ML20029D194

Forwards Safety Insp Rept 70-0008/94-01 on 940131-0325 & Notice of Violation.Licensee Radiation Protection Program Found to Be Adequate to Protect Radiological Safety of Employees & Public

ML20029D194
Person / Time
Site:	07000008
Issue date:	04/26/1994
From:	Axelson W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Brog K Battelle Memorial Institute, COLUMBUS LABORATORIES
Shared Package
ML20029D195	List: ML20029D194 ML20029D197 ML20029D198
References
NUDOCS 9405040161
Download: ML20029D194 (3)

Text

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Battelle Memorial Institute License No. SNM-7 Columbus Operations Docket No. 070-00008 l

ATTN: Kenneth C. Brog, Ph.D.

Vice President Environmental Safety and Health 505 King Avenue Columbus, OH 43201-2693

SUBJECT:

SPECIAL INSPECTION OF LICENSED ACTIVITIES (REPORT N0. 070-00008/94001(DRSS))

This refers to the special safety team inspection conducted from January 31 through March 25, 1994, led by Michael Kurth of the NRC Region III staff. At the conclusion of the on-site inspection on February 3,1994, the preliminary findings were discussed with you and those members of your staff identified in the enclosed report. This also refers to the March 11, 1994, management meeting, held at the Region III office, which included a discussion of the inspection results and the restructuring of your NRC license.

The enclosed copy of the inspection report identifies areas examined during the inspection. Within these areas the inspection consisted of a selective i

examination of procedures and representative records, observations, independent measurements, and interviews with personnel. The inspection also included the review of internal audits /self assessments, with particular emphasis placed on a July 1992 self assessment of the byproduct'research and development program.

The Battelle Columbus Division's radiation protection program was found to be adequate to protect the radiological safety of employees and the public.

However, during the inspection, certain of your activities were found to be in violation of NRC requirements, as specified in Enclosure 1.

A written i

response is required as directed in the enclosed Notice of Violation.

In addition to the item identified in the Notice of Violation, four violations were identified and corrected by your staff as a result of the July 1992 self assessment.

The violations include: the failure to inform the NRC of a l

change of Radiation Safety Officer; the failure to provide training to personnel; the failure to calibrate a survey instrument at the proper 1

frequency; and the failure to utilize the proper radiation postings.

The NRC encourages and supports licensees who perform self assessments of their program. Also, the NRC supports and encourages the self identification and correction of problems. Since the four violations were self-identified, would normally have been classified as Severity Level IV or V violations, were not violations that could reasonably be expected to have been prevented by l

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M 2 019N your corrective actions for a previous violation or previous Battelle finding within the past two years, were corrected in a reasonable time, and were not willful violations, the NRC will exercise discretion and consider these to be non-cited violations in accordance with 10 CFR Part 2, Appendix C, VII(B)(2).

No response is required regarding the non-cited violations.

j Also, the inspection identified that documentation regarding the disposition of nine low activity calibration / check sources could not be located.

Based upon information developed by Battelle via interviews of past and current employees and Battelle's extensive review of past and present inventory and disposal records, it is our understanding that you are confident that the sources were properly disposed of as radioactive waste, transferred to an authorized recipient or stored in sealed hot cells that are awaiting decommissioning.

Based on prior inspections of Battelle, if these sources were disposed as radioactive waste, the NRC is confident that the disposal complied with NRC license and regulatory requirements. The NRC will continue to monitor this issue during future inspections and consider this an inspection follow-up item (IFI No. 070-00008/94001-01).

Please confirm in your response to this letter, that Battelle will notify this office of any additional information identified regarJing the final disposition of these sources.

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, the enclosures, and your response to this letter will be placed in the NRC Public Document Room.

The response directed by this letter is not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.

We will gledly discuss any questions you have concerning this inspection.

Sincerely, Original Signed by Cary L. Shear for W. L. Axelson, Director Division of Radiad on Safety and Safeguards

Enclosures:

1.

Notice of Violation 2.

Inspection Report No. 070-00008/94001(DRSS) 0, )

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vii; Distribution cc w/ enclosures:

-R. Owens, Ohio Department of Health T. Baillieul, U.S. Department j

of Energy bec w/ enclosures:

D. Funk, RIII PUBLIC (IE 07)

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