ML20029D486
| ML20029D486 | |
| Person / Time | |
|---|---|
| Site: | 07003074 |
| Issue date: | 04/28/1994 |
| From: | Nessen P, Reber E, Shanbaky M, Galen Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20029D479 | List: |
| References | |
| 70-3074-94-01, 70-3074-94-1, NUDOCS 9405060018 | |
| Download: ML20029D486 (18) | |
Text
_.
t U.S. NUCLEAR REGULATORY COMMISSION REGION I l
Report No.
070-03074/94-001 Docket No.
070-03074-License No.
SNM-1995 l
Licensee:
Columbia University 289 Eneineerine Terrace 500 West 120th' Street New York. New York 10027 Facility Name: Columbia University Inspection At:
Columbia University -
+
Inspection Conducted: March 9-Aoril 12.1994 '
Inspectors:
29 Eric H. Reber, Health Physicist
' 'date '
n, A,.
A P nny Nessen, Hedh ' Physic /ft' date I L
m b.A.a -C b A f( fY e
'Grego% Smith, 'Sr. Security Specialist I date #
M 2/3 k M. Sha'3.aky, Chief [
Approved by:
ytMoh date l
Re e and Development Section Areas Insoected: Inventory and records of special nuclear material; transfer of special 1
nuclear material; area radiation surveys; security of special nuclear material; posting of Form -
NRC-3 and radioactive materials caution signs; radiation safety commiuee; verification of
-i qualifications of individuals involved with the radiation safety program; verification of the presence of a radiation safety officer since 1991; human use experiments; radiation safety-manual.
I 9405060018 940429 PDR ADOCK 07003074 i
r-C PDR I
2 Results: Five violations were identified: possessing special nuclear material not authorized by a specific license (details, Section 3); failum to maintain receipt records (details,.
Section 3); failure to perfonn monthly surveys (details, Section 5); failure to evaluate training of authorized users (details, Section 8); failure to retrain employees annually (details, Section 8).
5 1
l l
f-E h
i i
t
'l
l I
l DETAILS i
i 1.
Persons Contacted
+* ~ Paul D. Carter, Senior Advisor to the President
+~
David Brenner, Ph.D., Chairman, Radiation Safety Committee (RSC) l
+*~ Herbeit Michael, Assistant Director of Environmental Health and Safety and Radiation Safety Officer (RSO)
+*
Imretta Greenholtz, Director of Environmental Health and Safety Richard Kulikowsky, Ph.D., Director, New York City Bureau of Radiological Health Gene Miskin, New York City Bureau of Radiological Health Richard Borri, New York City Bureau of Radiological Health James Florakis, Laboratory Supervisor Alex Voxakis, Health Physics Supervisor Bob O'Hagan, Physics Department Sally Chapman, Ph.D., Chemistry Department Faculty Steve Marino, Nevis Cyclotron Laboratory l
Alan Zindler, Ph.D., Lamont-Doherty Earth Observatory
- indicates those present during exit interview conducted March 9,1994
+ indicates those present during exit interview conducted March 30,1994
- indicates those present during exit interview conducted April 12,1994
===2.
Background===
Columbia University is a large university with its principal campus (Morningside) in New York City, New York. The university has a broad scope license (License No.162-1) issued by the City of New York's Bureau of Radiological Health that authorizes the possession of byproduct material and source material for use in research and development. NRC License No. SNM-1995 authorizes the possession of special nuclear material (i.e., uranium enriched in uranium-235 and plutonium) at Morningside Campus, Barnard College and Nevis Cyclotron Laboratory.
A research reactor was constmeted at the Morningside Campus. - However, no reactor fuel was ever receive.d at the facility and the reactor was never operated.
1 1
1
l 4
l l
I 3.
Inventory and Records of Special Nuclear Material License No. SNM-1995 authorizes possession of the following:
Isotope Chemical and/or Possession Limit physical form i
Uranium enriched in the Plated electrodes in two 2.37 g i
_ U-235 isotope to less than -
fission counters 99.99% U-235 l
Uranium enriched in the Foils 286 g,
U-235 isotope to less than 99.99% U-235 Pu-239 Sealed neutmn sources' 80 g/soun:e,363 g total Pu-239 -
Plated detector sources 0.81 g License No. SNM-1995 authorizes the sealed neutron sources to be used in teaching and training students. The other special nuclear material (SNM) is authorized for storage only.
Upon request, the licensee pmduced a written inventory of special nuclear material on hand dated December 17, 1993. The licensee's inventory indicated that they possess-1 Uranium Isotope Form Total Uranium Isotope [g]
(all isotopes) [g]
U-235 Powder / foils 462.604
. 385.975 (U-235)
U-235 4 Fission Detectors Unknown -
2.37 (U-235)
U-235 "In Envelope" 1.43 1.357 (U-235)
Total Uranium /U-235 464.034 389.702 (U-235)_
U-233 Glass Vial-
.not listed 3 (U-233) i-
5-Plutonium Isotope Fonn Total Plutonium Pu-239 [g]
(all isotopes) [g]-
Pu-239 Sealed Source 16.0 not listed Pu-239 Sealed Source 32.0 not listed -
Pu-239 Sealed Source 80.0
. not listed i
Pu-239 Sealed Source 9.84 not listed Pu-239
. Sealed Souwe 2.0 not listed Pu-239 Sealed Source 16.0-
' not listed Pu-239 Sealed Source 16.0 not listed Pu-239 Sealed Source 16.0
- not listed Pu-239 Sealed Source 16.0.
not listed Pu-239 Sealed Source 16.0 not listed t
Pu-239 Sealed Source 80.0 not listed Pu-239 Sealed Source 64.0 not listed Total 363.84-The written inventory record possessed seveml weaknesses and requimd explanation 3
by the licensee so that it could be understood. An example of a weakness in the inventory was an apparent double entry for the same discrete item. One entry 1
indicated the item form as uranium-235 powder (462.604 g element, 385.5 g U-235).
i The other entry for the same item indicated 286 grams of uranium-235 as foils.
Licensee representatives explained that the total for the item (462.604 grams) was for i
all the material (powder and foils) while the 286 grams was for the foils alone.
1 Another weakness was that the label on the item containing U-233 indicated that the j
item contained 4 g of U-233. However, the inventory listed this. item as containing 3 g of U-233. In addition, the licensee stated they had found a card stating the value of the U-233 was 3 g, but there was no other supporting documentation for that value.
The records reviewed by the inspector provided no msolution of this diffemnce.
The inspector physically verified the presence of each packaged item listed on the inventory. The packaging of the items did not always allow visual conGrmation of the form of the material.. Verification of the weight of each item was not performed due to the lack of safety / safeguards significance of the small quantities involved, due to the fragile condition of some of the items, and due to the lack of suitable equipment -
for conducting such measurements. However, verification that the packages contained
--,s--
. --...i
.,.,........._-,..,....L.
- -..,... ~
l 6
t-radioactive material was obtained by use of a detection instrument sensitive to 1
beta / gamma radiation.
The Laboratory Supervisor, a long-term. employee of the university, stated that he.
l.
knew of no locations at the campus where special nuclear material is stored other than j
the locations identified to the inspectors. The Health Physics Supervisor confirmed :
)
i the Laboratory Supervisor's statement.
i j.
The inspector identified in a drawer in Mudd Room 173, several packages containing.
i SNM. Two very small flat packages of translucent plastic labelled."U-233" were not j
listed on the inventory. However, the other SNM in the drawer was on the inventory; j.
The licensee estimated that one package contained 10 mg of U-233; the contents of the-i i
other was unknown. Based on the appearance of the material (foils) and past experience, the inspector estimated that the second package did not contain more than 1 gram of U-233.
i Licensee representatives stated that while plutonium-beryllium scaled sources are used routinely for teaching' purposes, all other material has been in storage for several years.
In an attempt to reconstruct the receipt and transfer of special nuclear material, the inspectors reviewed all post-1967 transactions recorded in the NRC/ DOE Nuclear Materials Management and Safeguards System (NMMSS).' The beginning t dances for each category of SNM in this system were based on inventories as of December 1, 1967. The NMMSS records showed the licensee with a zero balance for all SNM (enriched uranium, plutonium, and U-233) as of that date. All receipts and removals on NRC/ DOE Form-741 Material Transaction Reports were recorded and balanced to achieve a total book balance through the date of the most recent transaction. - That.
reconciliation is summarized in the enclosures to this report.
On July 1,1986, the licensee filed NRC/ DOE Form-741 with the NMMSS to report the discovery in inventory of 342 grams total uranium and 286 grams U-235..The licensee reportedly found this material while conducting an inventory of SNM in its possession. The origin of this material was not known. The records reviewed by the inspectors provided no further information regarding this material. It was, however, included in the inventory listed above in Section 3, and is shown in Enclosure 1 to this report.
A comparison of the NRC's reconciliation (Enclosures 1-3) and the licensee's
)
inventory showed the licensee to have approximately 130 grams more plutonium,100 grams more uranium-235 and 3 grams more U-233 on inventory than indicated by the -
NMMSS records. Since activities with special nuclear material at Columbia University began well before the NMMSS was instituted, the differences may be the result of material being at the facility prior to the initiation of the NMMSS and this material not being accounted for on the beginning inventories established in NMMSS..
Also, the discrepancies may result from inaccuracies in the values reported on NRC/ DOE Form-741, which record special nuclear material receipts and transfers.
s------
--,-,-..s me
...n-n e-m:-
,,, ~
,w,+
l l
l 7
l Since the NMMSS indicated a "zero" balance of special nuclear material in 1967, the l
licensee may have incorrectly reported a "zero" inventory to NMMSS. This appears to have been the case for enriched uranium, since, as described above, in 1986 the licensee found 342 grams of total uranium and 286 grams U-235 not on the inventory.
As noted above, the f.icensee's inventory records were difficult to understand. In fact, l
the inventory of special nuclear material developed by the licensee during the l
inspection was pieced together from different documents stored in different rooms.
This method of documentation may have contributed to the licensee exceeding its l
possession limit, in that it was difficult for the licensee representatives to determine from their records exactly how much special nuclear material was in their possession.
l Comparison of the physical inventory and the license revealed that, as of April 12, 1994, the licensee possessed special nuclear material that was not authorized in a license issued by the Commission. Specifically, as of April 12, 1994, the licensee's inventory documented possession of 389.7 g of uranium-235 when only 288.37 g were authorized. In addition, the licensee possessed 3 g of uranium-233, a material not authorized in the license. Licensee possession of about 100 g of U-235 greater than their licensed limit and of 3 g of U-233 not authorized by their license is an apparent violation of 10 CFR 70.3.
The inspector reviewed the licensee's records of receipts for special nuclear material.
Except for several of the twelve plutonium-239 sealed neutron sources currently on hand, receipt records for special nuclear material could not be located. Specifically, the licensee did not keep or could not locate records of the receipt of 3 grams of U-233 contained in a glass vial,462.604 grams of uranium enriched in the U-235 isotope in the form of powder and foils,2.37 grams of the U-235 isotope in four fission detectors and 1.43 grams of uranium enriched in the U-235 isotope in an envelope. Further, for the receipt records available, the licensee had no system in place that would tie a particular receipt record to a specific plutonium sealed neutron source.
The licensee's failure to maintain records showing the receipt of all special nuclear material is an apparent violation of 1C CFR 70.51 (b)(1), which requires that each licensee shall keep records showing th: receipt of all special nuclear material in its possession, tegardless ofits origin or nethod of acquisition.
Selected records of leak tests performed on plutonium sealed neutron sources in the twelve months prior to the inspection were reviewed in an effort to confirm the licensee's inventory of these sources. Records indicated that eleven of the twelve plutonium sources, including the source at Nevis Laboratory, were leak tested in the twelve months prior to the inspection (also see Section 6). One of the twelve sources was not leak tested because it was placed in its storage container upside down and was inaccessible. However, a leak test was not required since the source was in storage and not in use. The source was locked in its container and the container was stored properly in a locked room.
4 8
At the time of the inspection, the licensee was exploring ways of disposing of the stored uranium enriched in the U-235 isotope and of the U-233. The inspector reviewed the licensee's documentation of the effort to properly dispose of the store; materials. Several communications betwaa the licensee and the U.S. Department -
Energy (DOE) were reviewed. In one of these, a letter dated March 7,1994, DOE stated that they will accept certain of the items. The licensee also presented the inspectors with a license amendment request, dated March 8,1994, also mailed to NRC Region I, in which they requested possession limit changes that would bring them into compliance.
No additional safety concerns or items of noncompliance were identified.
4.
Transfer of Soecial Nuclear Material The RSO stated that no transfers of special nuclear material had been made since February 14,1991, when 0.035 g of U-233 was transferred to The NDL Organization, Inc. (NDL), a radioactive waste broker. The inspector reviewed the Radiowtive Manifest and Disposal Receipt which documented the fact that NDL took possession of radioactive waste including 0.33 millicuries (0.035 g) of U-233 in the form of cement on February 14, 1991. The RSO also stated that he had no knowledge of any other transfers oflicensed special nuclear material.
No safety concerns of items of noncompliance were identified.
5.
Area Radiation Surveys The inspector noted that area surveys were not performed on a monthly basis in all areas where special nuclear material was stored. That was identified as an apparent violation of Condition No.16 of License No. SNM-1995, which requires that licensed material be possessed and used in accordance with the statements, representations, and procedures contained in an application dated November 6,1%. Item 10 of the Appendix, Section D, page 17, " Health Physics Office", of this application, required that radiation surveys be conducted on a monthly basis. Contrary to this requirement, radiation surveys were not being conducted on a monthly basis in Mudd Rooms 069A and 173 and Pupin Room 606B (at the Morningside Campus), Altschul Room 608 (Barnard College), and Nevis Laboratory, areas where SNM was stored.
The RSO stated that area radiation surveys, including radiation level measurements and removable radioactive contamination measurements, were performed monthly in Mudd Room 284C because unsealed radioactive material licensed by the City of New j
York's Bureau of Radiological Health was stored in this room in addition to special nuclear material. Selected records of these surveys for the past year were reviewed.
These records indicated that monthly surveys were performed and that radiation levels and radioactive contamination were characterized. The RSO also stated that area surveys were performed approximately quarterly in rooms where special nuclear material sealed sources were stored. Selected records of surveys performed during the previous twelve months were reviewed. The RSO stated that surveys were
l 9
i l
l currently scheduled for several of the sealed source locations. Area survey records l
indicated that surveys were performed in sealed source storage locations approximately on a quarterly basis. The inspector stated that failure to perform the required surveys on monthly basis is an apparent violation of License Condition No.
16.
The Health Physics Supervisor (HPS) stated that, prior to the current RSO's arrival, area radiation surveys were not performed. He stated that area surveys were initiated when the current RSO assumed his position in January 1993. The HPS also stated I
that he performs monthly surveys in areas where unsealed radioactive materials are j
used and quarterly surveys in all areas where radioactive sealed sources are stored.
l An NRC Notice of Violation dated July 14,1993 documented the licensee's failme to l
locate radiation survey records and not being able to verify that required area radiation surveys were conducted. During the current inspection, the HPS stated that he performed the surveys and produced the records of surveys performed on the dates indicated by the records that were attached to the licensee's response to the Notice of Violation dated July 14, 1993. The NRC had no further questions regarding these survey records.
l The HPS stated that he did not know why the survey records could not be found during the previous inspection. However, the RSO stated that the records could not be found during the inspection because his department is understaffed and therefore survey records and other paperwork are not filed in a timely fashion. He also stated i
that in July,1993, inspectors from the City of New York's Bureau of Radiological Health were inspecting the university on the same day as the NRC and therefore, it was difficult to find the survey records because he was occupied with two inspections by two different regulators on the same day.
No additional safety concerns or items of noncompliance were identified.
6.
Security of Special Nuclear Material The inspectors observed several special nuclear material storage locations. Seven plutonium sealed neutron sources were stored in Mudd Room 069A. This room is accessed through Mudd Room 172. The RSO stated that this room was normally locked and keys were possessed by the radiation safety staff, the researcher (an authorized user) responsible for Mudd Room 172, and another laboratory supervisor for Mudd Room 173. The room was observed by the inspector to be locked. In addition, the sources were locked in their storage containers.
Two plutonium sealed neutron sources and several additional small quantities of special nuclear material were located in a storage room that is part of Mudd Room 173. The small quantities of special nuclear material were stored in a cabinet that was observed to be locked with a padlock and chain. The storage room itself, which contained the cabinet and the two plutonium sealed neutron sources, was also observed by the inspector to be locked. The RSO stated that an authorized user of
10 radioactive material and the Laboratory Supervisor, who works under the supervision of the authorized user, had keys to the storage room and padlock on the cabinet.
Several small sources of uranium-233 and uranium-235 were located in a storage room that is part of Mudd Room 284C. The r?aterial was stored within an unlocked cabinet in the room. The storage room itself was observed to be locked. The RSO stated that only the Radiation Safety OfFce had keys to this storage room.
One plutonium sealed neutron source was located in a storage room in Pupin Room 606B. The storage room was observed to be locked. A Physics Department employee stated that he and one other Physics Department employee responsible for l
bringing the source to Pupin Room 318 for teaching demonstrations conducted by the authorized user had keys to the storage area.
One plutonium sealed neutron source was stored in a storage closet in the Barnard Room 806. The storage room and the source storage container were observed to be L
locked. The authorized user for the source stated that all faculty of the Chemistry l
Department had keys to open the storage closet, since experiment notebooks were also l
kept in this closet. However, the authorized user also stated that only she and the l
Director of General Chemistry, who works under the supervision of an authorized user, had a key to open the source storage container.
l One plutonium scaled neutron source was stored in a storage room in the Nevis l
facility. The storage room was observed to be unlocked, however, the area was observed to be attended by several Nevis employees, including a member of the Radiation Safety Committee (RSC). The source storage container was observed to be locked. A Nevis employee who is also a member of the RSC stated that an unknown number of people have keys to the Nevis facility, including Nevis personnel and security guards. He also stated that all doors were locked at night and that security guards patrol the area. The licensee ' stated that the security of this source will be improved by securing the source within a locked storage cage currently used by the Nevis facility for storage of tritium waste. The RSO informed the inspector on March 31,1994, that the Nevis plutonium neutron source had been placed in the locked storage cage and that only the authorimi user responsible for the tritium waste has keys to this storage cage. On April 12, 1994, the authorized user for the storage cage was contacted to confirm that the plutonium neutron source was secure. The authorized user confirmed that the source was locked within the waste storage cage-and stated that the key to the cage was placed in a box within a cabinet in his lab.
The authorized user also stated that the key storage area was not readily accessible and that the only personnel that accessed the area were himself, his assistant, and another authorized user.
The inspector examined several refrigerators and freezers at the Morningside Campus, including some of those in the Biology Building, and no special nuclear material was found. However, food and drink were found in one laboratory. This issue was referred to the City of New York since the material used in the laboratory was
l l
i 1
11 l
l L
radioactive material which is regulated by. the City.
No additional safety concerns or items of noncompliance were identified.
7.
Posting of Form NRC-3 and Radioactive Materiah Caution Signs In all areas that were inspected, radioactive material caution signs were properly posted. This included the posting of all cabinets and rooms where special nuclear i
materials were stored.-
I Copies of Form NRC-3, " Notice to Employees", were posted in places where 1
employees with access to licensed materials would see them on the way to or from the l
area where the materials were stored.
l No Lafety concerns or items of noncompliance were identified.
8.
Training The licensee's procedure for authorizing new users, as described in their license -
application dated November 6,1991, includes confirming that the individual:---1)-
l possesses a college degree at the bachelor level; 2) has 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 exp dence 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; and 3) has attended the site specific radiation safety training course. The inspector determined that, although, the last two authorized users approved by the RSC met the college degree criteria and attended radiation j
safety training, they did not submit documentation showing that they had 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. The RSO stated that the required 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of training was not confirmed for authorized users.
Failure to confirm that authorized users have 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 j
experience is an apparent violation of License Condition 16 of License No. SNM-1995.
j L
In its application dated November 6,1991, the licensee also described the_ training g
requirements for all radiation workers. The licensee committed to providing initial radiation safety training and a continuing education course in radiation safety or an i
annual radiation safety refresher course to all radiation workers. Although, the licensee had provided initial radiation safety training to all radiation workers, a continuing education course in radiation safety or and annual radiation safety refresher course was not always provided. Specifically, individuals responsible for working with the plutonium sealed neutron sources in the Mudd Building and Pupin Building had not received a continuing education course in radiation safety or an annual radiation safety refresher course.
i-
12 Failure to provide a continuing education course in radiation safety or an annual radiation safety refresher course to all radiation workers is an apparent violation of License Condition 16 of License No. SNM-1995.
No additional safety concerns or items of noncompliance were identified.
9.
Radiation Safety Committee Records of Radiation Safety Committee'(RSC) meetings held during the previous twelve months were reviewed. Items recorded in the minutes indicated that the RSC is actively involved in overseeing radiation safety issues and granting approval to use radioactive materials. The minutes also indicated that David Brenner is the chairman of the RSC and actively participates in its meetings. Several members of the RSC-were contacted to provide confirmation of the information in the minutes and J
described to the inspector the contents of the March 1994 and December 1993 meetings.
No safety concerns or items of noncompliance were identified.
10.
Verification of Oualifications ofIndividuals Involved with the Radiation Safety Program a.
Herbert Michael, Assistant Director, Department of Environmental Health and Safety and RSO.
Mr. Michael's resume was submitted to the NRC with a letter dated December 7,1992 that requested that he be named the RSO on NRC License No. SNM.
1995. Several major items included on his resume were verified. The fact that Mr. Michael received a master's degree from the Department of Environmental Health Science, Hunter College in 1987 was verified by Christine Alexio, secretary for the department, during a telephone conversation-with the inspector on March 8,1994. The fact that Mr. Michael received a i
bachelor's degree in liberal studies from the University of the State of New York was verified by Colleen Degonzague, Clerk, Records Department, ReFents College during a telephone conversation with the inspector on March i
10, 1994. During the inspection, Mr. Michael stated that his course work -
involved three years of study of sciences at City College of New York and two -
years of studying radiation therapy at Montifiore Hospital. The fact that Mr.
Michael worked as an Associate Radiological Health Specialist with New York State's Bureau of Environmental Health, Department of Health, from 1986 to 1991 was confirmed by Mr. Ihor Czerwinskyj.who is now a Health Physicist with the NRC, but worked at the Bureau of Environmental Health during that time. The fact that Mr. Michael worked as the Director of the Radiation Safety Office at the University of Medicine and Dentistry of New Jersey was confirmed by documentation in NRC Docket File Nos. 030-09926 and 030-13634.
j j..
13 I
Mr. Michael stated, and the New York City Bureau of Radiological Health confirmed,Lthat he is named as the RSO ' n License No.162-1,~ the o
i University's broad scope license issued by the City of New York. The fact that Mr. Michael is a Certified Industrial Hygienist was given credence'by the fact that he possesses certificate number 4105 issued by the American Board of Industrial Hygiene on December 9,' 1988. -
During conversations with the inspectors, Mr. Michael demonstrated I
knowledge of health physics principles and practice, and NRC regulations commensurate with the knowledge required for a RSO of an NRC license similar to License No. SNM-1995, b.
Loretta Greenholtz, Director, Department of Environmental Health and Safety
{
Ms. Greenholtz oversees the Department of Environmental Health and Safety, which is responsible for fire safety, indoor air quality, chemical safety, j-hazardous waste disposal, asbestos. safety and radiation safety. : Mr. Michael i-reports directly to her.
Ms. Greenholtz stated that she studied chemistry at State University of i
New York, Plattsburg. She also stated that she received 'a Master of Public Health degree from New York Medical College. She stated that she served as the RSO/ Safety Officer from 1983 to 1985 at the Dana Taylor Research.
Institute and as the Director of Environmental Health and Safety from 1985 to 1989 at Albert Einstein College of Medicine. Although the NRC does not routinely review the qualifications of the RSO's supervisor, her training and j
experience are sufficient for her current position. The fact that Ms. Greenholtz served as the Director of Environmental Health and Safety from 1985 to 1989 at Albert Einstein College of Medicine was confirmed by George Hamawy, j
RSO, Albert Einstein College of Medicine _ during a telephone conversation with the inspector on March 10, 1994. The fact that Ms. Greenholtz received -
F a Master of Public Health degree from New York Medical College was confirmed by Marlene Bellengi, Coordinator, New York Medical College during a telephone conversation with the inspector on March 10, 1994, i
c.
David Brenner, Ph.D., Chairman, RSC
).
Dr. Brenner is currently an Associate Professor at the Center for Radiological Research, College of Physicians and Surgeons, Columbia University.
i Dr. Brenner's qualifications were reviewed by the NRC when he was designated Chairman of the Radiation Safety Comm_ittee. Dr. Brenner.
confirmed that several items on his curriculum vitae that was sent to the NRC with Columbia University's letter dated August 21,1991 are correct.
F Specifically, he confirmed that (1) he received a Master of Science degree in radiation physics from the Medical College of St. Bartholomew's Hospital, y
University of London; (2) he received his doctoral degree, for which he.
j' completed a thesis which involved radiation therapy, from the University of e
.-~:---
- +
1 1
14 Surrey, Surrey, England; and (3) he worked at Los Alamos Scientific laboratory. In a telephone conversation on March 11,1994 between the l
inspector and Mary Ann Sprouse, Clerk III, Los Alamos National laboratory, she confirmed that David Brenner worked as a staff member at the laboratory from June 11,1979 to October 23,1983. Dr. Brenner stated, and Mr.
Michael concurred, that as chairman of the RSC, Dr. Brenner (1) attends -
quarterly committee meetings; (2) gives advice regarding radiation safety issues to the RSO; (3) provides oversight of the radiation safety program; and (4) evaluates non-routine applications to use licensed materials. Although?
Dr. Brenner has his office at the College of Physicians and Surgeons,.
Columbia University, which is several blocks away from the Morningside.
Campus, he stated that he maintains contact with the RSO.by telephone conversations and electronic mail transmissions. He also teaches a class at Morningside Campus which requires him to be on campus twice per week.
During conversation with the inspector, Dr. P enner demonstrated knowledge of.
health physics principles and practices and dc. mstrated a keen interest in the radiation safety program at Columbia that would indicate that he actively' pursues his duties as chairman of the Radiation Safety Committee.'
No safety concerns or items of noncompliance were identified.
11.
Verification of the Presence of a Radiation Safety Officer since 1991 Dr. Richard Kulikowsky, Director, New York ' City Bureau of Radiological Health, confirmed that Columbia University has had a RSO continuously from 1991 to.the i
present. He stated that Ahmad Hatami served as RSO from 1988 to June 1991. He L
further stated that from July 1991 to January 1992, Leon Lidofsky served as the RSO.
From January 1992 to December 5,1992, Neil Wotherspoon served as RSO. Mr.
Michael and Dr. Kulikowsky confirmed that from December 5,- 1992 through December 30,1992, Dr. Brenner served as interim RSO. From December 30,1992 to the present, Mr. Michael has served as RSO. Correspondence in NRC files also reflects the status of the RSO position as described by Mr. Michael and Dr.-
Kulikowsky.
No safety concerns or items of noncompliance were identified.
12.
Human Use Exoeriments
~
The RSO stated that due to the recent interest in human use experiments with l
radioactive materials, he had conducted a records review to determine if any human i
use experiments may have taken place at Colunibia University at the Morningside Campus. Also, he stated that he interviewed available personnel to ascertain their knowledge of human use experiments. He said that he had discovered no evidence that human use experiments were ever performed at Columbia University at the-Morningside Campus. Dr. Brenner stated that_ he reviewed radiation safety' committee L
meeting minutes dating to the 1950's for possible references to human use
J i
15 experiments. Dr. Brenner stated that there were no references regarding the administration of radioactive materials' to humans as part of scientific experiments at Columbia University in the meeting minutes. He also stated that there were several j
references to ethical considerations and the concept of informed consent in the meeting minutes. Dr. Brenner stated that the only_ mention of human use studies in the meeting minutes was the analysis by the Lamont Geological Laboratory, Columbia i
University of autopsy samples from cancer patients who were administered an average -
i of 90 microcuries of strontium-85 and 25 microcuries of calcium-45 at Montiflore i
- Hospital in New York City. He stated that Montiflore Hospital is not, and has never l
been, part of Columbia University. The administration of the radioactive materials to patients at Montiflore Hospital was also not. directed by Columbia University researchers. 'Dr. Brenner also stated that the Montifiore study is well documented in scientific literature.
No safety concerns or items of noncompliance were identified.
13.
Radiation Safety Manual The inspector examined the licensee's written program and procedures. The RSO stated that he is in the process of revising the University's Radiation Safety Code (in effect, a manual). He stated that he expects to submit a draft of his revision to the -
RSC in May or June of 1994. The fact that the RSO is working on revising the Radiation Safety Code was corroborated by the minutes of RSC meetings. The RSO stated that the University's current " radiation safety manual" is a combination of documents, including the " Radiation Safety Code of Columbia University,1987," the i
policy for maintaining radiation exposures as low as reasonably _ achievable (ALARA) which is published in booklet form, and current written procedures. The inspector noted that maintaining a radiation safety manual is not an NRC requirement.
No safety concerns or items of noncompliance were identified.
14.
Exit Interview The findings of this inspection, including the five apparent violations, were discussed with individuals identified in Section 1. The individuals present acknowledged the inspection findings, except for the apparent violation involving monthly area surveys.
The RSO explained that he felt that monthly area surveys'were not required because he stated that area surveys would only be performed quarterly in his letter dated August 13, 1993, in response to the Notice of Violation dated July 14,1993. The inspector explained that monthly area surveys are still required because Condition No.
16 of License No. SNM-1995 requires monthly area surveys. The importance of keeping organized, current, and accurate inventory records was also communicated to the licensee representatives present at the exit interviews.
Development of Book Inventory from NRC/ DOE NMMSS Computer System Enriched Uranium Total Uranium (g)
U-235 (g)
Beginning Inventory l
12/1/67 0
0 Receipts 12/18/73 1734 1454 1/1/76 1785 1487 2/27/77 - 3/31/89 3
Total Receipts 3522 2941 Removals 12/19/75 1734 1454 12/19/75 51 33 2/28/76 1734 1454 Total Removals 3519 2941 2
7/1/86 Correction
+342
+286 Ending Book Inventory 345 286 3* Negligible quantity (less than 0.5 grams) 2According to NRC/ DOE computer records this material was discovered by the licensee in 1986 and a correcting transaction submitted at that time. This material apparently is from activities conducted prior to the requirement for a license and for transaction reporting.
Development of Book Inventory from NRC/ DOE NMMSS Computer System Uranium-233 Total Umnium (g)
U-233 (g) l Beginning Inventory 12/1/67 0
0 Receipts 12/18/73 75 73 3/24/87 to 3/31/89 Total Receipts 75 73 l
Removals 9/30/782 15 15 9/30/80 60 58 Total Removals 75 73 Ending Book Inventory l
l l
l
- Negligible quantity (less than 0.5 grams) 2This removal is suspect because it is listed on the NRC-741 form as Fission and Transmutation, which is unlikely since the reactor never operated.
J,, '.
Development of Book Inventory from NRC/ DOE NMMSS Computer System Plutonium Total Plutonium (g)
Pu-239 (g)
Beginning Inventory 12/1/67 0
0 Receipts 1/16/73 112 104 12/18/73 94 87 1/10/74 30 29 Total Receipts 236 220 Removals 3/09/77 Total Removals Ending Book Inventory 236 220 1
- Negligible quantity (less than 0.5 gmms)