ML20045C205
| ML20045C205 | |
| Person / Time | |
|---|---|
| Issue date: | 09/14/1990 |
| From: | Glenn J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Bettenhausen L, Cline W, Mallett B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20045C188 | List: |
| References | |
| HPPOS-305, NUDOCS 9306220203 | |
| Download: ML20045C205 (3) | |
Text
9 i
SEP 141990 MEMORANDUM FOR:
Lee H. Bettenhausen, Chief Nuclear Materials Safety Branch Division of Radiation Safety and Safeguards, RI William E. Cline, Chief Nuclear Materials Safety and Safeguards Branch Division of Radiation Safety and Safeguards, RII Bruce S. Mallett, Chief fluclear Materials Safety and Safeguards Branch Division of Radiation Safety and Safeguards, RIII A. Bill Beach, Director Division of Radiation Safety and Safeguards, RIV Robert J. Pate, Chief Nuclear Materials Safety and Safeguards Branch Division of Radiation Safety and Safeguards, RV FROM:
John E. Glenn, Chief Pedical, Academic, and Commercial Use Safety Branch Division of Industrial and Medical Nuclear Safety, !!!!SS
SUBJECT:
INSTALLATI0fl CF FIXED GAUGES This refers to a remorandum dated June 22, 1990 (enclosed), from A. B. Beach fRIV, to Richard Cunningham (NMSS) concerning the above subject. Mr. Beach's memorandum indicates that although a standard license. condition gererally prohibits gauge users from installing specifically licensed gauges, some gauge manufacturers may be instructing their customers to mount gauges despite the standard condition. This topic was also discussed during our July telephone-ccnference call with the regions.
The standard license condition the memorandum discusses dces prohibit licensees from mounting and installing fixed gauges unless specifically authorized.
We also note that items 7, 10.1, and 10.6 of the licensing guide for nonportable gauging devices generally make it clear that, if the applicant wishes to install gauging devices, the applicant must describe appropriate proceoures and employee training provisions.
/.s was discussed in the conference call, Texas Nuclear (TN) raised this issue in 1987 in response to an All Agreement States letter dated April 3, 1987. State Programs (SP) coordinated their response to TN with our office, and we informed Si that we considered mounting or hanging a device 9306220203 900914 PDR ORG NRRB i
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fultiple Addressees to be part of the installation process and that NRC licensees must be g eciiically authorized to mount gauges.
However, SP's letter to TN fails to n.ake this position clear.
We have enclosed copies of the correspondence addressing the issue at that time.
While the letters to All Agreement States and TN concerned generally licensed devices, you should note that HMSS's position also cpplied to specifically licensed devices.
We note that NRC has allowed 10 CFR Part 31.5 ger.eral licensees to mount devices, provided they follow the manufacturer's instructicns, i.e., the gauge source shutter must remain padlocked as received from the manufacturer.
We are not aware of any significant mishaps resulting from this practice.
We tend to believe that this procedure should also be acceptable for our specific licensees.
However, we also believe that the tranufacturer should commit, in its service license, to evaluate the licensee's mounting prccett.res ar.o discuss ar.y additional safety precautions that may need to be considered.
It is not clear to us that the manufacturers have made such commitments. Some regional licensing personnel have also suggested that a revisea st6naard condition permittinc t our: ting of locked gauges may be-appropriate. We would appreciate it if the regions would provide us with their opinions on this ir.atter.
If deemed acceptable, we will revise the standard license condition to allcw gauge licensees to mount locked gauges, ar.d will revise the licensing guide and standard review plan in the future to clarify these points.
Mr. Beach's memorandum requests consideration of a Temporary Instruction for inspecting field installation work by licensed manufacturers / distributors.
While we share Region IV's concern about these activities, we do not believe that a sufficient health and safety risk exists to redirect inspection resources.
However, we note that the procedure the region followed with Kerr McGee Refining Corporation, a new licensee, certainly helped to uncover potential gauge installation problems. Therefore, we suggest the other regions may wish to consider this procedure when issuing new fixed gauge licenses.
We note this would meet the Manual Chapter criteria that all new fixed gauge licenses be inspectec within six months.
Alternatively, the regions may wish to conduct their inspettics.s at W titre the manufacturer is completing the gauge installation process - this may help to identify other problem areas, such as excessive radiation levels, inadequate access controls, etc. We wish to be kept informed of any significant findings in this area.
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Multiple Addressees i If you have any further questions on this matter, you may contact me at FTS 492-3418 or Bruce Carrico at FTS 492-0634.
John E. Glenn, Chief fiedical, Academic, and Commercial Use Safety Branch Division of Fuel Cycle and Material Safety, NMSS
Enclosures:
As stated DISTRIBUTION FC-493 NMSS r/f NRC File Center TAR r/f JEGlenn RECunningham GSjoblom IMNS Central File PCVacca LHBettenhausen, RI WECline, RII BSMallett, RIII RJPate, RV MShanbacky, RI JKinneman, RI JWhite, RI CHosey, RII GMMcCann, RIII BRiedlinger, RV SLBaggett, IMAB MLamastra RFonner, OGC EMcAlpine, RII ABBeach, RIV VLMiller, GPA/SP WFisher, RIV JRicci, AEOD/TTC CCain, RIV LWCamper, IMAB
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OFFICIAL RECORD COPY GAUGE MEM0
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