ML20029D481
| ML20029D481 | |
| Person / Time | |
|---|---|
| Site: | 07003074 |
| Issue date: | 04/29/1994 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20029D479 | List: |
| References | |
| 70-3074-94-01, 70-3074-94-1, NUDOCS 9405060015 | |
| Download: ML20029D481 (3) | |
Text
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APPENDIX A NOTICE OF VIOLATION Columbia University Docket No.
070-03074 New York, New York License No.
SNM-1995 During an NRC inspection conducted between March 9 and April 12, 1994, five 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, the violations are listed below:
A.
10 CFR 70.3 requires that no person (which includes public and private institutions) possess special nuclear material except as authorized in a license issued by the Commission pursuant to 10 CFR 70. License No. SNM-1995 authorizes the possession of Isotope Chemical and/or Possession Limit j
physical form Uranium enriched in the Plated electrodes in two 2.37 g i
U-235 isotope to less than fission counters 99.99% U-235 Uranium enriched in the Foils 286 g U-235 isotope to less than 99.99% U-235 Pu-239 Scaled neutron sources 80 g/ source,363 g total Pu-239 Plated detector sources 0.81 g Contrary to the above, as of April 12, 1994, the licensee possessed special nuclear material that was not authorized in a license issued by the Commission pursuant to 10 CFR 70. Specifically, as of April 12, 1994, the licensee possessed approximately 100 grams of uranium-235 greater than the licensed limit, and 3 grams of uranium-233 which wem not authorized by a license issued by the Commission pursuant to 10 CFR 70.
This is a Severity LevelIV violation. (Supplement VI)
B.
10 CFR 70.51 (b)(1) requires that each licensee shall keep records showing the receipt of all special nuclear material in its possession, regardless of its origin or method of acquisition.
Contmry to the above, as of April 12,1994, the licensee did not keep records showing the receipt of all special nuclear material in its possession regardless of its origin or method of acquisition. Specifically, the licensee did not keep or could not locate records ONojoojg74 PDR
l Appendix A !
(
of the receipt of plutonium-239 sealed neutron sources, 3 grams of U-233 contained in a l
glass vial,462.604 grams of uranium enriched in U-235 in the form of powder and foils, 2.37 grams of U-235 in four fission detectors and 1.43 grams c,f uranium enriched in U-235 "In Envelope "
l This is a Severity Level IV violation (Supplement VI).
C. Condition No.16 of License No. SNM-199$ requires that licensed material be possessed and used in accordance with the statements, representations, and procedures contained in an application dated November 6,1991.
1.
Item 10 of the Appendix, Section D, of the application, " Health Physics Office",
requires, in part, that radiation surveys be conducted on a monthly basis in areas where special nuclear materials are used or stored.
Contrary to the above, as of April 12, 1994, monthly radiation surveys were not conducted in Mudd Rooms 069A and 173 and Pupin Room 606B (Morningside Campus), Altschul Room 608 (Barnard College), and Nevis Laboratory, areas where special nuclear materials are used or stored.
l l
l 2.
Item 8 of the Appendix, Section A, of the application, requires, in part, that the l
Radiation Safety Committee (RSC) use criteria for approving the use of radioactive material which includes confirming that the responsible investigators meet the l
training requirement to have at least 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of training and experience in the safe handling of radioactive materials, and in the characteristics of ionizing radiation, units of radiation dose and quantities, radiation detection instrumentation, and biological hazards of exposure to the types and forms of byproduct material to be used.
Contrary to the above, as of April 12, 1994, the Radiation Safety Committee did not confirm that responsible investigators met the training requirement to have at least 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of training and experience in the safe handling of radioactive materials, and in l
the characteristics of ionizing radiation, units of radiation dose and quantities, radiation detection instrumentation, and biological hazards of exposure to the types and forms of byproduct material to be used. Specifically, at least two individuals were approved as authorized users without confirmation by the RSC ' hat they had l
obtained the required 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of training and experience.
3.
Item 8 of the Appendix, Section C, of the application, requires, in part, that after initial training, each responsible investigator and radiation worker will be required to attend a continuing education course in radiation safety or radiation safety refresher course annually.
Appendix A - Contrary to the above, as of April 12,1994,~several radiation workers working with the plutonium sealed neutron sources in the Pupin Building and Mudd Building had not been provided a continuing education course in radiation safety or a radiation safety refresher course annually.
These are Severity Level IV violations (Supplement VI).
Pursuant to the provisions of 10 CFR 2.201, Columbia University is hereby required to submit a written statement or explanation to the U.S.' Nuclear Regulatory Commission,
. ATTN: Document Control Desk, Washington, D.C. 20555, with a copy to the Regional Administrator, Region I, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of-Violation" and should include for each violation: (1) the reason for the violation, or,-if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations,-
and (4) the date when full compliance will be achieved. If an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be is. sued to show cause why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.
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