ML20029B478
| ML20029B478 | |
| Person / Time | |
|---|---|
| Issue date: | 02/26/1991 |
| From: | Kinneman J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Ganter R ROHM & HAAS CO. |
| References | |
| REF-QA-99990001-910226 NUDOCS 9103080054 | |
| Download: ML20029B478 (2) | |
Text
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fEB 2 61931 General Licenset Rohm and Haas Delaware Valley, Inc.
ATTN: Robert Ganter Route 13 and 413 Bristol, Pennsylvania 19007 Gentlemen:
Subject:
Inspection No. 9999001/91-001 On January 17, 1991 Christopher J. Eckert of this of fice conducted a routine safety inspection at your facility of the activities authorized by the general license contained in 10 CFR 31.5. Mr. Eckert reviewed the results of the inspection with you at the conclusion of the inspection.
During the inspection a discussion was held between yourself and Mr. Eckert concerning your:
(1) authorization to remove generally licensed gauges from service and (2) commitment to maintain security of licensed material. As Mr. Eckert explained, in accordance with 10 CFR 31.5(c)(3), removal from installation of generally licensed gauges may only be performed by a person holding a specific license issued pursuant to 10 CFR 30 and 32 to perform this service. Therefore, if the removal of a gauge is necessary to perform maintenance on adjacent equipment you must contact either the gauge manufacturer or other licensed individuals to remove from installation any generally licensed gauge.
We are concerned that your administrative controls may not be adequate to ensure that licensed material is properly secured at all times as required by 10 CFR 20,207(a) and that gauge maintenance is performed by authorized individuals.
You should review your administrative controls for the security of licensed material and maintenance to ensure their adequacy and provide additional employee training on these controls if necessary.
During the inspection the inspector observed a generally licensed Ronan Level gauge which had been removed from service and placed on the floor in the PM-2 area. The gauge had been separated into two pieces (source housing and detector) thereby producing a radiation level of approximately 0.8 - 1.5 millirem per hour immediately in front of the source housing.
This radiation did not present an immediate hazard; however, this action is not compatible with keeping radiation exposures as low as reasonably achievable (ALARA).
You should assure that gauges not in service are stored in such a way that radiation exposures are minimized.
.The removal from installation and security of generally licensed gauges will i3 be reviewed during subsequent inspections of your activities.
W) 9103080054 910226 IE GA999 ENVROHN 9999001 PDR ti 0FFICIAL RECORD COPY LTR ROHM - 0001.0.0 C
02/26/91 Return Original to Region !
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l Rohm and Haas Delaware Valley, Inc.
2 No response to this letter is required. Your cooperation in this matter is appreciated.
Sincerely, Original Signed Dv:
John D. Kinnornan John D. Kinneman, Chief Nuclear Materials Safety Section B Division of Radiation Safety and Safeguards CC:
Public Document Room (PDR)
Nuclear Safety Information Center (NSIC)
Commonwealth of Pennsylvania bec:
Region I Docket Room (w/ concurrences)
Management Assistant, DRMA RI: SSS k
EcLe t7bj VJinneman
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02/h/91 02/ V 91 0FFICIAL RECORD COPY LTR ROHM - 0002.0.0 02/26/91 i
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