
- RIV Files (2)
- RSTS Operator
- REHall, URF0
- W/766
] 5 j APPENDIX NOTICE OF VIOLATION i i Northwestern Oklahoma State University Docket No. 070-01167/90 01 License No. SNM 1101 Alva, Oklahoma 1 During an NRC inspection conducted on November 28, 1990, violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1990), the violations are listed below: 1.- License Condition 13.A requires, in part, that sealed sources shall be 4 tested for contamination and/or leakage at intervals not _to exceed i 6 months, except those sources that are stored and not being used. Contrary to the above, tests for contamination and/or leakage of the neutron source (Serial No. 800P33) had not been performed between April 1987 and December 1990; an interval exceeding six months. The neutron source had been used during this period. This is a Severity Level IV violation. (Supplement VI) 2. 10 CFR 20.401(c)(1) requires, in part, that records of individual exposure to radiation made pursuant to 10 CFR 20.401(a shall be preserved until the Commission authorizes disposition. Contrary to the above, personnel monitoring records were not maintained for the period between April 1970 and January 1979. i This is a Severity Level IV violation. (Supplement VI) License Condition 15 requires, in part, that licensed material be 3. possessed and used in accordance with statements, representations, and procedures contained in an application dated April 24, 1989, and letters dated May 18, 1984, March 29, 1990, and June 15, 1990. Item 1 of-letter dated May 18, 1984, states that each time the howitzer is to be used, the howitzer and adjacent area will be surveyed for-gamma activity using a calibrated survey meter available from the State of Civil j Defense Office. l Contrary to the above, surveys of the howitzer and the adjacent' area were not performed even though the howitzer and the neutron sealed source were used on at least one occasion in 1988, 1989,_and 1990. This is a Severity Level IV. (Supplement VI) Pursuant to the provisions of 10 CFR 2.201, Northwestern Oklahoma State University, is hereby required to submit to this office, within 30 days of the H t t r $ 7t f
J l l. 4 date of the letter transmitting this Notice, a written statement or explanation in reply, including for each violation: (1) the reason for the violation if admitted, (2) the corrective steps which have been taken and the results achieved, (3) the corrective steps which will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Where good cause is shown, consider 9 tion will be given to extending the response time. Dated at Arlington, Texas, this 24th day of December 1990 I
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