ML20030D143
| ML20030D143 | |
| Person / Time | |
|---|---|
| Issue date: | 08/24/1981 |
| From: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20030D141 | List: |
| References | |
| NUDOCS 8108310438 | |
| Download: ML20030D143 (3) | |
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Appendix A NOTICE OF VIOLATION The Massillon Steel Casting License No. 34-02605-01 Company As a result of the inspection conducted on June 2,1981, and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7, 1980), the following violations were identified:
1.
10 CIR 34.43(a) requires that at least one calibrated and operable radiation survey instrument be available at the location of radio-graphic operaticus whenever radiographic operations are being per-formed.
Contrary to this requirement, the Victoreen Sodel 592B survey meter which was used during raciographic operations was not calibrated in accordance with this requirement. Specifically, the calibration re-l cords show that on December 18, 1979 your calculated radiation level i
at 37 inches from a 44 millicurie cobalt-60 source was 300 mR/hr.
However, the actual calculated radiation level on that date from this source was 67 mR/hr.
In addition, cobolt-60 radioactive decay was improperly calculated for all instrument calibrations performed in 1980 and 1981.
This is a Severity Level IV violation (Supplement VII).
This is a repeat viciation.
2.
10 CFR 34.29(b) requires that each entrance used for personnel l
access to the high radiatior. area in a permanent radiographic installatica love both visible and audible warning signals to warn of the precence of radi tion. The visible signal must be activated by radiation whenever the source is exposed and the audible signal must be activated WFen an attempt is made to enter the installation while the source is exposed.
i Contrary to this requirement, as of the day of the inspection, June 2, 1981, the(permanent radiographic installation?)1ocated in your facility did not have the required audible signal activated in the manner prescribed.
l This is a Severity Level V violation (Supplement VII).
l 3.
10 CFR 34.25(b) requires that you test each sealed source for leakage at intervals not to exceed six months.
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0108310438 810H24' hM9S LIC3K) 34-Cn605-01 PM
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Appendix A Contrary to this requirement, a leak test had not been performed on your cobalt-60 sources (Serial Nos. 1332 and 269) between March 17, 1980 and Janua ry 13, 1981, a period in excess of six months.
This is a Severity Level V violation (Supplement VII).
4.
10 CFR 34.33(c) requires that pocket dosimeters be checked at intervals not to exceed one year for correct response to radiation.
Contrary to this requirement, as of the day of the inspection, June 2, 1981, you have failed to perform the required check for correct response to radiation on pocket dosimeters used at your facility.
This is a Severity Level V violation (Supplement VII).
5.
10 CFR 34.26 states that each licensee shall conduct a quarterly physical in-ventory to account for all sealed sources received and possessed under his license. The inventory record is to include certain required information.
Contrary to this requirement, inventory records did not include the kind of byproduct material nor the location of sealed sources.
This is a Severity Level VI violation (Supplement VII).
6.
10 CFR 20.408(b) and 20.409(b) require that you make a report to the Commission, and to the individual involved, of the radiation exposure of each individual who has terminated employment.
Contrary to this requirement, as of the day of the inspection, June 2, t
j 1981, you have failed to provide the required report to the Commission, l
or to the individuals involved, for two individuals who terminated employment in 1979 and 1980.
l This is a Severity Level VI violation (Supplement IV).
Pursuant to the provisicns of 10 CFR 2.201, you are required to submit to this
. office within thirty days of the date of this Notice a written statement or I
explanation in reply, including for each item of noncompliance:
(1) corrective action taken and the results achieved; (2) corrective action to be taken to avoid further noncompliance; and (3) the date when full compliance will be achieved. Under the authority of Section 182 of the Atomic Energy Act of 1954, as amended, this response shall be submitted under oath or affirmation.
Consideration may be given to extending your response tine for good cause shown.
gG g 41981 dd ouSw-.,
Dated C. E. Norelius, Director Division of Engineering and Technical Inspection
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r Appendix B HANAGEMENT CONTROL In order to provide jou with some guidance in assessing the adequacy of your management control program, the NRC Region III office provides the following as the acceptance criteria for adequate management control for materials licensees. " Management Control" is a system instituted by management to assure that licensed activities are performed safely and in accordance with regulatory requirements (license conditions and applicable regulations).
This will include:
a.
Delineation of duties and responsibilities of all persons involved in licensed activities.
b.
Providing for indoctrination and training of all personnel performing licensed activities, specifically in those areas directly affecting compliance with NRC regulations and license conditions.
c.
Verification, as by checking, auditing and inspecting, that activi-ties affecting safety related functions have been correctly performed.
The verifying process should be performed by individuals or groups other than those performing the safety related procedures.
d.
Insuring continued compliance of licensed activities throughout periods during which routine activities may be interrupted, such as changes in equipment, personnel or facilities.
Because ot the many variables involved, such as the number of personnel, type of activity being performed and the location or locations where activities are performed, the organizational structure for executing the management control program may take various forms; however, irrespective of the organizational structure, the individual or group responsible for this control should have the flexibility and authority to institute changes or corrections as required to maintain compliance with NRC regulations and license conditions.
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