ML20045G288
| ML20045G288 | |
| Person / Time | |
|---|---|
| Issue date: | 05/01/1991 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20045G120 | List: |
| References | |
| NUDOCS 9307130137 | |
| Download: ML20045G288 (97) | |
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REPORT AND EVALUATION OF THE MARYLAND RADIATION CONTROL PROGRAM FOR THE PERIOD FEBRUARY 17,1989 TO MARCH 27,1991 18th Reculatory Program Review i
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1 EVALUATION OF AGREEMENT STATE RADIATION CONTROL PROGRAM STATE REVIEW GUIDELINES, QUESTIONS AND ASSESSMENTS Name of State Programs Maryland Date of NRC Reviews March 1991 I.
LEGISLATION AND REGULATIONS NRC Guidelines Clear statutory authority should exist, designating a state radiation control agency and providing for promulgation of regulations, licensing, inspection and enforcement. States regulating uranium or thorium recovery and associated wastes pursuant to the Uranium Mill Tailings Radiation Control Act of 1978 (UMTRCA) must have statutes enacted to establish clear authority for the State to carry out the requirements of UMTRCA. Where regulatory responsibilities are divided between State agencies, clear understandings should exist as to division of responsibilities and requirements for coordination.
A.
Lecal Authority Questions:
1.
Please list all currently effective legislation that affects the radiation control program (RCP).
Annotated Code of Maryland Environmental Title 8 - Radiation Section 8-101 601 Title 7 Hazardous Materials and Hazardous Substances Sections 7-201, 7-208, 7-225, 7-226, 7-227, 7-228, 7-232, 7-223, 7-234, 7-235, 7-236, 7-237, 7-238, 7-239, 7-240, 7-241, 7-242, 7-243, 7-244, 7-245, 7-249, 7-250, 7-251, 7-252, 7-257 and 7-264.
2.
What changes have been made to the State's statutory authority to regulate agreement materials including LLW operations, since the last review? Please attach copies of the changes.
Effective July 1, 1989, REP was granted the authority to establish a fee schedule for all radiation users.
Effective July 1, 1990, RHP was granted expanded enforcement authority, including the issuance of administrative penalties and the increase in civil penalty maximum to $10,000 per day, per violation.
3.
Please cite legislation if the State has the authority to a.
apply civil penalties?
Yes, Section 8-509(b) Environment Article, Annotated Code of Maryland b.
collect fees?
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Yes, Section 8-301(b), Environment Article,. Annotated Code of Maryland c.
require performance bonds or sureties for decommissioning i
licensed facilities?
No
-d.
require performance bonds or sureties for clean-up of' licensed facilities after a contamination accident?
i No e.
require long-term care funds for uranium mill or low-lev-l waste facilities?
No 4.
If any responses to the above question are negative, explain-any plans the State may have regarding those issues.
The issue of bonding and financial surety are being discussed I
w'ith MDE management and may result in legislation in FY '92.
B.
Status and Comoatibility of Reculations (Category I)
NRC Guidelines The State must have regulations essentially identi-cal to 10 CFR Part 19, Part 20 (radiation dose standards, effluent limits, waste manifest rule and certain other parts), Part 61 (technical definitions and requirements, performance objectives, financial assurances) and those required by UMTRCA, as implemented by Part 40.
The State should adopt other regulations to maintain a high degree of uniformity with NRC regulations. For those regulations deemed a matter of compatibility by NRC, State regulations should be amended as soon as practicable but no later i
than 3 years. The RCP.should establish procedures for effecting appropriate amendments to State regulations in a timely manner,-
normally within 3 years of adoption by NRC.
Opportunity should be provided for the public to comment on proposed regulation changes.
(Required by UMTRCA for uranium mill regulation.) Pursuant to the terms of the Agreement, opportunity-should be provided for the NRC to comment on draft changes in State regulations.
l Questions 1.
What is the effective date of the last amendment of the State's regulations that was made to maintain compatibility?
Adopted:
September 2, 1986. Effectives September 21, 1986 No Change.
2.
Referring to the NRC chronology of amendments attached to this questionnaire identify those that have not been adopted by the State and explain the reason why they were not adopted and/or actions being taken to adopt them.
June 28, 1983. No change. The State is promulgating regulations equivalent to the NRC's low-level waste classification and manifest rules, and intends to adopt them no later than July 1, 1991.
3.
Describe your State's procedures for revising and adopting changes to regulations.
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3 A copy of new procedures are available in Region I files. No change.
4.
How is the public involved in the process?
Proposed regulations are published in the Maryland Register for comment. A public hearing is also held. No change.
5.
At what stage does the NRC have the opportunity to comment on draft changes to State regulations?
During Department review, a copy is submitted to the NRC-Region I.
II.
ORGANIZATION A.
Location of the Radiation Control Procram Within the State Orcanization (Category II)
NRC Guidelines The RCP should be located in a State organization parallel with comparable health and safety programs. The Program Director should have access to appropriate levels of State management.
Where regulatory responsibilities are divided between State agencies, clear understandings should exist as to division of responsibilities and requirements for coordination.
1.
Please attach a current dated organization chart (s) showing the position of the RCP within the State organization and its relationship to the Governor.
Organizational Chart is attached.
2.
Is the RCP on a comparable level within the State organization with other health and safety programs so as to compete effectively for funds and staff?
Yes.
3.
Has the RCP program director experienced difficulty in obtaining access to appropriate levels of State management? If so, explain.
No.
B.
Internal Orcanization of the RCP (Category II)
NRC Guidelines The RCP should be organized with the view toward achieving an acceptable degree of staff efficiency, place l
appropriate emphasis on major program functions, and provide 1
specific lines of supervision from program management for the execution of program policy. Where regional offices or other government agencies are utilized, the lines of communication and administrative control between these offices and the central office (Program Director) should be clearly drawn to provide uniformity in licensing and inspection policy, procedures and supervision.
Questions:
1.
Please attach current, dated copies of your internal RCP organization charts.
Include titles for all positions and names for incumbents.
If applicable, include regional offices and contract agencies.
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organizational chart is attached.
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4 2.
If regional offices or contract agencies are used:
No regional office used.
a.
To whom do regional or contract agency personnel report administratively?
b.
To whom do regional or contract agency personnel report technically?
3.
If the RCP shares the program with, or contracts with other agencies to administer the program:
RCP does not contract with other agencies to administer the
- program, a.
Identify the agencies and indicate their responsibilities.
b.
How are their responsibilities set out (e.g. statutes, MOU, contract)?
c.
To whom do their personnel report to administratively?
d.
To whom do their personnel report technically?
C.
Leoal Assistance (Categor, II)
NRC Guidelines Legal staff should be assigned to assist the RCP, or procedures should exist to obtain legal assistance expeditiously.
Legal staff should be knowledgeable regarding the RCP program, statutes, and regulations.
Questions:
l.
Are legal staff members assigned to assist the RCP or do pro-cedures exist to obtain legal assistance expeditiously?
Toxies, Environmental Science and Health (TESH) has legal assistance specifically assigned from the State Attorney General's office. No chant,e.
2.
Is the legal staff knowledgeable regarding radioactive materials, the RCP, statutes, and regulations?
Yes.
3.
If legal assistance was utilized since last review, provide a brief summary of the circumstances.
The Toxies, Environmental Science and Health (TESH) attorney has been involved in various escalated enforcement actions for the Department for over a year, and has been very important in assuring that licensee received penalties appropriate to the violation (s) and within the authority of the Radiological Health Program. Legal assistance is used in constructing enforcement letters, in determining civil and administrative penalties, during enforcement conferences, answering Freedom of Information Act requests, interpreting statutory and regulatory authority,and preparing orders.
D.
Technical Advisory committees (Category II)
NRC Guidelines: Technical Committees, Federal Agencies, and other resource organizations should be used to extend staff capabilities for unique or technically complex problems. A State Medical
5 Advisory Committee should be used to provide broad guidance on the
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uses of radioactive drugs in or on humans. The Committee should represent a wide spectrum of medical disciplines. The committee should advise the RCP on policy matters and regulations related to use of radioisotopes in or on humans. Procedures should be developed to avoid conflict of interest, even though Committees are advisory. This does not mean that representatives of the regulated community should not serve on advisory committees or not be used as consultants.
Questions:
1.
What technical advisory committees have been established to assist the RCP7 The law provides for a Radiation Control Advisory Board (RCAB);
we have a Medical Advisory Committee (MAC).
Regular meetings of the RCAB are held. Assistance from the MAC is either by mail or a meeting. Consultants are used on a case by case basis.
If we need assistance from a licensee ws request it, the same for the NRC and other State and Federal agencies. No change.
2.
Are regular meetings scheduled? If so, what is the frequency?
The RCAB meets four times per year. Minutes are prepared. No change.
3.
Please provide a list of the names and affiliations of the technical committee (s) members.
Current list is attached.
4.
What procedures exist to avoid areas of conflicts of interest by members of the committees?
Attention is given to avoiding conflicts of interest by not requesting advice from committee members in cases involving a licensee with whom they are associated. Legal guidance is also obtained.
No change.
5.
If any advisory committee was utilized during the review period, please provide a brief summary of the circumstances.
The RCAB is asked to give advice as needed at time of the meetings. Members are provided with drafts of regulations, etc. to review and comment on.
The average workload would probably not exceed 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> each 6 months. The law stipulates that members are to receive no remuneration, but provides for reimbursement of expenses. The MAC is consulted by mailing each member a letter of request for advice supported by the necessary backup material. Members then respond by mail giving their recommendations.
No remuneration is provided. No change.
Estimated average workload - 8 hrs. per year.
III. MANAGEMENT AND ADMINISTRATION A.
Quality of Emeroency Plannino (Category I)
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6 NRC Cuideliness The State RCP should have a written plan for g.
j response to such incidents as spills, overexposures, transportation accidents, fire or explosion, theft, etc.
The Plan should define the responsibilities.and actions to be taken by state agencies. The Plan should be specific as to persons responsible for initiating response actions, conducting operations and cleanup.' Emergency i
communication procedures should be. adequately established with appropriate local, county and State agencies. Plans should be distributed to appropriate persons and agencies. NRC should be provided the opportunity to comment on the Plan while in draft form.
2 The plan should be reviewed annually by Program staff for adequacy and to determine that content is current.
Periodic drills should be performed to test the plan.
Questions:
1.
What written plan does the RCP use for response to incidents involving radioactive materials (other than plans for fixed nuclear facilities)?
Radiation response plan is incorporated into the Maryland Disaster Assistance Plan (MDAP). The MDAP is a comprehensive State plan.
Excerpts applicable to radiation incidocts are tvailable in Region I files. For materials incidents, the general plan applies. For-fixed nuclear facilities Annex Q of the plan applies. CRH rarely refers to the MDAP in #1 above. No change.
l 2.
According to the Plan, which State agency is responsible for:
)
a.
initiating response actions?
b.
conducting operations?
c.
supervising cleanup?
Secretary, MDE is primarily responsible for directing radio-logical assistance and recovery operations. Other state t
agencies will provide appropriate assistance to MDE..No change.
3.
Describe your emergency communications procedures..
Communications are primarily by public telephone systems.
Individual agencies may also utilize two-way radio or beepers for internal notification. Some interface exists on two-way radio frequencies.
The state has designated State Highway Administration "24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Emergency frequency" as the frequency to be used by state agencies during a statewide emergency. REP has its own frequency.
4.
Who is responsible for distributing the plan to the appropriate l
persons and agencies?
i Maryland Emergency Management Agency.
5.
When was the emergency communications list last reviewed and/or revised?
i Every six (6) nonths. Last revised January, 1991.
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Other than'the communication list, when was the plan last f
updated ?
MDAP - 1988
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Annex Q Radiological Emergency Plan - April 1990 7.
At what stage is the NRC provided the opportunity to comment on the plan or the revision while it was in draft form?
Each year appropriate Federal agencies are given a copy of the plan as part of a graded exercise response.
It is at this time review and comment is required.
8.
When was the plan last reviewed to assure its content is up-to-date?
1990 Peach Bottom Graded Exercise 9.
When was a drill last performed to test the plan?
1990 Peach Bottom Graded Exercise B.
Budoet'(Category II)
NRC Guidelines Operating funds should be sufficient to support program needs such as:
staff travel necessary to conduct an effec-tive compliance program, including routine inspections, follow-up or special inspections (including pre-licensing visite) and responses to incidents and other emergencies; instrumentation and other equipment to support the RCP; administrative costs in operating the program including rental charges, printing costs, laboratory services, computer and/or word processing support, preparation of correspondence, of fice equipment, hearing costs, etc. as appropriate.
Principal operating funds should be from sources which provide continuity and reliability, i.e., general tax, license fees, etc.
Supplemental funds may be obtained through contracts, cash grants, etc.
Questions:
1.
Show the amount for funds for the RCP for the current fiscal year obtained from:
a.
State General funds - $697,749 i
b.
Fees - $361,805 c.
Federal grants and contracts (identify)
(1) NRC Reactor Monitoring - $17,100 (2) FDA: Federal I-Ray Inspection - $18,127 (3) EPA: Radon - $130,897 d.
Other (1) BG&E Staff support - $94,779 (2) DNR Sample Collection & Analysis - $56,280 e.
Total - $1,473,530 2.
Show the total amounts in the current RCP budget allocated for.:
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Administration - $221,188
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b.
Radioactive materials -
$123,013 + $178,032 + 94,770 = $395,824 c.
X-ray - $211,180 + $180,902 + $18,127 = $560,835 d.
Environmental Surveillance - $56,280 e.
Emergency planning - $65,500 f.
LLW regulation - N/A g.
other (radon, non-ionizing, operator credentialing, etc.
Please identify) - RADON $173,903 h.
Total: - $1,473,530 3.
What is the change in budget from the previous year and what is the reason for the change (new programs, change in emphasis, statewide reduction, etc.)?
Change from previous year:
$441,489 Increase due primarily to fees collected and EPA Radon Grant.
4.
Describe your fee system, if you have one, and give the percen-tage of cost recovery for the radioactive materials program.
Please attach a copy of the fee schedule.
See attached COMAR 26.12.03 State Radiation Control Fund.
Fee recovery for the materials program is approximately 30%.
5.
Overall, is the funding sufficient to support all of the program needs? If not, specify the problem areas.
Funding is adequate at this time.
C.
Laboratory Support (Category II)
NRC Guidelines The RCP should have the laboratory support capability in-house, or readily available through established procedures, to conduct bioassays, analyze environmental samples, analyze samples collected by inspectors, etc., on a priority established by the RCP.
Questions:
1.
Are laboratory services readily available in-house or through other departments within the State organization?
Yes.
2.
If services are provided by other departments, discuss t!.e arrangements, supervision, charges and interdepartmental com-munications.
The Radiation Chemistry laboratory is under DHMH but supports MDE almost exclusively.
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9 The DHMH lab prepares data that is used in a bi-annual report-
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prepared by the Department of Natural Resources and Maryland V
Department of the Environment.-
3.
Have there been any changes in the status of the laboratory support since the last review? If so, please explain.
No change since last report.
4.
If laboratory services must be provided by a non-State agency:
NA Discuss the contractual arrangements.
a.
b.
Is the party providing the service a State licensee?
r If a State licensee provides the service or equipment, c.
what are the costs?
5.
Describe the capability of the laboratory as follows:
a '.
can it qualitatively and quantitatively analyze low-energy beta emitters?
- Yes, b.
Can it qualitatively and quantitatively analyze alpha emitters?
Yes.
Can it selectively determine the presence and quantity of c.
gamma emitters?
Yes.
d.
Can it handle samples in any physical form - wipes, liquids, solids, gaseous?
Yes Does the lab participate in a periodic quality control e.
program? If so, please identify the program.
Yes 6.
How much time does it take to obtain the results from sample analyses on both a routine basis and on an emergency basis?
Normally 1 to 10 days depending upon the type of sample, sample preparation time, sensitivity and precision of the analysis in growth time etc.
t on an emergency basis, sample preparation can begin immediately upon delivery to the laboratory. Availability of results constrained as stated above. When necessary, laboratory staff can be contacted during non-routine work hours to conduct sample analysis.
7.
Please attach a list giving the number and types of laboratory instrumentation and services available.
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20 The laboratory has instrumentation to qualitatively and f
quantitatively analyze samples for alpha and beta
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radioactivity.
It can also identify and quantify gamma photons greater than 30 kev.
List and types of laboratory instrumentation is available in Region I files.
D.
Administrative Procedures (Category II)
NRC Guidelines: The RCP should establish written internal procedures to assure that the staff performs its duties as required and to provide a high degree of uniformity and continuity in regulatory practices. These procedures should address internal processing of license applications, inspection policies and procedures, decommissioning and license termination, fee collection, contacts with communication media, conflict of interest policies for employees, exchange of information and other functions required of the program. Administrative procedures are in addition to the technical procedures utilized in licensing, and inspection and enforcement.
Questi'ons:
1.
Have administrative procedures and policies been established, documented and made available to RCP staff regarding:
a.
Office administration:
- Yes, b.
Receipt, assignment and tracking of license applications Yes.
c.
Inspections (e.g., assignments, announcements of inspections):
Yes.
d.
Terminating licenses and decommissioning licensed facilities:
- Yes.
e.
Collecting fees:
Yes.
f.
Responding to press inquiries: MDE Policy Guidance.
g.
Conflict of interest for RCP employees State Ethics i
Policy.
h.
Exchange-of-information with NRC and Agreement States: No formal procedures established. All contacts made with Program Director's approval.
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l 1.
Distribution (as appropriate) to staff and licensees of All Agreement State letters and Information Notices:
- Yes, in accordance with established HDE and RAM Licensing procedures.
Procedures are established in all categories exemplified in this question except decommissioning procedures.
2.
What other written administrative procedures have been developed?
All procedures are documented. A Manual of Operations has been written. This manual includes general procedures for licensing and inspection of radioactive materials, and administrative f
g policies and procedures.
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11 3.
Have copies of these procedures been distributed to regional offices and to other appropriate agencies?
The written policies and procedures described above are applicable to this.
In addition direct communications, one on one, meetings between the two staffs, and frequently the Program Administrator and both staffs.
4.
How are personnel and regional offices (if applicable) kept informed of changes in regulatory policies and practices?
By written policy and procedures guides, administrative directives, and meetings.
E.
Manacement (Category II)
NRC Guidelines Program management should receive periodic reports from the staff on the status of regulatory actions (backlogs, problem cases, inquiries, regulation revisions).
RCP management should periodically assess workload trends, resources and changes in legislative and regulatory responsibilities to forecast needs for increa' sed staff, equipment, services and funding.
Program management should perform periodic reviews of selected license cases handled by each reviewer and document the results. Complex licenses (major manufacturers, large scope - Type A Broad, or potential for significant releases to environment) should receive second party review (supervisory, committee, or consultant). Supervisory review of inspections, reports and enforcement actions should also be performed. When regional offices or other governmental agencies are utilized, program management should conduct periodic audits of these offices.
Questions:
1.
How does management track the status of the licensing and inspection programs -- workloads, backlogs, problem caaes, etc.?
By issuing monthly reports.
2.
How often are meetings held between program management and staff?
As required. Approximately every 3 weeks.
3.
How often is a statistical tabulation of licenses, licensees, licensing actions, inspections due, performed and overdue, etc., prepared?
Monthly.
4.
How does the RCP management keep abreast of changes in legis-lative and regulatory responsibility?
RCP staff reviews all proposed legislation introduced, and comments on it.
When legislation is passed placing the responsibility, planning is begun immediately to implement it.
RCP introduces proposed regulations and is responsible for follow through to adoption.
5.
What license review practices are followed for unusual or complex license application?
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A secondary review is conducted by a senior staf f member of all new licenses, license renewals and complex amendment requests.
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The Administrator reviews and signs all licenses and amendments.
6.
How many management reviews of license cases were performed since the last review?
Program management reviews and signs all licensing actions.
7.
Were all license reviewers included in the cases selected for management review?
No 8.
How many field accompaniments of inspectors were conducted by program management?
Eleven (11) 9.
Were all inspectors (including supervisors acting as inspectors o.r LLW inspectors, if applicable) accompanied by management during the review period?
No. These are performed by the Compliance Supervisor.
10.
Do all inspection reports receive supervisory review?
Yes 11.
Does all enforcement correspondence receive supervisory review prior to dispatch?
9 Yes 12.
If applicable, how many management audits were made of regional offices or other government agencies involved in the regulation of agreement materials?
N/A F.
Office Eculoment and Support Services (Category II)
NRC Guidelines The RCP should have adequate secretarial and clerical support. Automatic typing and Automatic Dsta Processing and retrieval capability should be available to larger (300-400 licenses) programs.
Similar services should be available to regional offices, if utilized.
Professional staff should not be used for fee collection and other clerical duties.
1 a.
Describe the secretarial and clerical support for the radioactive material program, including, if appropriate, any problem areas.
Clerical support is approximately 1.0 person years per 100 licenses.
b.
If your program has regional office, discuss the clerical support for those offices.
NA c.
In cases of unusual workloads or vacancies, can i
supplementary secretarial / clerical support be obtained?
a3 a
Yes, but must conform to Departmental budget constraints.
2.
Describe the computer equipment available to the RCP.
Workstation (screen & keyboard)
Model # 2000 Printer (Diablo)
Model # 8624862 IBM PC-AT and Printer 386 PC (1) 286 PC (3)
Hewlett Packard Rugged Writer Printer Hewlett Packard Laser Jet II 3.
What operating system do you use (i.e., MSDOS, UNIX, Apple, etc.)?
MS DOS 4.
What data base or spreadsheet programs do you use?
Database Manager - Paradox Spread Sheet - Lotus /Quatro Pro 5.
What word processing program (s) do you use?
Word Processing - Word Perfect 6.
Does your word processing program have the capability to process documents that may be transferred to and form the IBM 5520 system?
(With the exception of Wordstar most popular programs have this capability. This information can be found in your user manual index under "DCA" or " revisable format" files.)
Yes 7.
What licensing functions are on your computer system?
Licensing conditions, licensee by name, license type by code, date of last amendment and renewal requirements.
8.
What compliance functions are on your system?
Data regarding the payment of fees.
9.
Do you have a modem? If so please describe how a connection can be made.
Yes, Hayes compatible - dial up modem.
10.
Are computers or terminals available to the professional staff, and if so, what use is made of them?
Yes, word processing of reports / reference documents in file.
11.
Do you have access to a facsimile transmission unit? If so, please identify it by name an type and provide the receive and verification (information) telephone numbers.
Yes - Receive Fax telephone number (301) 631-3198 f
Verification number (301) 631-3300 l
14 12.
Describe the fee collection system and identify the staff resources assigned to it.
Fees are handled through the Fiscal Services Division Annual reciprocity fees are assessed to out-of-state licensees as a Maryland licensee, e.g., by a specific code identifying the type of licensee. A letter is mailed to each out-of-state licensee informing them of their fee along with an invoice that indicates the amount due.
All information concerning fee collection system is coeputerised.
G.
Public Information (Category II)
NRC Guidelines:
Inspection and licensing files should be available to the public consistent with State administrative procedures.
Opportunity for public hearings should be provided in accordance with UMTRCA and applicable State administrative procedure laws.
Questions:
1.
Are licensing and inspection files available for inspection by the public?
Yes 2.
If so, what information may be withheld?
Proprietary / confidential information is placed in a sealed envelope (s) so identified.
3.
What written procedures and laws govern this? Please provide reference citations.
Section 10-616(h) of the State Government Article, Annotated Code of Maryland.
IV.
PERSONNEL A.
Qualifications of Technical Staff (category II)
NRC Guidelines:
Professional staff should have a bachelor's degree or equivalent training in the physical and/or life sciences. Addi-tional training and experience in radiation protection for senior personnel should be commensurate with the type of licenses issued and inspected by the State.
Written job descriptions should be prepared so that professional qualifications needed to fill vacancies can be readily identified.
Questions:
1.
Do all professional personnel hold a bachelor's degree or have equivalent training in the physical or life sciences?
Yes 2.
What additional training and experience does the RCP director have in radiation protection?
Master of science Degree in organic Chemistry, 20 years U.S.
i Army experience in various positions dealing with radiation l
safety, control of radioactive materials, radioactive waste i
15 disposal, and radiation detection, measurement and identification.
3.
What additional training and experience are required of the senior personnel?
Written position descriptions are available in Region I files.
4.
Do written position descriptions describe the duties, respon-sibilities and functions of each professional position in the RCP and the qualifications needed by applicants for them?
Please attach copies.
Written position descriptions are available in Region I files.
B.
Etaffino Level (Category II)
NRC Guidelines Staffing level should be approximately 1-1.5 person-year per 100 licenses in effect. RCP must not have less than two professionals available with training and experience to operate RCP in a way which provides continuous coverage and continuity.
For States regulating uranium mills and mill tallings, current indi-cations are that 2-2.75 professional person-years' of effort, inclu-ding consultants, are needed to process a new mill license (including in situ mills) or major renewal, to meet requirements of Uranium Mill Tailings Radiation Control Act of 1978.
This effort include expertise in radiological matters, hydrology, geology, must and structural engineering.
Questions:
1.
Complete a table as below, listing the professional / technical person-years of effort applied to the agreement or radicactive material program by individual.
Include the name, position, fraction of time spent and the duty (licensing, inspection, administration, etc.).
Name Position FTE% Area of Effort Roland Fletcher Administrator 45 License Review and Escalated Enforcement William K. Bonta Chief, I-Ray Prog.
15 Consulted on Regulations &
Emergency Mgmt Paul R. Perzynski Prog. Admin. I 50 Emergency
Response
Ed Roach BG&E 100 Emergency
Response
1 Charles Flynn Program Admin. I 100 Licensing i
Thomas Ferguson Public Health 100 Licensing Radiation Spec.
and LLRW Carl Trump, Jr. Prog. Admin.I 100 Inspection &
Enforcement Alan D. Jacobson Elth Phys. III 100 Inspection &
Enforcement i
i
16 Robert Nelson Elth Phys. I 100 Inspection &
Enforcement Ray Manley Elth Phys. III 100 Inspection &
Enforcement Frank Kasper Elth Phys. I 100 Inspection &
Enforennent Douglas McAbee Elth Phys. I 100 Licensing 2.
Compute the professional / technical person-year effort of person-years per 100 licenses (excluding mills and burial sites).
Show calculation.
The total staff effort for the materials program is 7, not including supervisory personnel, or clerical support. However, an accurate portrayal of staff years per 100 licenses cannot be made with simple calculations. One of the RHP's licensees is Neutron Products, Inc. which, over the years, has required increasing regulatory ef fort.
In the last three years, NPI has required 1.5 PTE of radioactive material staff time, which does n'ot include legal, clerical or MDE management overview time.
With that in mind, staff is reduced to 5.5 for all other licensees.
Calculation:
5.5
I 516 100 516 I = 550 I
1.07 3.
Is the staffing level adequate to meet normal and special needs and backup? If not, explain.
Yes C.
Staff Supervision (Category II)
NRC Guidelines: Supervisory personnel should be adequate to provide guidance and review the work of senior and junior personnel. Senior personnel should review applications and inspect licenses indepen-dently, monitor work of junior personnel, and participate in the establishment of policy. Junior personnel should be initially limited to reviewing license applications and inspecting small programs under close supervision.
Questions:
1.
Identify the junior and senior personnel.
Junior personnels Douglas McAbee, Frank Kasper, Robert Nelson Senior personnels Roland Fletcher, William Bonta, Paul Perzynski, Charles Flynn, Carl Trump, Thomas Ferguson, Alan Jacobson, Nathaniel owrutsky, Raymond Manley 2.
a.
What duties are assigned to junior personnel?
Junior personnel inspect radioactive materials licensees, write reports, make recommendations for enforcement action, perform investigations, and participate in
{
emergency response operations.
17 b.
How is their work monitored?
Their work is monitored by senior and supervisory staff during accompaniments, document reviewa, and one on one job review discussions.
3.
Is there adequate supervisory or senior guidance and direction for junior personnel?
Yes 4.
How do senior personnel participate in the development of program policy?
Through written input solicited by supervisors and program managers.
D.
Training (Category II)
NRC Guidelines: Senior personnel should have attended NRC core courses in licensing orientation, inspection procedures, medical practices and industrial radiography practices.
(For mill States, mill training should also be included.) The RCP should have a program to utilize specific short courses and workshops to maintain appropriate level of staff technical competence in areas of changing technology.
Questions:
1.
List materials personnel and all of the training courses, workshops, seminars, symposia, etc. that your personnel have attended since the last review, and the source of the funding for the training (e.g., travel, per diem, tuition as applicable).
Copies of RHP training records are available in Region I files.
2.
Explain how new employees are trained.
New employees initially receive MDE's orientation on the overall responsibilities of the Department.
They are then given verbal and written organizational and sectional duties and responsibilities, followed by required review of regulatory requirements, inspection observations and detailed instructions prior to conducting inspections on their own.
They are scheduled for NRC and other courses as soon as those courses become available.
3.
If any of your RCP staff currently need NRC training, please identify the employees and the courses needed.
Robert Nelson, Francis Kasper and Douglas McAbee all need basic NRC five week Bealth Physics course and the Radiation Protection Inspection Procedures course.
E.
Staff Continuity (Category I')
l NRC Guidelines:
Staff turnover should be minimized by combinations of opportunities for training, promotions, and competitive salaries. Salary levels should be adequate to recruit and retain persons of appropriate professional qualifications.
Salaries should be comparable to
(
similar employment in the geographical area.
The RCP organization
'I mm--.
18 structure should be such that staff turnover is minimized and
(
program continuity maintained through opportunities for promotion.
Promotion opportunities should exist from junior level to senior level or supervisory positions. There also should be opportunity for periodic salary increases compatible with experience and responsibility.
Questions:
1.
Identify the RCP employees who have left the program since the last review and give the reasons for the turnovers. Also state whether the positions are presently vacant, filled (name re-placement), abolished or other status.
Richard Brisson, retirement Steve Stackhouse, dismissed 2.
List the RHP salary schedule:
Position Title Grade Annual Salary Ranoe Health Physicist I 9
$17,952 - $23,514 Health Physicist II 12
$22,360 - $29,362 Bealth Physicist III 13
$24,084 - $31,628 Public Health Radiation Specialist 16
$30,106 - $39,544 Program Admin. I 19
$37,923 - $49,814 Program Admin. II 20
$40,959 - $53,800 i
3.
Compare your salary schedule with similar employment alterna-tives in the same geographical area, such as industrial, medical, academic employers or other State agencies.
University of Haryland Health Physicists are also State employees but receive higher salaries, e.g.
j Position Title Grade Annual Salary Rance i
EP I 11
$20,772 - $27,262 HP II 12
$22,360 - $29,362 HP III 14
$25,937 - $34,075 HP IV 16
$30,106 - $39,544 HP V 17
$32,515 - $42,708 4.
Explain whether your salary schedule is adequate to recruit and retain staff.
Salary scale is not adequate to recruit Health Physics trained staff. A salary conversion proposal to upgrade current salaries is being redrafted.
5.
What opportunities are there for promotion within the RCP organizational structure without a staff vacancy occurring?
l i
l
19 The H.P. s'eries is interchangeable, and, with the appropriate j
time in grade, promotion can be effected.
Other positions
\\
require a vacancy.
V.
LICENSING A.
Technical Ouality of Licensine Actions (category I)
NRC Guidelines The RCP should assure that essential elements of applications have been submitted to the agency, and which meet cur-rent regulatory guidance for describing the isotopes and quantities to be used, qualifications of persons who will use material, faci-lities and equipment, and operating and emergency procedures suffi-cient to establish the basis for licensing actions. Prelicensing visits should be made for complex and major licensing actions.
Licenses should be clear, complete, and accurate as to isotopes, forms, quantities, authorized uses, and permissive or restrictive conditions. The RCP should have procedures for reviewing licenses prior to renewal to assure that supporting information in the file reflects the current scope of the licensed program.
Questions:
1.
a.
How many specific licenses are currently in ef fect?
516 b.
Please attach numerical totals of the licenses in each category.
Medical 164 Academic 60 Industrial 162 Civil Defense 1
Other 29 2.
a.
How many new licenses (not amendments in entirety) have been issued since the last review?
73 b.
How many were major licenses?
None 3.
List the specific licenses (name and licenso number) that were terminated since the last review?
94 See attached list 4.
How many amendments were issued during the review period?
846 5.
Identify unusual or complex licenses issued since the last review, including name and license number.
None 6.
Note any variance in licensing policies and procedures or exemptions from the regulations granted since the last review.
None I
20 Do you require licensees to subm'it contingency plans?
7.
a.
(
(
Reference:
All Agreement State and Non-Agreement State letter dated May 21, 1987, or NUREG-0767).
When the licensee's possession of limits of radioactive materials presents a potential for accidents that could-result in doses as stipulated in NRC's notice of proposed rule making published on June 3, 1981 (46 FR 29712).
b.
List the licensees (name and license number) who are subject to contingency plan requirements and the status of their plans (approved, under review, etc.).
Neutron Products, Inc.
Teruno Medical Products Dickerson, Maryland Elkton, Maryland License No. ND-31-025-01 License No.MD-15-007-02 8.
a.
What criteria does the State use to determine the need for a prelicensing visit?
A copy of the State's policy on prelicensing visits are available in Region I files.
b.
How many prelicensing visits were made during this review period?
6 Prelicensing visits.
9.
How do you ensure up-to-date information has been submitted prior to a license renewal?
We ensure up-to-date information by basing the renewal ou currently submitted information without referring to previous submissions. We ask the applicant to review and revise past submittals before resubmitting them.
10.
Has the RCP taken any unusual licensing action with respect to licensees operating under multiple jurisdiction?
No unusual licensing actions have been taken with respect to licensees operating under multiple jurisdiction.
11.
Prepare a table as below showing the RCP's major licensees with name, number and type.
INCLUDE:
Broad (Type A) Licenses LLW Disposal Licenses LLW Brokers Major Manufacturers and Distributors Uranium Mills Large Irradiators (Pool Type or Other)
Other Licenses With a Potential Significant Environmental Impact Other Licensees You Consider to be " Major" Licensees Name License Number Type Univ. of Maryland 07-014-01 Broad license Baltimore Campus
(
Johns Bopkins Medical 07-005-03 Broad license
21 Institutions Johns Hopkins Medical 07-005-10 Broad license Institutions Asthma / Allergy Sinal Hospital of Baltimore 07-011-01 Broad license Univ. of Maryland 33-004-01 Broad license college Park Univ. of Maryland 07-014-04 LLW Disposal Baltimore Campus (Incinerator)
Johns Hopkins Medical 07-005-06 LLW Disposal Institutions (Incinerator)
Radiation Services Org.
33-021-02 LLW Broker Neutron Products 31-025-03 Major Manufacturer (Sources)
& Distributor Pharmacia LKB Nuclear 31-071-01 Major Manufacturer
& Distributor Shimadzu 27-011-01 Major Manufacturer
& Distributor Data Measurement Corp.
31-008-01 Major Manufacturer
& Distributor Pharmacia ENI Diagnostics 27-025-02 Major Manufacturer
& Distributor Johnston Labs 05-025-01 Major Manufacturer
& Distributor GE Medical Systems 27-028-01 Major Manufacturer
& Distributor Syncor, Timonium, MD 05-058-01 Major Manufacturer
& Distributor syncor, Latham, MD 33-061-01 Major Manufacturer
& Distributor Terumo Medical Products 15-007-02 Large Irradiator Neutron Products, Inc.
31-025-04 Large Irradiator Neutron Products, Inc.
31-025-05 Large Irradiator Univ. of Maryland 33-004-03 Large Irradiator College Park Radiation Oncology 05-051-01 Affiliates Other (teletherapy, multi-facility)
B.
Adecuacy of Product EvaluaM m (Category I)
NRC Guidelines RCP evaluations of manufacturer's or distributor's data on sealed sources and devices outlined in NRC, State, or appropriate ANSI Guides,
{
should be sufficient to assure integrity and safety for users. The RCP should
32 review manufacturer's information in labels and brochures ralating to radiation j
(
health and safety, assay, and calibration procedures for adequacy. Approval documents for sealed source or device designs shoald be clear, complete and accurate as to isotopes, forms, quantities, uses, drawing identifications, and permissive or restrictive conditions.
Questions:
1.
List new and revised SS&D registrations of sealed sources and devicea issues during the review period?
LICENSEE BS& D Sheet Number Adaptive Technologies, Inc.
MD-113-D-101-0 l
MD-113-D-102-0 Neutron Products, Inc.
ND-474-S-109-S Nuclotron Corporation MD-497-D-102-S MD-497-D-105-S Pharmacia LKB Nuclear MD-541-D-101-0 l
2.
How many SS&D evaluations have been made for which registry documents have not yet been issued?
)
i None 3.
What guides and procedures are used to evaluate registry applications?
Our evaluation is based on engineering data submitted defining tests performed and results including dose profiles from sealed sources. Where it is determined that the staff does not have the competence to evaluate certain engineering data, the material is sent to the NRC with a request for technical assistance with that portion of the evaluation.
4.
Please describe the procedures for supervisory review of SS&D registrations.
All SS&D registrations are reviewed and signed by the Program Administrator II.
5.
a.
Do you have any pressing concerns about any sources / devices / products currently authorized for distribution including to persons either generally licensed or exempt from licensing?
No b.
If so, identify the items by manufacturer's name and model number and describe your concerns.
C.
Licensino Procedures (Category II)
NRC Guidelines: The RCP should have internal licensing guides, checklists, and policy memoranda consistent with current NRC practice. License applicants (including applicants for renewals) should be furnished copies of applicable guides and regulatory positions. The present compliance status of licensees should be considered in licensing actions. Under the NRC Exchange-of-Information program, evaluation sheets, service licenses, and licenses authorizing distribution to general licensees and persons exempt from licensing should be submitted to NRC on a timely basis. Standard license conditions comparable with current NRC standard license conditions should be used to expedite and provide uniformity in the licensing process.
Files should be i
23
. maintained in an orderly fashion to allow fast, accurate retrieval of-information and documentation of discussions and visits.
Questions:
1.
Are current NRC Regulatory Guides furnished to reviewers?
All NRC licensing guides are made available to the staff.
2.
Do your reviewers use the standard review plans, model licenses, etc.,
that are furnished in the NRC Fuel Cycle Policy and Guidance Directives FC xx-xx7 Checklists provided by the NRC are provided to the staff. Policy memoranda are provided to the staff.
3.
Are checklists used by the reviewers maintained in the files?
Yes 4
What internal licensing guides and procedures has the State developed?
None 5.
What licensing guides and regulatory positions are furnished to new and renewal license applicants?
Only those specifically requested.
6.
How do reviewers determine the present compliance status of licensees when considering licensing actions?
Reviewers detersine the compliance status of a licensee when planning an amendment or renewal by either looking at the most recent inspection or by direct conversation with enforcement personnel.
7.
For what length of time are licenses issued?
5 years 8.
Explain how soon-to-expire licenses are tracked to assure either timely applications are received or procedures initiated to terminate the license.
An expiration log is maintained for all licenses by month and year of expiration date so that an expiration notice can be sent out two months-before expiration.
9.
What mechanism exists to assure that SS&D registrations and service licenses issued by the State are distributed to the NRC7 Copies of SS&D sheets are sent to NRC Agressants State office and the cover page of each is sent to NRC NMSS office.
10.
Have you developed your own standard' license conditions, and if so, when were they reviewed and updated? Please provide copies for review.
Our list standard license conditions is based both on selection from the NRC list and our own needs.
11.
How do you verify that your standard conditions are comparable to the current NRC conditions?
f See 110
24 12.
How is your SS&D registry kept current?
our SS&D registry is filed in 36 - 2 inch, 3 ring binders. When we write a SS&D sheet and when we receive new sheets from NRC, we add them to the binders in proper sequence.
13.
Describe the system used to advise licensees of pertinent changes in regulations and regulatory procedures.
Changes in regulations are placed in the Maryland Register. Additionally, letters are sent to licensees.
14.
Describe your procedures for maintaining the license files (How are files and folders arranged? Are telephone contacts and visits documented? Who is responnible for filing materials in folders?).
All license files are maintained in a series of file cabinets accessible to both licensing and enforcement personnel. Current files are maintained alphabetically by licensee name and terminated files are kept in similar fashion. Telephone calls and on site visits are documented and filed by the person involved into the "back-up" section of the license file.
15.
Are there opportunities for license reviewers to accompany inspectors?
Yes VI.
COMPLIANCE A.
Status of Inspection Procram (Category I)
NRC Guidelines The State RCP should maintain an inspection program adequate to assess licensee compliance with State regulations and license conditions.
The RCP should maintain statistics which are adequate to permit Program Management to assess the status of the inspection program.on a periodic basis.
Information showing the number of inspections conducted, the number overdue, the length of time overdue and the priority categories should be readily available.
There should be at least semiannual inspection planning for the number of inspections to de performed, assignments to senior vs. junior staff, assignments to regions, identification of special needs and periodic status reports. When backlogs occur the program should develop and implement a plan to reduce the backlog. The plan should identify priorities for inspections and establish target dates and milestones for assessing progress.
Questionst 1.
How is statistical information maintained about the inspection program to permit periodic assessment of its status by RCP management?
Manually kept on a monthly schedule on a form titled " Overdue Inspection As of..... Date".
2.
Prepare a table as below, indicating the number of inspections made in the review period, by category and priority.
i
25
{
'. cense Scheduled Inspection Number of ategory Frequency Priority Inspections s
Major Processors Each J mos.
I 9
Broad Scope A, B, C Annually II, IV II-6 Each 3 yrs.
Each 4 yrs.
Irradiators Annually II, IV II-7 CAT IV Each 4 yrs.
IV-1 CAT I Radiography Annually II II-21 Academic Annually II, IV, V Each 4 yrs.
IV-6 Each 5 yrs.
V-2 Medical Each 3 yrs.
III, IV III-3 Each 4 yrs.
IV-49 Industrial Each 3 yrs.
III, IV, V II-l III-9 IV-56 V-93 Incinerators Each 3 yrs.
III 1,
Total 264 3.
Prepare a table (or tables) as below which identifies the Priority 1, 2, and 3 licensees with overdue inspections. Include the license category, the due date, and the number of months the inspection is overdue.
(If list is extensive, a comparable computer printout is acceptable.) The list should include initial inspections that are overdue.
Overdue as of February 28, 1991 - 19 EER Overdue Completed Priority I
- None Priority II - ATEC Associates 2/91 (1) month 3/91 Priority III - BD Immunodiagnostic Ctr. 1/91 (2) months 4.
Prepare a table as below indicating the total number of overdue license inspections for all lower priorities.
Priority IV - 57 Priority V - 30 5.
If there are overdue inspections, describe or attach a copy of your plan for eliminating it.
Identify priorities, target dates and procedures for measuring progress.
Include, as appropriate, copies of memoranda to the RCP staff regarding the plan.
Overdue Inspection Plan The Radiological Health Program's (REP) inspection and enforcement plan to reduce and/or eliminate the backlog is as follows:
Continue to inspect Priorities I, II and III at their regular a.
frequency with no backlog.
f
l 26 4
b.
Concentrate ~ REP's ef forts over the 'next twenty-four (24) months on Priority IV inspections, especially on medical programs (hospital and privates). Currently, there are 11 overdue medical programs of which 25 are hospitals. These ' efforts can be accomplished if t (1) One senior inspector can substantially reduce his overall weekly work schedule of greater than 60% to Neutron Products, Inc.'and thereby his resumption of the normal 5 monthly inspections.
(2) Another inspector having limited experience in the radiation program can be trained to perform material inspections of
- medical programs, in particular, smaller private practice programs.
(3) The newest materials inspector can be trained over the next i
three (3) months to perform Priority V inspections.
i 6.
Project the number of inspections needed to be done annually to meet your j
inspection priorities and to eliminate your overdue, if any.
1986 - 131; 1987 - 174; 1988 - 110; 1989 - 101; 1990 - 143 Projection of inspections - 175/yr. or 34% of total licenses, All j
7.
How are inspection schedules planned and how are the dates and personnel assignments made?
Senior staff inspection assignments are scheduled by the supervisor of the.
radioactive materials section. These assignments are normally based upon y
priority and due or maximum overdue dates. The exception to this practice 1s when a license is located so far away from.the central office that the inspector must stay overnight.
In this case, the cost effective practice
{
is for the inspector to inspect several or maybe all of the licensees in that region.
l Junior staff inspection assignments are scheduled as stated above except that the assignments are limited to include the lower priority licenses.
NO CHANGE l
8.
How are initial inspections identified when they become overdue?
Cardex system and statistical logbook, 9.
a.
Describe your inspection priorities for inspecting terminated licenses.
Licensees are required to notify RHP, in writing, no later than 30 days in advance before they vacate the premises or those areas where radioactive materials are used. Once the licenses submits a close-out survey to the REP, indicating that the area / facility is free from all sources of radiation, the REP may either release the facility based in the submission or schedule an independent survey.
No facility will be released until the licensee meets the criteria for release.
b.
How many of these inspections are pending at this time?
NONE c.
How many were inspected since the last review?
j 38
--"5
-7 c:
-Y-'F vy-m-2 y
'Y y
q m
e 3-tr-e+=m w
tn-er
-e g
r-"f eN w
w-T* - *
- ='
37 10.
a.
How many reciprocity notices were received in the review period?
212 Initial notices b.
How many reciprocity inspections were conducted in the review period?
21 11.
How many field inspections of radiographers were performed in the review period?
9 B.
Igepection Frecuency (Category I)
NRC Guidelines The RCP should establish an inspection priority systom. The specific frequency of inspections should be based upon the potential haterds of licensed operations, e.g., major processors, broad licensees, and industrial radiographers should be inspected approximately annually -- smaller oc less hazardous operations may be inspected less frequently. The minimum inspection frequency should be consistent with the NRC system.
Questions:
1.
Please attach a copy of the RCP's inspection priority system.
A copy of the State's priority system is available in Region I files.
2.
How are inspection priorities assigned to licenses?
Hr. Carl Trump, RAN Inspection & Surveillance Section Chief assigns inspection priorities.
3.
Is the priority noted in the license file?
Yes 4.
Discuss any variances in the State's priorities from the NRC priority system and the reasons for the variances..
As a matter of practice we inspect fixed radiography licenses and limited medical licenses at the minimum inspection frequency consistent with the NRC.
However, due to other staff work, we have been unable to rewrite the written inspection priority system so that it reflects actual State policy.
However, REP has inspected certain MD licenses more frequently depending on the nature and hasard of the license, compliance history, and if the license has actually initiated a RAM program.
5.
Describe the RCP's policy for unannounced inspections and exceptions to the policy.
All radioactive materials license inspection are unannounced except in a few cases where the licensee maintains several locations in different counties and the RSO may be at any location.
6.
Describe the RCP's policy for conducting follow-up inspections.
Follow-up inspections are not done routinely due to insufficient manpower.
However, since the inspection backlog has decreased, RHP has been conducting follow-up inspections on a case-by-case basis.
7.
Identify any individual licensees or groups of licenses for which the j,
State is inspecting more frequently due to compliance problems.
Please discuss the nature of those problems.
28 Neutron Products, Inc. (NPI) MD-31-025-01.
Normal inspection frequency is
,/
quarterly. Licensee has not corrected deficiencies identified in the
\\
progras dating back to the issuance of license amendment 33 dated May 23, 1989.
C.
Inspector's Performance and Caoability (Category I)
NRC Guideliness Inspectors should be competent to evaluate health and safety problems and to determine compliance with State regulations.
Inspectors must demonstrate to supervision an understanding of regulations, inspection guides, and policies prior to independently conducting inspections.
The compliance supervisor (may be RCP manager) should conduct annual field evaluations of each inspector to assess performance and assure application of appropriate and consistent policies and guides.
Questions:
1.
How do new inspectors become qualifies to conduct independent inspections since the last review?
New/ untrained inspectors accompany senior inspectors on routine inspections, close-out surveys and investigations, as time permit. During this time one-on-one training is given to new personnel by senior inspectors. Additionally, the Section Chief conducts an inspection with the new inspector, and the Section Chief will accompany the newer inspector during a scheduled inspection. Therefore, based on the supervisory accompaniments, input from the inspection staff, and further discussions with the new inspector, these factors will greatly determine whether or not independent inspections can be conducted.
2.
Prepare a table showing the number and types of supervisory accompaniments made during the review period.
Include:
supervisor Inspector License Catecorv Date Carl Trump Steve Stackhouse V
2/24/89 Carl Trump Steve Stackhouse V
7/5/89 Carl Trump Steve Stackhouse V
7/27/89 Carl Trump Ray Manley I
9/28-29/89 Carl Trump Ray Manley/ Alan Jacobson I
1/12,16,18/90 Carl Trump Nat Owrutsky V
3/23/90 Carl Trump Ray Manley I
4/23/90 Carl Trump Nat Owrutsky IV 10/4/90 Carl Trump Bob Nelson V
10/25/90 Carl Trump Nat Dwrutsky IV 10/30/90 Carl Trump Nat owrutsky IV 10/31/90 Ray Manley Steve Stackhouse V
8/4/89 Ray Manley Steve Stackhouse V
8/23/89 Alan Jacobson Steve Stackhouse V
7/7/89 Alan Jacobson Steve stackhouse v
8/30/S9 3.
Did all inspectors receive at least one accompantment by the compliance supervisor during the review period? If no, explain.
YES D.
Pesponses to Incidents and Alleoed Inci1ents (Category I)
NRC Guidelines Inquiries should be promptly made to evaluate the need for onsite investigations. Onsite investigations should be promptly made of incidents requiring reporting to the Agency in less than 30 days (10 CFR 20.403 types).
For those incidents not requiring reporting to the Agency in less than 30 days, investigations should be made during the next scheduled inspection, g
Onsite investigations should be promptly made of non-reportable incidents which i
i
29 may be of significant public interest and concern, e.g. transportation
/
accidents.
Investigations should include indepth reviews of circumstances and 1
should be completed on a high priority basis. When appropriate, investigations should include reenactments and time-study measurements (normally within a few days).
Investigation (or inspection) results should be documented and enforcement action taken when appropriate. State licensees and the NRC should be notified of pertinent information about any incident which could be relevant to other licensed operations (e.g., equipment failure, improper operating procedures).
Information on incidents involving failure of equipment should be provided to the agency responsible for evaluation of the device for an assessment of possible generic design deficiency. The RCP should have access to medical consultants when needed to diagnese or treat radiation injuries.
The RCP should use other technical consultants for special problems when needed.
Special Note:
The criteria for reporting radioactive materiale events are set out in All Agreement States letter form D. Nussbaumer dated July 22, 1986:
Abnormal occurrences: These are the most significant events.
In addition to an early telephone notification to the regional office, a written report from the State is needed for inclusion in the Quarterly Report submitted by NRC to Congress (AOR).
Criteria for reporting and guidance on content of reports can be found in any AOR.
Telephone Reports:
These are events for which NRC would like to receive early telephone notification. Typically, these include incidents requiring prompt of 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> notification by licensees to States or events that receive significant media attention.
Other Reportable Incidents: These are events for which reports are j
required of the licensees to the State.
Questions:
1.
What criteria are used to determine the need for and timeliness of on-site inspections of reported incidents?
Where we can assess that it is a true incident, we respond immediately.
On other as promptly as possible.
For alleged incidents written notification is required as per Part J. of the Regulations before an*;
response is made.
2.
How many reports of incidents and alleged incidents were received during the review period?
1989 - (31) 1991 (2 months)
(6) 15 1990 - (41) 3.
How many on-site inspections of incidents were conducted during the period?
78 4.
How many inspections 01 incidents revealed an incident occurred which required NRC notification, either by telephone or by written report?
(Refer to July 22, 1986 All Agreement State letter for definition.
20 5.
Please have summaries of the events identified in questions 2 and 4 above.
Use the incident summary forms attached for this purpose.
j SEE ATTACHMENTS
30 6.
If not included in the response to question 5 above please attach a
(
summary of reports of leaking sealed sources.
Please identify the sources.
Please identify the source by manufacturer, model number, age of source (if available), date of leak test and leak test result.
SEE ATTACEMENT a.
University of Maryland - College Park curium - 244, 500 pci 7.
Did any incidents involve equipment or source failure or operating procedures that were deficient but were approved? If so, how and when-were State licensees and the NRC notified of pertinent information relevant to other licensed operations?
No 8.
Was information on incidents involving failure of equipment or sources provided to the agency responsible for evaluation of the device for an assessment of possible generic design deficiency? Please provide details.
(Refer to CTI Consultants, Inc. Incident)
The cesium-137 sealed source broke off at the weld joint unknowingly to the licensee.
Source was not recovered.
Troxler Electronics, Inc. of North Carolina was notified of this incident by their Maryland office and the RHP.
Upon visual inspection by their technical staf f and state of North Carolina's inspector, Troxler denied there was a flaw in the weld and gave evidence that gauge was struck with a heavy object that may have caused the source capsule to break away from the source rod.
9.
If the RCP utilized medical or technical consultants for an emergency during the review period, please describe the circumstances.
NONE 10.
Describe the procedures for looking into allegations or other reports of possible wrong doing by licensees, for example, It is the REP's position that the allegation is put in writing, if possible, with any copy of records, etc.
Protecting the identity of allegers or persons requesting that their a.
identities not be made available for public disclosure.
Guidance in these situations is provided by the Attorney General's Office.
I b.
Obtaining documentation (e.g., signed statements, copies of records).
Guidance in these situations is provided by the Attorney General's Office.
Obtaining the services of persons with specialized training and c.
experience such as conducting and documenting formal interviews.
Nedical and professional consultation services are initially sought from Medical and Radiation Control Advisory Boards. Guidance in other situations is provided by the Attorney General's Office.
d.
Obtaining necessary legal counsel for inquires into wrong
{
doing.
i
31 o
Guidance i'n these situstions is provided by the Attorney General's Office.
Guidance for staff when allegations or inspections disclose the e.
possibility of willful violations of regulatory requirements or other evidence of criminal wrong doing.
Guidsuce in these situations is provided by the Attorney General's Office.
Please attach copies of these procedures.
11.
In the review period, are there any cases involving possible criminal wrong doing that were looked into or are presently undergoing review?
No E.
Enforcement Procedurea (Category I)
NRC Guidelines Enforcement Procedures should be sufficient to provide a substantial deterrent to licensee noncompliance with regulatory requirements.
Provisions for the levying of monetary penalties are recommended.
Enforcement letters should be issued within 30 dvre following inspections and should employ appropriate regulatory language clear:
specifying all items of noncompliance and health and safety matters identified during the inspection and referencing the appropriate regulation or license condition being violated.
Enforcement letters should specify the ti.me period for the licensee to respond indicating corrective actions and actions taken to prevent recurrence (normally 20-30 days). The inspector and compliance supervisor should review licensee responses.
Licensee responses to enforcement letters should be promptly acknowledged as to adequacy and resolution of previously unresolsed items. Written procedures should exist for handling escalated enforcement cases of varying degrees.
Impounding of material should be in accordance with State administrative procedures. Opportunity for hearings should be provided to assure impartial administration of the radiation control program.
Questions:
1.
What enforcement measures are available to the State to provide a deterrent to licensee noncompliance with regulations or license provisions?
a.
Enforcement conference at MDE-RHP b.
Modification Revocation and/or Termination of the License c.
Administrative / civil penalties 2.
Are there written procedures establishing severity levels for violators?
Please attach a copy.
copies of this document are available in Region I files.
3.
Are there written procedures for escalated enforcement? Please attach a copy.
Copies of this document are available in Region I files.
4.
If the RCP can apply civil penalties, have procedures been established to i
determine when they apply and the amounts? Please attach a copy.
-l Copies of this document are available in Region I files.
i
c 32 5.
Describe the State's provisions for criminal penalties.
state's provisions for criminal penalties. Determined by the Attorney General's office upon referral for criminal investigation.
6.
Are enforcement letters issued within 30 days following inspections?
Routine letters mostly fall within the period a.
b.
Letters including civil oenalties must be reviewed by the Attorney General's office.
7.
Do you have a standard format for enforcement letters?
YES 8.
How are recommendations differentiated from items of non-compliance in the letters?
Any items not listed as items of noncompliance are usually listed as Issues of Concern or so identified in the letter.
Do the' letters reference the appropriate regulation or license condition 9.
being violated?
YES 10.
What time period is specified in the enforcement letters for the licensee to respond with corrective actions taken?
Normally - 20 days 11.
Do inspectors write enforcement letters? If so, do the letters undergo supervisory review before they are sent to the licensee?
a.
YES b.
YES, letters are received by Section Head and Director of REP prior to licensee mailing 12.
Who reviews licensee responses?
Both inspector and Section Head 13.
What is the time limit for the State's acknowledgement of licensee responses and what tracking system exists for assuring resolution of the items of non-compliance and unresolved items?
No specific time limit for acknowledgement of licensee responses currently exists, since all compliance letters are sent CERTIFIED MAIL, it is the inspector's responsibility to track the response letter in a reasonable time frame. Telephone communication is the most expeditious means of acknowledging licensee responses. Follow-up letters are sometimes sent to the licensee.
14.
Does the State have the authority to impound radioactive material?
YES 15.
Can the State issue orders, including Emergency orders?
YES
33 o
16.
Do State administrative procedures permit the opportunity for hearings in major enforcement cases?
YES 17.
Describe the State's policy for conducting follow-up inspect. ions.
Follow-up inspections can be conducted anytime, but especially to assess licensee corrective action as a result of violation notice and/or escalated enforcement actions.
18.
If during the review period the State has issued orders, applied civil penalties, sought criminal penalties, impounded sources, or held formal enforcement hearings, identify these cases and attach a summary of the circumstances and results.
See Attachment 19.
Have any compliance problems occurred involving licensees operating under multiple jurisdiction or under reciprocity? If so, please identify the licenses and explain if other Agreement States and NRC were advised.
Any compliance problems involving licensees operating under multiple jurisdiction or under reciprocity?
Yes, TN (Texas. Nuclear) visited GAF in Baltimore in December, 1990 performed transfer / shipment of gauge without verification. Compliance letter was sent to Texas Nuclear.
F.
Inspection Procedures (Category II)
NRC Guidelines:
Inspection guides, consistent with current NRC guidance, should be used by inspectors to assure uniform and complete inspection practices and provide technical guidance'in the inspection of licensed programs. NRC Guides may be used if properly supplemented by policy memoranda, agency interpretations, etc.
Written inspection policies should be issued to i
establish a policy for conducting unannounced inspections,-obtaining corrective action, following up and closing out previous violations, interviewing workers and observing operations, assuring exit interviews with management, and issuing appropriate notification of violations of health and safety problems.
Procedures should be established for maintaining licensees compliance histories.
Oral briefing of supervision or the senior inspector should be performed upon return from nonroutine inspections.
Fer States with separate l
i licensing and inspection staffs, procedures should be established for feedback of information to license reviewers.
)
Questions:
4 1.
Do you use inspection guides that are specific to categories of licensnes?
YES 2.
Has the RCP developed its own inspection guides or does it use NRC. guides?
Uses NRC guides 3.
Discuss the use of inspection policy memoranda, interpretations, etc., to supplement inspection guides.
Whenever additional /new NRC memorandums are sent to Naryland's REP, there is-a discussion before implementation If possible, staff comments are s
distributed and acknowledged by all Radioactive Material. inspection and licensing staff.
I 1
4.
Are there written policies and procedures for i
~,
..u
_~
~
P 34 a.
unannounced inspections?
YES b.
obtaining corrective action?-
YES c.
following-up and closing out previous citations of violations?
YES d.
interviewing workers?
YES e.
observing operations?
YES f.
exit interviews with management?
Yks g.
issuing notices of violations and findings of health and safety problems?
YES Please have copies of these procedures available for the reviewer.
5.
Describe the procedures for maintaining licensee's compliance histories.
a.
License Files b.
Cardex Files 6.
Explain your policy for supervisors debriefing inspectors upon return from inspections.
It is customary for inspectors-to discuss their current inspections with RAM Inspection Chief especially when there are a number of items of N/C or t
significant, stand-out items of N/C are found. Inspector may call REP for further guidance.
7.
What procedures are there for providing feedback of compliance information to licensing?
It is a standing REP procedure that licensing be informed when ever compliance actions are initiated against a licensee.
G.
IneDection ReDorts (Category II)
NRC Guidelines Findings of inspections should be documented in a report describing the scope of inspections, substantiating all-items of noncompliance and health and safety matters, describing the scope of licensees' programs, and indicating the substance of discussions with licensee management and licensee's response.- Reports should uniformly'and adequately document the results of inspections and identify areas of the licensee's program which should receive special attention at the next inspection. Reports should show the. status of previous noncompliance and the independent physical measurements made by the inspector.
'j-
.?
35 Questions:
1.
Describe the format (s) used by the RCP'for documenting inspections.
5-page report for all inspections except for industrial radiography -a unique ll-page report.
2.
Do the reports documents the entrance and exit discussions held with license management? YES a.
b.
follow-up of previous citations of violations? YES c.
results of interviews of workers? YES d.
results of observations of operations? YES confirmatory measurements conducted by the inspector? YES e.
f.
areas of the licensee's program needing special attention at the next inspection? YES g.
the items of non-compliance found in the inspection? YES H.
Confirmatory Heasurements (Category II)
NRC Guidelines Confirmatory measurements should be sufficiert in number and type to ensure the licensee's control of materials and to vals ' ate the licensees measurements. RCP instrumentation should be adequate for surveying license operations (e.g., survey meters, air samplers, lab counting equipment for smears, identification of isotopes, etc.).
RCP instrumentation should include the following types:
CH Survey Heter:
0-50 mr/hr Ion Chamber Survey Heter: up to several R/hr Neutron Survey Heter Fast & Thermal Alpha Survey Heter:
0-100,000 c/m Air Samplers: Hi and Low Volume Lab Counters:
Detect 0.001 uci/ wipe velometers Smoke tubes Lapel Air Samplers Instrument calibration services or facilities should be readily available and appropriate for instrumentation used. Licensee equipment and f acilities should not be used unless under a service contract. Exceptions for other State Agencies, e.g. a State University, may be made. Agency instruments should be calibrated at intervals not greater than that required to licensees being inspected.
Questions:
1.
Discuss the State's policy for conducting confirmatory measurements as a part of each inspection (e.g., air samples, wipe samples, air flows, dose rates),
i f
confirmatory measurements are taken in accordance with the license ^ that is inspected. But untimely, dose rate, count rate and wipe sampling is performed.
1 2..
List the equipment that is readily available to the RCP for surveying licensed operations and conducting appropriate-confirmatory measurements.
f-t 1
l
36-
.i Equipment used - GM survey meters, ion chamber, scintillation detectors, air samplers, velometers, filter wipes-3.
Describe the method ussd for calibrating survey instruments and the frequency of calibration.
Noters are calibrated by Radiation Service Organisation in Laurel, Md.
Frequency can be quarterly, semi-annual and annual depending on the frequency of the license that is inspected.
)
l VII.'OTHER ASPECTS OF THE STATE'S RADIATION CONTROL PROGRAM A.
Non-Acreement Sources of Radiation Questions:
1.
Are the licensing and inspection procedures for NARM the same as for agreement materials?
YES B.
Environmental Monitorino Procram Questions:
1.
To indicate the scope of the environmental monitoring programn undertaken specifically to evaluate the environmental radiological impacts of State licensed facilities describes a.
the licensee (name, license number and type of operation)
NPI b.
types of media sampled Water, soil, TLD's posted, wipe sampling c.
the number and locations of stations sampled Number and locations sampled d.
the frequency of sample collection No exact frequency e.
the analyses run on each type of sample Gross B; Gross alpha 2.
How is such data used in your licensing and inspection programs for these State licenses?
Placed in licensee's file Please attach copies of any summaries or periodic reports relating to this aspect of your environmental surveillance program.
C.
Other Area.g This section of the review is for the use of either the reviewer or the RCP to address issues pertaining only to the individual State,.to new areas of concern, or to generic or State-specific issues raised by NRC staff.
Questions:
37 1.
Have there been any applications or approvals for incineration, compacting
(
or for methods of LLW disposal not provided for in the regulations (i.e.,
10 CFR 20.302 requests)? If so, please list the applicant and nature of application and status.
see licensing 2.
Is the State making any effort during jaspections of nuclear pharmacies to observe the licensee conducting the re'guired molybdenum breakthrough
- tests, i.e.,
what is the State doing 1.n addition to record reviews to establish compliance or noncompliance with the requirement?
During the entire inspection, the in spectors are asked to observe the moly
- breakthrough if licensees are still using generators.
3a.
Is the State mounting any special effort to look at the possibility of reconcentration of radionuclides in sanitary sewers and sewerage treatment plants as part of the regular inspection program?
If so, please describe.
No b.
If reconcentration of radionuclides in sanitary sewers or sewerage treatment plants has been found, please identify the site and licensee.
N/A 4.
How does the RCP handle inspection findings concerning industrial safety hazards? (Reference A/S letter dated January 18, 1989.)
Refer them to MOSHA and/or hazardous and solid waste Administration of HDE.
Sa.
3M has reported not all of their customers returned static eliminators that were subject to recall. Are you aware of this?
YES, I have heard this to be true.
b.
If such customers were located in your State, please provide a summary of any actions taken by the RCP to locate the users, etc. (Note:
We recognize that by this date the Po-210 has significantly decayed and reduced the potential hazard. The information is requested because of its relevance to the question of maintaining a system to adequately account for GL devices.)
A listing must be provided to the REP before contact is made with these customers.
38 INCIDENT REPORTING CHECK LIST 1.
Type of Incident or Alleged Incident:
3.
Was an investigation conducted by your staff?
Date Initiated:
3.
Did the investigation reveals (check all appropriate blocks)
[
] Loss of package effectiveness or contamination?
[
] Theft or loss of licensed material?
[
} Overexposure of individual to radiation or radioactive material?
(
) Excessive' levels of radiation or concentrations of RAH 7
[
} Safety failure of GL devices?
[
] Equipment failure that could occur on similar licensed devices?
[
] Leaking source?
[
] Hisadministration?
[
} Transportation incident?
[
] Uranium mill occurrence?
[
] Possible criminal violations?
If any boxes are check,ed or if the event is newsworthy, review the criteria for telephone reporting Agreement State Materials Events to the NRC Regional Office (see All Agreement State letter dated July 22, 1986 and December 23, 1988). A description of the incident should he summarized as follows for the next NRC review. (Use extra sheets if necessary.)
SUMMARY
OF EVENT Licenseet License No.:
Location of events Description of event:
Isotooe Amounts Dates Date of Report to RCP:
Identify any other licensees involved:
Licensee:
License No.
Jurisdictions Reciprocity Licensee Y /N I
Describe clean-up actions taken the RCP7 What radiation measurements were taken by the RCP7 What other action was required of the RCP7 What action was taken to notify the NRC, other Agreement States or licensees?
Is the case closed?
Is record of incident in RAM files?
What enforcement action was taken?
~~
NAME OF PERSON PREPARING THIS
SUMMARY
DATE k
39 TTACHMENT
- 18 m.
ORDERS 1.
Neutron Products, Inc. (NPI) ORDER TO STOP, dated 10/10/89 (SEE ATTACHMENT) b.
ENFORCEMENT CONFERENCES 1.
HEI, MD-31-025-01, on 3/8/89 Meeting concerned the " shutdown" and modification of license 2.
Sacred Heat Hospital, MD-01-002-01, on 10/19/89 Heeting concerned medical therapeutic misadministrations of October 1988.
Result was a MDE-RHP OONSENT AGREEMENT and a $9,500 civil penalty.
3.
SCM Chemicals, Inc., MD-07-038-01, on 11/2/89 Heeting concerned RAM inspection and resulted in $2,500 civil penalty.
4.
Chem Alysis, Inc., MD-27-042-01, on 12/14/89 Heeting concerned licensee's failure to notify REP of vacating premises and to operate at a new location.
Result was a $1750 civil penalty.
5.
Hector Collison, MD, e)n 12/15/89 Dr. Collison, a nuclear medicine physician, split from his partnership with Dr. Christian Chinwuba at a Silver Spring office.
Dr. Collison practiced at location without processing a specific license. Result was a S2,500 civil penalty.
6.
Christian Chinwuba, MD, MD-31-182-01 and MD-33-100-01, on 1/22/90.
Meeting concerned his failure to notify RHP of his intent to split the partnership with Dr. Collison in Silver Spring that, in part, led to Dr. Collison's situation. Additionally, both programs under his licenses were sul-par. Result was $4,500 civil penalty.
7.
ImmuOuest Labs, Inc., MD-31-124-01, on 2/8/90.
Meeting concerned his vacating premises without notifying the RHP, and also left behind three (3) 55-gallon drums of radioactive waste.
Result was a $5,000 civil penalty. A letter of appeal to the RHP was denied. Only payment made was $500 in August, 1990.
RHP-licensee remain in communication with licensee's promise to pay balance of penalty.
f ENCLOSURE 2 REVIEWER EXPLANATORY COMMENTS 1.
LEGISLATION AND REGULATIONS A.
Legal Authority During the course of the review, the NRC representative had an opportunity to meet with Maryland Department of the Environment (MDE) representatives from the Attorney General's Office concerning the status of the low-level waste regulations. These regulation come under thejurisdiction of the Hazardous and Solid Waste Management Administration and the legislation covering the regulation oflow-level waste contains a definition oflow-level waste which is not consistent with the current definition from the Low-Level Policy Amendments Act, i.e. it excludes transuranics. The MDE legal staff was informed that in order to maintain compatibility with NRC requirements, the definition of low-level waste would need to be compatible with the definition in the Amendments Act. The MDE staff indicated that this would probably require an amendment to the legislation.
)
B.
Status and Compatibility of Regulations The State has not yet adopted the waste classification and manifesting provisions from Parts 20 and 61. The Department has been working on low-level waste disposal regulations which would address these requirements as well as other provisions of Part 61 related to siting and operation of a disposal facility. NRC has reviewed an early draft and provided comments on these proposed amendments. in tne discussions with MDE legal staff, the reviewer provided information on the specific requirements to maintain compatibility with NRC requirements. Since Maryland is not currently a designated host State, only the waste classification and manifesting requirements are a matter of compatibility, it was suggested that the State may wish to hold off promulgating regulations in the area of facility siting and operations until such time as the State may be disignated a possible host State. The legislation, however, also requires MDE to establish certain requirements for low-level waste storage facilities. The State may need to be selective as to what provisions are deleted so that the regulations cover the appropriate areas for waste storage.
There are a number of other changes to NRC regulations which the State has not adopted within the 3 year time frame. These include the revisions to the transportation regulations, the elimination of the exemption for glass enamel frit, changes to the regulations governing industrial radiography, the bankruptcy
notification requirement, medical misadministration reporting, well logging c
(
requirements and the NVLAP certification of dosimetry processors.
IV.
PERSONNEL B.
Staffing Level In the State's calculation of staffing level, they excluded the effort devoted to the regulation of Neutron Products, approximately 1.5 FTE. The State believes that the inclusion of this staff effort does not accurately portray the staffing situation in Maryland. In terms of applying the 1.0 to 1.5 str.ff-years per 100 licenses guideline, there is no provision for allowing the exception for any type oflicensee other than uranium mills and low-level waste disposal facilities. Maryland's total staffing level is 9.1 FTE. With 516 licenses in effect, the staffing level is 1.76 staff-years per 100 licenses. The problem, however, has been that with staff turnover and the inability to recruit adequately trained staff, the workload for experienced staffis quite high. In addition, over the past two years, the State has experienced a large number of terminations (38) due to the imposition of fees, a large inspection effort in the area of reciprocity (240 notices and 21 inspections),
and 78 incident investigations.
On a percentage basis, this is the largest reciprocity inspection effort of any Agreement State in the Region.
D.
Training As mentioned above, the State has not been able to recruit adequately trained individuals into the program, so training is a high priority for the State. In addition, the RCP has experienced some trouble in getting State approval to send staff to NRC-sponsored training courses. The State Department of Personnel must approve all out-of-State travel, whether paid for by the State or not. This issue was discussed with the. Secretary of the Department and hopefully future problems will be minimized. Currently, the most critical need is for new staff to attend the five-week health physics course.
E.
Staff Continuity Staff salaries continue to be a problem. During the previous review, this problem was discussed and at that time the Department had a plan to upgrade all salaries for the program. However, only a portion of the plan was approved, providing upgrades for the program supervisors to level I Program Administrators. The
)
main problem is still entrance level salaries, which are the lowest in the region.
Even other State agencies (e.g. University of Maryland) have higher staring level i
salaries than MDE. Secretary Perciasepe reports that the proble is Department-wide and that he is preparing a package for submittal to the Department of Personnel which proposes upgrades for a number of job categories in the Department. He assured the reviewer that the Health Physicist series would be a part of that proposal.
V.
LICENSING A.
Technical Ocality of Licensine Actions During the revi:w,14 license files were reviewed. See Enclosure 3. For the most part license action were found to be adequate.
B.
Adecuacy of Product Evaluations Adaptive Technologies, Inc. is a manufacturer of beta thichness gauges. The State reviewed and approved two new gauges during the review period. The gauges were approved for krypton and strontium sources. However, in reviewing the manufacturer's documentation, it became evident that the gauges were also being offered with promethium as well as other sources. During the initial inspection of the licensee, the inspector verified that gauges with promethium sources had been distributed. This was authorized by the specific license issaed by Maryland but not noted on the SS & D registration. It was recommend that revised registrations be issued to cover all sources currently being distributed.
VI.
COMPLIANCE A.
Status of Inspection Program As of the time of the revisv, there were 89 licenses overdue for inspection. One in Priority II, overdue by 1 month; one in Priority III, overdue by 2 months; and 57 in Priority IV; and 30 in Priority V. For the Priority IV and V licenses, none were overdue by significant periods of time, most have come due during the latter half of 1990. The staff has worked out a detailed plan to address the backlog, but due to expected workload and the training of new staff, the plan does not envision elimination of the backlog until around the end of 1992. There is a significant amount of reciprocity work done in the State of Maryland. Since the last review, the State received 240 initial notices of reciprocity work. During this same period the State performed 21 reciprocity inspections. This is significantly higher than that reported by other Agreement State in Region I.
B.
Inspection Frecuency The State's inspection priority system has not changed in a number of years. Au examples of differences between the State and NRC, medical licensees, including teletherapy, are in Priority III and IV inspected 3 to 4 years. Broad medicals are Priority II as are other broad licenses and are inspected annually which is more frequent than NRC. The State would need to make a number of changes to its priority system in order to be compatible with the April 1990 changes to the NRC priority system. The State believes that this would have a significant impact on the State's workload and therefore they have not made a commitment to the
i i
)
changes yet. Tlie reviewer encouraged the State to respond to the All Agreement
(
States letter dated December 27,1990 on this subject.
C.
Inspector's Performance and Caoability During the review three RCP inspectors were accompanied on routine materials inspections. On March 19,1991, Alan Jacobson was accompanied on a regular unannounced inspection of Franklin Square Hospital. This is a fairly large nuclear medicine program including brachytherapy. On March 20,1991, Ray manley was accompanied on a regular unannounced inspection of Harford Memorial Hospital.
This is a small nuclear medicine program limited to diagnostic studies. On March 21, 1991, Robert Nelson was accompanied on a regular unannounced inspection of Data Measurement Corporation.
Data Measurements is a manufacturer and distributor of generally licensed beta gauges.
All three inspectors were professional in their approach to the inspections, were generally well prepared for the inspections and carried out appropiate interviews with all levels of licensee staff, record reviews and independent measurements.
It was recommended that Mr. Jacobson focus his inspection more on observing licensee operations. Both Messrs. Jacobson and Manley had scheduled two days for their inspections.
Both inspection were completed in one day and the reviewer felt that any further time spent at these licensed facilities would not have been an ef6cient use of staff time. Mr. Nelson is a new inspector and, in the reviewer's opinion was not quite ready to inspect a program of the nature of Data Measurements. The licensee had expanded since the last inspection, and although not a complex program, presented some interesting questions requiring a good background in radiation protection and the general license provisions of the regulations. Mr. Nelson is scheduled to go to the NRC inspection procedures course soon, and it was recommended that he attend the 5-week health physics course in the near future.
D.
Responses to incidents and Alleged Incidents For reasons the State staff could not explain, the State continues to respond to a large number of " incidents". These can involve anything from a empty labeled container in a landfill to a Co-60 ingestion at Neutron Products. 78 incidents were reported during the review period. Twenty incident files were reviewed and it is the reviewers opinion that the State performs an admirable job in the area of incident response. All alleged incidents are responded to on-site and a report prepared. Those involving licensees are address through enforcement actions or in some other manner followed-up with the licensee.
E.
Enforcement Proceduas As a result of the last two reviews, NRC commented on the need for the State to document its escalated enforcement procedures.
Since the last review the i
Department has drafted, and is using, escalated enforcement procedures which
l address the concerns expressed during past reviews. The Department plans to
(
formalize the procedures by incorporating them into the Department's radiation control regulations in the near future.
The State is involved in a lengthly enforcement action against Neutron Products at the present time. This action can be traced back to early 1989 and concerrs the apparent inability of NPI to keep contamination from getting off-site. A short chronology of events from 1989 to the present is attached to this report. One highlight of the events was the issuance on May 23,1989 of amendment 33 to the NPI license which required NPI to do a number of things to improve the radiation protection program. Since that time, NPI has failed to meet a number of deadlines for compliance and addition problems have been noted during State inspection which have been conducted in the interim.
During the most recent inspection (January 1991), the State found numerous and repetitive violations and concluded that management oversight was still not adequate to maintain radiation safety. NPI was cited foi failure to remove waste from an unauthorized off-site storage location (this was originally cited in October 1990), failure to conduct surveys in the Limited Access Area (LAA), failure to remove contaiminated soil (previously cited), failure to implement a management audit program, failure to restrict access to radiation areas, and other items. The State indicated that these items represented a situation which was " extremely unsafe and indisputably irresponsible." In addition, the State had a number of other concern about the facility. The total man-rem for the facility has been increasing over the past couple of years, Co-60 contamination continues to be found in unrestricted areas, there is a lack of RSO oversight of environmental and facility surveys, and others.
In a December 6,1990 enforcement letter which covered inspections performed in March and July of 1990, the State proposed a civil penalty of $120,000, to be paid by December 28, 1990. NPI has not paid the penalty and on March 19, 1991, the State issued another letter to NPI indicating that the penalty must be paid within 7 days or the State would take the licensee to court. It is the reviewer's understanding that the Department of the Environment is currently preparing to file an action in District Court. In addition to the civil penalty issue, the March 19 letter requires NPI to take other actions. Overdue reports must be submitted, contaminated soil from a sump area must be removed by May 1, employee training program must be implemented by May 1, the licensee must implement a certification program for individuals working in the LAA by May 1, senior management audits must be performed by May 1, the licensee must proceed with covering the facility courtyard by June 1, the licensee must build an 8 foot fence aroung the contaminated dry pond by June 1 and remove the contaminated soil by August 1. Failure to meet any of these requirements would result in cause for modification of the license.
Among the issues that the State is most concerned about is waste at the facility.
f The licensee has some 700 curies of Co-60 waste which is being kept in a section i
of the facility access to which is gained through two large doors. Whenever work needs to be done in the building, the doors are kept open. On windy days, this could result in airborne contamination since the waste stored in the building is not sealed in drums but is contained in plastic bags which in some cases are ripped.
The State suspects that this may be a source of some of the contamination they are finding on adjacent properties. The State has been requesting NPI to evaluate this situation. NPI's main pool contains a large quantity of C0-60 sources which the State considers waste, but which the licensee considers cobalt " source" material for use in fabricating irradiator or other sources. Also, the State has recently found that the licensee was storing depleted uranium waste at an unauthorized location off of NPI property.
G.
Inspection Reoorts contains a review of selected compliance files. Thirteen inspection files were reviewed. For the most part inspection fm' dings and enforcement actions are adequately documented. The State utilizes a form similar to NRC's 591 for reporting inspection findings. These are usually left with the licensee at the end of the inspection. In two cases where enforcement letters were written, they were dispatched more than 30 days after the inspection. In both cases, numerous items of non-compliance were found. In one inspection report, and during the inspection accompaniments, it was noted that the inspectors do not review the film badge reports of the physician / authorized user at medical facilities.
It appears that they focus on only the technologists.
This was discussed with the staff and they agreed that they should also look at the physicians personnel monitoring records.
r i
I i
ENCLOSURE 3 k,
REVIEW OF SELECTED LICENSE FILES During the review,14 license files were reviewed. For the most part license action were found to be adequate. Adaptive Technologies, Inc. is a manufacturer of beta thickness gauges. The State reviewed and approved two new gauges during the review period. The gauges were approved for krypton and strontium sources.
However, in reviewing the manufacturer's documentation, it became evident that the gauges were also being offered with promethium as well as other sources. During the initial inspection of the licensee, the inspector verified that gauges with promethium sources had been distributed. It was recommend that revised catalog sheets be issued to cover all sources currently being distributed.
- l. St. Joseph Hospital, Inc.
Towson, Maryland License No. MD-05-005-02 License Type: Medical License Action: Termination Date Issued: 3/12/90 l
- 2. Radiology Clinic Havre de Grace, Maryland License No. MD-25-010-01 1
License Type: Medical License Action: Termination j
Date Issued: 2/26/90 l
- 3. Anne Arundel Diagnostics, Inc.
Annapolis, Maryland License No. MD-03-050-01 License Type: Medical License Action: New Date Issued: 3/29/90
- 4. Drs. Schultze, Snider & Associates, P.A.
Owings Mills, Maryland j
License No. MD-05-109-01
{
License Type: Medical License Action: New Date issued: 5/9/90 f
l i
(
- 5. Environmental Safety Associates, Inc.
Rockville, Maryland License No. MD-33-085-02 License Type: Scaled source transfer License Action: New Date Issued: 3/2/90
- 6. Washington County Hospital Associates, Inc.
Hagerstown, Maryland License No MD-43-001-03 License Type: Medical therapy License Action: New Date Issued: 3/12/90
- 7. Calvert Memorial Hospital Prince Frederick, Maryland License No. MD-09-003-01 License Type: Medical License Action: Renewal in entirety Date issued: 7/25/90
- 8. Drs. Raab & Nieland, P.A.
Salisbury, Maryland License No, MD-45-010-01 License Type: Medical, cardiology License Action: New Date Issued: 6/15/90
- 9. Rad / Irid, Inc.
Landover, Maryland License No. MD-33-053-01 License Type: Medical distribution License Action: Termination Date Issued: 11/15/89
- 10. Christian Chinwuba, MD Lanham, Maryland License No. MD-31-182-01 License Type: Medical License Action: Termination Date issued: 1/29/90 l'
- 11. Environmental Technogies Group,Inc.
el Baltimore, Maryland SS&D Sheet MD-236D-101-G Type: Spectrometry Cell Action: New Date Issued: 3/13/90
- 12. Engineering Consulting Services, Ltd.
Hanover, Maryland License No. MD-27-046-01 License Type: Moisture / density gauge i
License Action: New i
Date Issued:11/26/90 l
- 13. Data Measurements Corp.
Gaithersburg, Maryland License No. MD-31-088-01 License Type: Industrial (gauge manufacturer)
License Action: Renewal in entirety Date issued:3/19/90
- 14. Adaptive Technologies, Inc.
Gaithersburg, Maryland SS&D Sheets: MD-ll3-D-101-G and 102-G Type: Beta thickness gauges Action: New Dates Issued: 3/31/89 and 6/20/89 e
COMMINTS FILE NO.
\\
- 1. Close-out survey forms need to indicate instrument used 2,9
)
- 2. License authorizes transfer of 15 Ci Cs-137 source.
5 No possession license exists. No technical person responsible for source.
- 3. Committee does not have representative from administration 7
- 4. No requirement for thyroid uptake measurements per 35.315(a)(8). 7 No procedures regarding use of gamma camera for doing thyroid uptakes.
- 5. Documented close-out did not include direct radiation sun'ey 9
- 6. SS&D sheet was not revised when license was amended to authorize 14 distribution of second isotope in device.
(
ENCLOSURE 4 REVIEW OF SELECTED COMPLIANCE FILES Thirteen inspection files were reviewed. For the most part inspection findings and enforcement actions are adequately documanted. The State utilizes a form similar to NRC's 591 for reporting inspection findings. These are usually left with the licensee at the end of the inspection. In two cases where enforcement letters were written, they were dispatched more than 30 days after the inspection. In both cases, numerous items of non-compliance were found. In one inspection report, and during the inspection accompaniments, it was noted that the inspectors do not review the film badge reports of the physician / authorized user at medical facilities. It appears that they focus on only the technologists, This was discussed with the staff and they agreed that they should also look at the physicians personnel monitoring records.
- 1. Licensee: Neutron Products, Inc.
License No.: MD-31-025-01 Location: Dickeison, Maryland Type of Licensee / Facility: Source Manufacturer Inspection Type: Routine, Unannounced Date of Previous Inspection: 7/90 Inspection Date: 1/28-31/91 Enforcement Letter: 3/11/91 Licensee Response Date: None Inspector: Manley Supervisory Review By:
Date:
- 2. Licensee: Johns Hopkins License No.: MD-07-005-03 Location: Baltimore, Maryland Type of Licensec/ Facility: Broad Medical Inspection Type: Routine, Unannounced Date of Previous Inspection: 2/89 Inspection Date: 6/27-7/5/90 Enforcement Letter: 10/3/90 Licensee Response Date: 10/24/90 Inspector: Manley Supervisory Review By: Trump Date: 3/13/91
- 3. Licensee: Sopha Medical Systems License No.: MD-27-038-01 Location: Columbia, Maryland Type of Licensee / Facility: Calibration and Testing Inspection Type: Initial, Unannounced Date License Issued: 12/6/88 Inspection Date: 2/21/91
(
Enforcement Letter: 2/21/91
Licensee Response Date: 3/1/91
(
Inspector: Nelson Supervisory Review By: Trump Date: 3/12/91
- 4. Licensee: Bob Taylor Engineering License No.: MD-37-007-01 Location: Lexington Park, Maryland Type of Licensee / Facility: Troxler Gauges Inspection Type: Initial, Unannounced Date License Issued: 6/9/89 Inspection Date: 3/12/91 Enforcement Letter: 3/12/91 Licensee Response Date: 3/14/91 Inspector: Nelson Supervisory Review By: Not yet reviewed Date:
- 5. Licensee: Atec Associates, Inc.
License No.: MD-31-189-01 Location: Gaithersburg, Maryland Type of Licensee / Facility: Troxler gauges Inspection Type: Initial, Unannounced Date License Issued: 5/23/89 Inspection Date: 2/21/91 Enforcement Letter: 2/21/91
+
Licensee Response Date: 3/8/91 Inspector: Nelson Supervisory Review By: Trump Date: 3/12/91
- 6. Licensee: Fayaz Shawl License No.: MD-33-097-01 Location: Greenbelt, Maryland Type of Licensee / Facility: Nuclear cardiology Inspection Type: Initial, Unannounced Date License Issued: 6/8/88 Inspection Date: 4/17/90 Enforcement Letter: 4/17/90 Licensee Response Date: 5/9/90 (Date received)
Inspector: Jacobson Supervisory Review By: Trump Date: 12/19/90
- 7. Licensee: Diagnostic Assay Services, Inc.
License No.: MD-31-086-01 Location: Gaithersburg, Maryland Type of Licensee / Facility: In vitro studies
(.
Inspection Type: Routine, Unannounced Date of Previous Inspection: 8/85
Inspection Date: 6/12-13/90
(
Enforcement Letter: 9/17/90 l
Licensee Response Date: 10/10/90 Inspector: Jacobson Supervisory Review By: Trump Date: 1/10/90
- 8. Licensee: Atec Associates License No.: MD-27-005-02 Location: Columbia, Maryland Type of Licensee / Facility: Industrial Radiography Inspection Type: Routine, Unannounced Date of Previous Inspection: 2/89 Inspection Date: 3/8+13/91 Enforcement Letter: 3/13/91 Licensee Response Date: None Inspector: Manley Supervisory Review By: Not reviewed yet Date:
- 9. Licensee: Syncor International License No.: MD-05-058-01 Location: Timonium, Maryland Type of Licensee / Facility: Nuclear Pharmacy Inspection Type: Routine, Unannounced Date of Previous Inspection: 11/86 Inspection Date: 5/31-6/1/90 Enforcement Letter: 6/1/90 Licensee Response Date: 6/11/90 Inspector: Jacobson Supervisory Review By: Trump Date: 8/10/90
- 10. Licensee: Pharmacia Diagnostics License No.: MD 27-025-01 location: Columbia, Maryland Type of Licensec/ Facility: R & D, Manufacturing Inspection Type: Routine, Unannounced Date of Previous Inspection: 7/85 Inspection Date: 8/23-24/o a Enforcement Letter: 8/24/90 Licensee Response Date: 9/5/90 Inspector: Manley Supervisory Review By: Trump Date: 1/4/91
- 11. Licensee: Prince George's Hospital Center License No.: MD-33-003-01 Location: Cheverly, Maryland
(
Type of Licensee / Facility: Medical
f Inspection Type: Routine, Unannounced
('
Inspection Date: 9/18-19/90 Date of Previous Inspection: 11/85 Enforcement Letter: 9/19/90 Licensee Response Date: 9/25/90 Inspector: Manley Supervisory Review By: Trump Date: 1/3/91
- 12. Licensee: Bethlehem Steel License No.: MD-05-003-01 Location: Bethlehem, PA (Sparrows Point, Maryland)
Type of Licensee / Facility: Industrial Radiography Inspection Type: Routine, Unannounced Date of Previous Inspection: 12/89 Inspection Date: 1/8/91 Enforcement Letter: 1/8/91 Licensee Response Date: None (No violations)
Inspector: Manley Supervisory Review By: Trump Date: 1/11/91
- 13. Licensee: University of Maryland License No.: MD-33-004-03 Location: College Park, Maryland Type of Licensee / Facility: Irradiator Inspection Type: Routine, Unannounced Date of Previous Inspection: 5/89 Inspection Date: 8/29/90 Enforcement Letter: 8/29/90 Licensee Response Date: 9/17/90 Inspector: Manley Supervisory Review By: Trump Date: 1/10/91 1
COMMENTS '
FILE NO.
- 1. Enforcement letter issued more than 30 days after inspection.
2,7
- 2. Documentation of enforcement conference should indicate items 2
resolved and items remaining unresolved.
- 3. Initial inspection conducted more than 18 months after license issued.
3,4,6
- 4. User apparently not badged and not questions by inspector.
6
- 5. Nothing in report regarding transportation issues.
9
- 6. No information regarding customer license verification procedures. 9,10
- 7. No discussions with nursing staff or other ancillary personnel.
I1
- 8. Recommendations not documented when form 1097 issued.
I1
(
STATE OF MARYLAND WILI.IAM DONALD SCHAEFER GOVERNOR DEPARTMENT OF TiiE ENVIRONMENT ROBERT PERCIASEPE SECRETARY T0XICS, EriVIRONMENTAL SCIENCE AND HEALTil LAWRENCE M. WARD
~
DIRECTOR RADIOLOGICAL llEALTil PROGRAM ROLAND G. FLETCHER ADMINISTRATOR I
MARYLAND DEPARTMENT OF THE ENVIRONMENT GOVERNOR William Donald Schaefer LT. GOVERNOR Melvin Steinberg m
intergovernmental Relations SECRI ARY Counsel 631-3056 L.. "' "l... A Michael C Powell
~7 631-3034 631-3053 Fair Practice Office -
W. Wallace Baker Deputy Secretary 631-3056 l
Public Education and Robert Perciasepe Hearings O!! ice Media Office 631 3086 Cornelia Bright Gordon
^
Charles Walker 631-3003
% }{ MFJ 53 p) 631-3016 NNWOR Assistant Secretary Assistant Secretary Assistant Secretary Cf r' ? ^ ~ c - 7 Toxics, Environmental Planning and Capital Operations Finance and Science and Health Programs '.
Adminictration gg v,p-w r,..mn Richard Naylor Richard F Pecora Charles Brannan.
is n 631-3774 631-3114 G31-3175 631-3065
- Environmental Health
- infrastructure Plans
- Project Execution
- Fiscal / Grants Accounting
-' Radiological Health
- Capital Program
- Inspection and Enforcement
- Budget, Grants and Management Information Management
- Toxics Integration
- Chesapeake Bay Water
- Program Coordination and
- Personnel and Manpower Quality Pla'ns implementation
- Procurement Central Services
- Toxics infortnation Service Maryland Water Quality and Telecommunications
- Boards Financing Administration
- Toxics Operations Hazardous & Solid Sediment and Air Management Water Management W ste Management Stormwater Administration
~ Administration mimstration Mm,imstranon George Ferreri J.LHearn R nam Nelson Mncent Berg 631-3255 631-3567 631-3304 631-3553 Sr
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- \\
.r FINA1. ACTION ON REGliLATIONS
- $093 f
s 7
Title 26 26.12.03 State Radiation ControlFund DEPARTMENT OF
., 7,,,,,,,,,d.
d.- C. (Proposed text unchanged)
THE ENVIRONMENT D. Dentist /Vetersnanan AnnualFee.
i Ill (Proposed text unchanged)
)
Subtitle 11 AIR QUALITY ~
(2) The annual dentistiveterinarian registrolion fee shall
^
26.11.05 Air Pollution Episode System be paid on or before the dates shown below ba. icd on the to.it digit of the radiation machine facility registration number:
i Authority: Environment Article. Title 2.
(d Odd registration number ll-April 1;])
Annotated Code et Maryland (i) First year-effective date of this regu ation, (io Each succeeding year-April 1; Notice of Final Action (b) (proposed text unchanged)
,,n ggy r Posed text unchanged)
On April 19, 1990, the Secretary of the Environment F. Radioacdve Maunals Danse Tee.
odopted emendments to Regulations.01
.03 and.05 under COMAll 20.11.05 Air Pollution Episode System. These
- "*f,*,,ioIs license fee shall be pald on "E'
g,,
amendments, which were proposed for adoption in 17:4 h!d. R.
before the dates shown below depending on the radioactive mo-534 - 536 (February 23, 1990). have been adopted as pr ^
teriallicense number resed.
(4 ogg g;,,,,,,ums,,3;_,p,gg 3;33 ;
Effective Dnte: Junc 18,1990.
fi) First year-effective date of this regulation, MARTIN W. WALSH, JR.
(ud Each succeedsng year-April 1; Secretary of the Environment (b) (proposed text unchanged) (( Agency Note )) (pro-posed text unchanged)
G.- H. (proposed text unchanged)
. M ARTIN W. WALS11, JR.
Subtitle 12 RADIATION MANAGEMENT Secretary of the Environment Author Hy: Environment Article, ll8 30ltbX ttili). 8 30t(cI3). end 6 306, Annotated Code et Maryland Notice of Final Action 190 016 F)
On April 10, 1990, the Secretary of the Environment odopted an amendment to Regulation.02 under COMAR 2G.12.02 Inspection and Certification of Radiation Ma.
chines and new Regulations.01
.03 under a new chapter, CON AR 20.12.03 State Rodintion Control Fund.These ac.
tions, which were proposed for adoption in 17:1 Md.R.96-100 (Janunty 12. 1990), have been adopted. ith the nonsub.
w stantive changes shown below.
Effective Unte: May 14,1090.
Attorney General's Certification in accordance with State Government Article,(10-113, An.
notated Code of Maryland, the Attorney General certifies that the following change does not differ substantively from the Tropcsed text.The nature of the change and the basis for this conclusion sie as follows:
Regulation.02D(2Xa) and F(2Xo) under COMAR 26.12.03:
The change does effect the duties and obligations of those inembers of the regulated group who possess odd registration numbers,in that they will, as a result of the change, have to pay annual fees in 1990. However, this effect is not a substan.
tial one, as the proposed regulation clearly conternpinted im.
position of an nnnual fee on those persons, with an April 1st date chosen mei ely as a matter of administrative convenience.
i De collection of those fees a few weeks later,in 1990,does not substantially change the annual nature of the fee. Accord.
ingly, another publication in unnecessary, i
MARYLAND REGISTER, Vol.17, ISSUE 9 FRIDAY, M AY 4,1990
Y 96 PFIOPOSED ACTION ON REGULATIONS 1
.03 Inmate Crlevance Commission.
tion of Redistion Machints, and edopt new Regulttions
- A. If the inmate Grievance Commission dismisses the iru
.01
.03 undst a nsw chepter, cob 1AR 26.12.03 Steta Radi.
mate's complaint as wholly lacking in merit-ation Control Fund. This will fulfill the mandate of The (1) The Executive Director of the inmate Grievance Cony Maryland General Assembly in Chapter 325 of the Acts of f
mission shall notify the Treasurer ofits decision; and
- 1989, (2) Upon receipt of notification of the inmate Grievance This purpose of these actions is to consolidate and expand Commission's decision, the Treasurer then shallprocess the in-the collections of fees now being imposed on persons who use 2
mate's claim in accordance with COMAR 25.02.03.
certain types of sources of radiation. The expansion will in-(
B. If the Inmote Grievance Commission recommends to the clude persons who use machines in dental and veterinary ac.
Secretary of Public Safety and Correctional Services that the tivities and certain persons who are licensed to use radioactive inmate be awarded monetary damages pursuant to COMAR materials.
12.07.01.06, and the Secretary affirms the inmate Grievance
. Commission's recommendation.
Estimate of Economic Impact (1) The Secretary of Public Safety and Correctional Ser.
L Summary of Economic impact.%ese proposed amendments j
and new regulations will establish the State Radiation Control Fund.
vices shall notify the Treasurer of the Secretary's decision;
""* * **"0 "* "'* I"'" *** 'h* '"* "** b'I" E P
- IO b' * ** I" **
1 (2) Upon receipt of the Secretary's decision and subject to fB?3) below, the Treasurer then shall Process the inmate's on persons who use radiation machmes in dental and vetennary act v-i claim in cecordance with COMAR 25.02.03; and ities and also on certain persons who are licensed to use radioactive
,j (3) in processing the inmate's claim, the Treasurer may materials.
rely on fact. finding undertaken by the inmate Grievance Com-U' E "
mission in its review of the inmate's complaint.
E' C Payment of anv award, compromise, or settlement of the inmate's tort claim pursuant to COMAR 25.02.03.07 shall be A. On issuing agency:
(+)
$462,327tyr.
made throuch the State insurance Trust Fund.
B 0" *'h*' S'*" *' I***I
- E* *'
'I";
- *'S
D. The Treasurer Aall notify de Secretary of Public Safety 1
and Correctional Services of the Treasurer's approval or denial Benefit (+ )
Cost ( -)
blarnitude cf the inmate's tort claim.
C, On regulated industries or 25.02.06 Agency CIaims trade groups:(including state and I '*I I
.0/ filing of Claimfor Reimbursemenf.
g3%,',],';"d o the agency
(-)
5462.327tyr.
A. Subject to fB. below, when a unit of State government g2, g,p,,7,,ng,g3u,t,,,t, sceles resmbursement from the State insurance Trust Fund for required because ofinspections
(-)
s 23,42wyr.
an occu rence ofloss, damage, or liability, the unit shall(de its (3) Savings in health care costs i
claim wnh the Treasurer within 60 days aller the unit discots because of tewer diagnostic X. ray crs the loss, damage, or liabtlity.
retakes
(+)
Unknown D. If the unit discover.; an occurrence ofloss, damage, or lia-D. On other industries or trade 4
bihtv in June it shalllite its claim for reimbursement with the groups:
NONE l
Trcosurcr before July 20th of the next l1scalyear.
pubh. Direct and indirect effects on E-
,j e:
.02 Theft ofPersonalProperty.
(1) Savings on health care costs
(+)
Unknown 1
A. Un! css otherwise required by statute or these regulations, (2) The increased cost of an X.
Less than 1 o claim of a unit ofState government under any insurance pro.
rey examination t-)
cent?tilm gram prouded by the Treasurer may not be ceceptedfor theil or Ill Assumptions.(Identified by impact Letter and Number from other disappearance ofits personalproperty.
Section 11.)
B. A una ofState government shall be solely responsible for A. All of the fees from Section llc 1 will be revenues for the issuing
-1 the care and custody ofits property.
agency.
B. State and Local Dental Machines
.)
LUCILLE Af AURER 35 machines at $$0/ machine 8 1,750 j
State Treasurer State and Local Medical blachines (Group 3 and 4)
.1 20 machines at $32.50/ machine'
$650 j
State and Local Radiactive blaterial Gauges f
200 licenses at $200$icense
$40.000
)i Title 26 cci> rees trom aii msuisted rersons:
Total $42.400
- l Radiation MacMne Certincation Tees i
DEPARTMENT OF t*une Teetper f
.T a e a e e eI rs e'n a e ae MacMne yur per Tee Total Annually Annun!
IM NVIMUN N
Caterary machinel increase
- Tacilites Atrected Cost
]
Grou !
375 Si?5 30 30 SE50 i.
Subtitle 12 RADIATION MANAGEMENT croup 3 sit.s0 s32 50 73 as -
si2.e70 Authovdy Environment Article,6 68 30lfbtlliii). B-30*c13), and 8-306, G
5 3
28 31 0 Annotated Code of Maryland
.g g
g
-i Notice of Proposed Action
'nis impact is due to the increase in the fee due to this proposal.
]-
ton 016 PJ The esisting regulation requires that fees by paid by persons using j
these types of radiation machines. Fees for Group 3 and Group 4 ma.
1 The Secretary of Environment proposes to amend Regula-chines an paid on a 2 year basis.
l tion.02 under COMAR 26.12.02 Inspection and Certifica.
b(
MARYL AND REGISTER, VOL.17. ISSUE 1 FRIDAY, JANU ARY 12,1990
,i
- ~
f 3
, PROPOSED ACTION ON REGULATIONS 97
" Assumes an average of 11 achines per hospital. All other Opportunity for Public Comment groups assume only 1 machine per facility.
The Department of the Environment will hold hearings con-Group 5 machines are paid on a 3 year basis-cerning the adoption of these amendments and new regula-h DentistNeterinarian Annual Fees tions on February 7,1990 at 10 a.m. In the MDE training Facility Type Annual Fee Facilities Machines Annual Cost room,2500 Broening Highway,1st noor, Baltimore, Maryland Vetermary 570 228 228 3 15,960 21224.
Dental
$50 2,220 4,456 3222.800 All interested persons are invited to attend and give their Total 4.684 3238.760 views. Any hearing impaired person may request an inter-I preter to be present at the hearing by giving 5 working days Radiation Machine Registration Fees for notice to Deanna L. Miles Brown, Regulations Coordinator, hew and Unregistered Facihties (301)631 3173.
Number of Written comments may be sent to Deanna 1 Miles. Brown.
Facihty Ty pe Fee FacibtiesNr.
Annual Cest Regulations Coordinator,2500 Broening Highway,3rd Floor, Group 1 and 2
$250 5
51,250 Baltimore, Maryland 21224. Written comments will be ac.
Group 3 S100 0
5 0
cepted until the close of business on February 14,1990.
Grcup 4 5 50 150 57,500 Group 5 5 25 15 3 375 26.12,02 inspection and Certification of Radia-Vetermary 5 50 10 s 500 tion Machines Dental 5 25 65 32.625 Tctal 511.250Nr.
.02 State Certification of Radiation Machines.
A.- C. (text unchanged)
Radicactive Material Lhense Fees D. Application for State Certification.
53S heenses at 3272 (avg.hcense 5144.000 (1)-(2) (text unchanged)
Radioactive Material License F3) Except for applications for recertification following Recicrocity Fee replacement or rebuilding of a major component, each person 220 Licenses at 5150Nr 5 30.000 submitting an application shall remit e State ecrtification fee with the application based on the following fee schedule:
Grand total 5462.327Nr.
(a) Radiation machine used for mdustrial purposes ex.
cept ifit is classified as a Group 1 machine..
.515; a
a e e e uca ona o pa rs X y a hine 10 nt req re ser e Aver ge se ce ca I is 5150. 4.6S4 dental and setermary macnmes mspected on a 3 year Chid'-
n
.535; cycle t4.654 - 310 la 5150) - 523.420*yr.
C(2) A reoucticn m the nurnber of diagnostic X. ray retakes trans.
(c) Group 1 or Group 2 machine.
. $75 )
lates mto a monetary savings in both hospaal operating costs and pa.
E. (text unchanged)
J tient health care L1) Savings en health care costs: These inspections, from past ex.
2& M.03 State Radiation Control Fund perience. should detect serious violations m ten percent of the irspec.
.01 Definitions.
tiens pcriernico These siolatiens on the nerage, are responsible foi doubbng the radiation received by patients dunng diagnostic work.
A ln this chapter, the following fcrms hcue the meanings i>
These savmgs m exposure, ncordmg to studies by the federal govern.
dicated.
ment. can be greater than the cost of the mspection program.
B. Terms Debned.
D2) increased cost of t'iagnostic procedures: Of those machines (1) " Brachytherapy license" means a category ofspecif c li-and facihties shou n sn the Table in C1 above. there are 5,652lyr.
cense authorizing a person to possess or use a source of radio-which do radiegraphic diagnosta imaging work. The following table lion to administer brachytherapy as de ned in Section G2 of shows the increased certificaticn costs, repairs, and registration:
the Maryland State Dcpartment of the Environment "Regula-Number of Increased Cost tions for Control ofionizing Radiation"(1995) whic' is incor.
T)pe of Machine Machsnes to Certify Total Cost porated by reference at COMAR 26.12 Cl.v1.
Group 3 396 532 50
$ 12.870 (2) " Civil defense license" means a category of specipe ii.
Group 4 587
$32 50
$ 19.077 cense authorizing a civa defense agency or its agents to use ro-Group 5 15
$2s00
$ 420 dioactive material.
Total 532.3G7Nr.
(3) " Consultant license" means a category of specipe li-Increased cost to repair machines
$23,420Nr.
cense authorizing a person to perform leak testing of scaled sources, calibration of teletherapy units, sample analysis and similar services.
traIon Fe Total Cost Tac y" means the ocahon ! which one or more Tme of Practice Nurnber sources of radiation arc installed or located and are under the Dental 2.228 53 5111,400 same administrative control.
Veterinary 229 70
$ 15.960
@ "Gaup hem"mau a MW ofge@ he w Total $127,360Nr.
thorizing a person to possess or use a device that uses a radic>
Grand Total $1E3,147Nr.
isotope to measure density, thickness, or other measurable pa-ram eter.
An estimated number of diagnostic films per week is 125 per ma.
(6) "Generallicense" means a license that, under the pro-chine or for 5.682 machmes(4,664 dental %ets + 998 mcdscolt visions of the " Regulations for Control ofionizing Radiation",
5.682 machines x 150 filmdwk n 52 skstyr = 44.320.000 part C, is effective without the pling of an opphcation by the films:yr.
Licensee.
Cm,t per film - $183,147,. 44.320.000 = 0 41 cents' film MARYLAND REGISTER, VOL.17, ISSUE 1 FRID AY, J ANU ARY 12,1990
a)
(7) "Generalin-vitro license" meana a category ofgeneral
.02 FeeRequired.
, license authorizing a person to possess or use radioactive mate-A. Applicability. Fees for radiation machine certipcation, rsal for the purpose of testing patient samples for diagnosis.
registration ofradiation machines at new or unregistered facil-(
(8) "Irradiator hcense" means a category ofspecife license ities, and general and specife radioactive materials licenses are Q
('
authorizing a person to perform intentional exposure ofvarious established as shown in Tables 1,2,3, and 4 in Regulation.03.
products to ionizing radiation to effect polymerization, steriliza-B. Exemptions. This regulations does not apply to persons i
tion or other effects.
using the following:
(3) " License" means any license, whether general or spe-(1) Sources of radiation exempted by "Section B.3 of the cil.c. that as required by COMAR 26.12.01 to be obtained from
" Regulations for Control oflonizing Radiation";
a th.? Department of the Environment to receive, possess, use, (2) Sources of radiation that produce non-ionizing electro-transfer, own, or acquire radioactive material, magnetic radiation; (10) "l.ow level waste broker license" means a category of (3) Sources of radiation that produce sonic, ultrasonic, or specific license authortting a person to receive and store low oO infrasonic radiation; and
{
tivity rcdioactive waste befor e disposal.
(4) Sources ofradiation, speci6cially radioactive materials 1
(11) "New facility" means a facility that has filed a regis-that are not included in fFof this regulation.
1 tration application with the Department in accordance with C. Radiation Machine Certifcation Fees. Except for applica-Section B 4 of the " Regulations for Control oflonizing Radia-tion for recertipcotion following replacement or rebuilding of a toon" before the operatwn of any radiation machine in that fa-major component, each person submitting an application for c lity.
certifcation of a radiation machine shall remit a fee with the f
(12) "Other speci6c license" means a speciSc license that application based on the fee schedule in Table 1.
i as not enumerated on Table 4.
D. Dentist / Veterinarian AnnualFee.
(13) " Radiation" mean s:
(1) For dentalor veterinarian practices, each person with a in) lanisme rcdsation. includmg gamma rays, X. rays,
^ radiation machine facility shall annually remit a fee for each c!pha particles, beta particles, neutrons, high speed electrons, radiation machine at the facility based on the schedule shown and any oth cr atomic or n ucl car particles or rays; in Table 2.
tid All ciectromagnetic racitation that can be generated (2) The annual dentistheterinarian registration (ce shai; during the ercrotinn of a manufactured daice that ha.s an elec be paid on or before the dates shown below based on the last tronte carcia:. ~
digit of the radiation machine facility registration number:
(c) A;. wmc, ultrasonic, cr infrasonic waves that are (c) Odd registration number-April 1; em:tted as a result of the operatton, in a manufactured device, (b) Even registration number-October 1.
c an elect'cntc chcuit that can,;cncrate a physical Beld of ra-E. Radiation Machine Registration Fees for New and Unre-Jut:o u gistered Facilities. Each person submitting an application for (14) " Radiation machine" means a device that is capable registration of a rodsation machine or machines in a new facil-ofproduciry rc imtum.
ity or an unregistered facility shall remit a single fee for all ma-6 (15) "Rectstratmn" or " registered" means complianee chines at the facility with the application tiased on the fee sched-wah E:wirwnent Artscle, fS 301(aw24ti), Annotated Code of use in Table 3.
Marylanri. cud the provasmus adopted under Section B 4 of the F. Radioactive Materials License Fee.
"Brgulattons for Control oflonizing Radiation".
(1) Each person holding a radioactive material license o' (16) "Rescarch and development license" means a cate the type shown in Table 4 shall annually remit the fee indicarec gvy of spccift license authorizing a person to possess or use in that Table.
radionctive ratcract for the purpose of research and develop-(2) The radioactive materials license fee shall be paid on or ment a.s dcBned in Section A 2 of the " Regulations for Control before the dates shown below depending on the radioactwe ma-cflonitmg Radwtion."
terial license number:
(17) "S;,ecu0c licen se" menns a license that. under the pro-(a) Odd hcense number-April 1; visions adopted in I art C of the "Rcgulatwns for Control oflon-(b) Even license number-October 1.
2:ing Raduation", is effectwc only aper the appbcant ples an Agency Note: For example, a license number of31025 02 contains th-i:rplication and the Department approves the application.
three digit number "02S"which is the number ofinterest and is on od.
(15) " State certsfcction" or " State certifed" means a dec.
number. A hcense u ith this number would therefore be due on April 1 laratnon by the Departmco according to Environment Article, G. Radioactive Material License Reciprocity Fee. Each per-fS-304, Annotated Cod
- of Maryland, and the regulations son granted a generallicense to conduct an activity under,th cdopted under COMAR 2612 C2 01
.05, that the use of a ro.
authority of Section C90 " Reciprocal Recognition of Licenses deation machme complies with the Mervland Radiation Act of the " Regulations for Control oflonizing Radiation" shall re.
and the regulations adepted under the Act.
mit a $75 fee to the Department before the 180 calendar da;.
~
(19) " Teletherapy hcense" means a category of specific li.
period during which the license is effective.
cense authoritmg a person to possess or use a source of radia.
H. All fees shall be payable to the Maryland Department o' tion to administer teletherupv as dcBned in Section G2 of the the Environment (MDE) Radiation Control Fund and shall be "Regulatwns for Control ofionizing Rad >ation "
acc mpanied by a form provided by the Department (20) " Unregistered facility" means a facility at which one or rnore sources of radmtion are installed without the facility having been rcpistered with the Department, in violation of the proutsions ofSe tion B 4 of the " Regulations for Control oflon-i:ing Radiation."
t' M ARYL AND REGISTER, VOL.17, ISSUE 1 FRID AY, J ANUARY 12,1990
m n'
.e s
PROPOSED ACTION ON REGULATIONS 99
.03 Tables ofFees.
Table 1 Radiation hiachine Certification Fees hiachine Category Certification Fee Per ofachine Group 1
- or Group 2 Accelerator
$250 Group 3 (Hospital)
$100 Group 4 (General hiedical)
$100 Group 5 (Other hiedical and Industriau
$100
'The term " group" refers to the classi$caten prescribed by COMAR 26.12.02.02B.
Table 2 Dentist / Veterinarian AnnualFees Facility Type Annual Fee Per biachine Veterinary
$70 Dental
$50 Table 3 Radiation hiachine Registration Fees for New and Unregistered Facilities Total Registration Fee Unregistered Facility Category Total Registration Fee New Facility Facility Group 1 or Group 2 (Accelerator)
$250
$500 Group 3 (Hospitab
$100
$250 Group 4 (Afedical)
$ 50
$150 Group 5 (Other hiedical and Industrial)
$ 25
$125 Yeterinary 5 50
$150 Den tal
$ 25
$125 Table 4 Radioactive blaterial License Fees Source (Section of the Regu-lations for Control oflonising
'.icense Type Radiation")
Annual Fee keml:
s Mcaical Diagnostic Uses C22(h)
$ 50 General in-Vitro C22(i)
$ 50 Svecific-Cans uitant C30
$250 Civsl Defense C30
$150 Research and Development C30
$300 Lou Exvel Waste Broker Irradictor, Self Contained C30
$750 C30
$250 Irtcdiator, Pool Type C30
$750 Gauges C30
$200 instautions for Human Use of Radioactive blaterial C26(a)
- $300 individual Physicians for Human Use of Radioactive Afaterial C26(b)
$300 Telesherapy C26(d)
$225 Brachytherapy C26(d)
$150 Sealed Sources, industrial Radiography C26(e)
$500 Broad Scope C27
$525 Other Speenfic License C30
$150 Agency note: The following specibe licenses are all issued w. der the cuthority of Section C28 "Special Requirements for a Specibe License to blanufacture Assemble, Repair, or Distribue Commodities, Products, or Devices which Contain Radsocctive bIateria!"of the "Regw latwns for Control oflonizing Radiation".
Source (Section of the "Regu.
lations for Control oflonizing Specific License Type Radiation")
Annual Fee introduction of Radioactive h1aterial into Products in Exernpt C28(a)
$ 150 Concentrations Distnbution of Radioactive 31aterialin Exernpt Quantities C28(b)
$ 150 Incorporation ofNaturally Occurring and Accelerator Produced C28(c)
$250 Tadioactive blaternalinto Gas and Aerosol Detectors
\\.
4 M ARYLAND REGISTER, VOL.17, ISSUE 1 FRIDAY JANUARY 12,1990
PROPOSED ACTION ON REGULATIONS 100 Source (Section of the "Regu-lations for Control oflonizing Radiation")
Annual Fee j
Specific License Type 1
Manufactwing and Distributing Devices to Persons Generally C28(d)
$225'
~
Licensed Under C22(d) l Manufacture, Assembly, or Repair ofLuminous Safety Devices C28(e)
$225 for Use in Aircraft Manufacturing of Calibration Sources Containing Americium-C28(f)
$250 241, Plutonium or Radium-226 for Distribution to Persons Gen-erally Licensed Under C22(g) r Manufacture and Distribution of Radioactive Material for Medi-C28(g)
$200 col Use Under General License l
Manufacture and Distribution of Radioactive Material for Cer-C2S(h)
$ 250 tain in-Vitro Clinical or Laboratory Testing Under General Li-cense Manufacture and Distribution ofice Detection Devices C28(i) 5150 Manufacture and Distribution of Radiopharmaceuticals Con-C2Sfj)
$ 500 taining Radioactive Materialfor Medical Use Under Group Li-censes Manufacture and Distribution of Generators or Reagent Kits for C2b(k)
$300 Preparation of Radiopharmoceuttcals Containing Radioactive Material Manufacture and Distribution of Sources or Devices Containing C2S(D
$1,000 t
Radioactwe Material for Medical Use Manufacture and Distribution oflndustrial Products Contain.
C2S(m)
$ 400 ing Depleted Uranium for Mass Volume Applications n
MARTIN W. WALSH, JR.
i Secretary of the Environment l
C V.
f 1
1 MARYLAND REGISTER, VOL.17, ISSUE 1 FRIDAY, JANUARY 12,1990
T
{
TA3.G 1
- y. 1 c.s. Ts"1"., ~. P....'.'.*..Y...." l.'.rs
'1 "..';.". ~. ~ " "... -
Activitics under the various priorities cf raterials licences chall be inerected routinely at the r.ini.un f racuency ctatad below:
Initial inspection vi.hin c..e nor.th after Fricrity 1 license is issued. heir.s;.se:icns as follows:
Eajor Procescors or t'sers - l'hree inspections per year. hay be redu:ed to two per year by the Division Chief if faverable cccpliance record warrants such action, r
Frierity II - To be inspected within six r.onths af ter license is issued and thereaf ter at intervals not exceedin;; cne year. Reincpectien ti.ne u.ay be extended up to six r.cnths for all users in this priority except active field radioi;raphic operaticns.
f Friority Ill - To be inspacted within 12 r enths after initial license is issued.
iined cr in-plant radiot,raphy licenr,es will b rein.ected at intorycls not to exceed three years.
Pricrity 1Y - To be inspected witair. 16 r.cnths after initial license is issued. heinspections will be made at intervals not to exceed h years.
To be inspected within 1B nonths. Reinspections Frierity V will be c.ade at intervals not to exceed 5 years.
Out-of-State radio;;raphers will be insp2cted as soon as possible afte cor.encin; operations in Maryland. Reinspecticns will ba r.ade as necessary.
4i
~
g p TABl.s II CATdGCRIdS CF USE AND ASSIGiED PPJ CRITIES FOR SCECULIrU 1:!3F ECTICIS Triority I Priority II Friority III Priority IV Friarit/ I A - l'ajor Processors A - Itadiograi)hy, A - Radio.;raphy, A - Indu; trial 'lype C A - E2d ic '.. Li-it :-
or Users Field In-Pl: nt Ernad B - Industrial Typo B - Wast.c Collection B - Industrial Limited B - All othar A Broad C - Acadenic Type A C - Industrial C - Academic Bread D - Eedical Broad D - Industrial Type D - Academic Typo C B Eroad Broad E - Academic Type B d - Ecdical Broad F - Environmental F - Possession of several sets of CD sources and multiple urcrs G - Medical
'T n.
.. ~
a I
(DRAFT)
INCIDENT REPORTING CHECK LIST (JULY 30, 1987)
(
).
Date of Incident:
10/17/90 Dats RCP notified:
10/17/90 2.
Type of Incident or Alleged incident:
Tnrnminn menn1 mhipmnnt not off ninr-nn -nnienr.
3.
Was an investigation conducted by your staff?
YES Date: 10/18/90 4.
Did the investigation reveal:
(check all appropriate blocks)
[
} Loss of package effectiveness or contamination?
[
] Theft or loss of licensed material?
[
] overexposure of individual to radiation or radioactive material?
[
] Excessive levels of radiation or concentrations of RAM 7
[
] Safety failure of GL device?
[
] Equipment f ailure that could occur on similar devices?
[
] Leaking source?
[
] Nisadministration?
[
] Transportation incident?
[
] Uranium mill occurrence?
If any[X)
OTHER boxes are checked or if the event is newsworthy, the event aust be reviewed against the reporting criteria for Agreement State Materials Events (see All Agreement State letter dated July 22, 1986) and a descrjption of the incident should be summarized as follows for the next NRC review. (Use extra sheets if necessary.)
SUMMARY
OF EVEhT Licensee:
r o,- + o.- - c+nin1 nee e+nos License No. : Mn-05-045-01 Location of event: '7700 Pollino Mill Poad Description of event:
Shirment of scrap steel was received and surveyed fe-PAM. Fire cet off the alarm on the meter.
1 Isotope: Pa-??6 Amount:
5-20 microcuries Event Date:
10/17/90 Report Date:
10/17/90 Identify any other. licensees involved:
Licensee:
NONE License No.:
N/A Jurisdiction:
N/A Reciprocity Licensee: Y/N Describe clean-up actions taken by you:
NONE What measurements were taken? Dino enrvnynd with Eberline F-520 GM meter van What other action was required of you? NO vith HP-260 and 270 What action was taken to notify the NRC, other Agreement States or licensees? probes t
pm
+kn "pr nna pnnney1vanin voro nntifind Is the case closed? YES Is record of incident in RAM files? YES What enforcement action was taken?
NONE
(DRAFT)
INCIDENT REPORTING CHECK LIST (JULY 30, 1987)
(
l.
Date of Incident: March 6. 1991 Date RCP Notified: March 6. 1991 2.
Type of Incident or Alleged Incident: radioactive scrao metal shioment 3.
Was an investigation conducted by your staff? ves Date:
3/6/91 4.
Did the investigation reveal:
(check all appropriate blocks)
[]
Loss of package effectiveness or contamination?
[]
Theft or loss of licensed material?
[]
Overexposure of individual to radiation or radioactive material?
[]
Excessive levels of radiation or concentrations of RAM 7
[]
Safety failure of GL device?
[]
Equipment failure that could occur on similar devices?
[]
Leaking source?
[]
Misadministration?
[]
Transportation incident?
[]
Uranium mill occurrence?
[x]
Other If any boxes are checked or if the event is newsworthy, the event must be reviewed against the reporting criteria for Agreement State Materials Events (see All Agreement State letter dated July 22, 1986) and a description of the incident should be summarized as follows for the next NRC review.
(Use extra sheets if necessary).
SUMMARY
OF EVENT Licensee: Samuel G. Kerwell Comnant License No.:
MD-05-080-01 Location of event:
7600 Rolline Mill Road. Baltimore. Marvland Description of event:
A truck loaded with stainless steel scrap set off Kerwell's Suntrak 3503 radiation monitor.
The truck was returned to Peanut City Iron and Metal in Suf folk. Virginia 23434.
Isotope:
unknown Amount:
unknown Event date:
3/6/91 Report date:
3/7/91 Identify any other licensees involved:
Licensee:
None License No.:
N/A Jurisdiction:
N/A P.eciprocity Licensee:
Y/N Describe clean-up actions taken by you:
None What measurements were taken:
None What other action was required of you?: investigation of incident conducted What action was taken to notify the NRC, other Agreement States or licensees?:
Xptified John McGrath. USSRC-Region I. on 3/6/91 at 1420 hours0.0164 days <br />0.394 hours <br />0.00235 weeks <br />5.4031e-4 months <br /> Is the case closed?:
Yes Is record of incident in RAM files?:
Yes What enforcement action was taken?:
None 4
r (DRAFT)
INCIDENT REPORTING CHECK LIST (JULY 30, 1987)
It 1.
Date of Incident: January 14, 1991 Date RCP Notified: March 12. 1991 2.
Type of Incident or Alleged Incident: source disconnect. well-logging source. 3.0 Ci Am-241. lost down a H O well 2
3.
Was an investigation conducted by your staff? ves Date:
3/12/91 4.
Did the investigation reveal:
(check all appropriate blocks)
[]
Loss of package effectiveness or contamination?
[x]
Theft or loss of licensed material?
[]
Overexposure of individual to radiation or radioactive material?
{]
Excessive levels of-radiation or concentrations of RAM?
l]
Safety failure of GL device?
[]
Equipment failure that could occur on similar devices?
I)
Leaking source?
[]
Misadministration?
[]
Tra: sportation incident?
[]
Uranium mill occurrence?
If any boxes are checked or if the event is newsworthy, the event must be reviewed against the reporting criteria for Agreement State Materials Events (see All Agreement State letter dated July 22, 1986) and a description of the incident should be summarized as follows for the next NRC review.
(Use extra sheets if necessary).
SUKMARY OF EVENT Licensee:
Accalachian Geophrsical Survers License No.: NRC-37-19798-01 Location of event: Cambridte Rubber Plant. 86 York St.. Tanevtown. Marvland Description of event: On 1/14/91. Aqn_alachian Geonhvsical Survers conducted vell-lottine at the Cambridte Rubber Plant without providine RHP a written notification. At 1430 hours0.0166 days <br />0.397 hours <br />0.00236 weeks <br />5.44115e-4 months <br /> on 1/14/91. the source became detached'from the lorging tool and fell to che bottom of the well.
Isotope:
Am-241 Amount:
3.0 Curies Event date:
1/14/91 Report date:
3/25/91 Identify any other licensees involved:
Licensee:
None License No.:
N/A Jurisdiction:
N/A Reciprocity Licensee:
Y/N Describe clean-up actions taken by you:
none What measurements were taken: dose rate at too of well:
backcround What other action was required of you?: H2O samole collected: ( 4 oCi/l What action was taken to notify the NRC, other Agreement States or licensees?:
RHP notified John McGrath. USNRC-Region I. on 3/12/91 at 1330 hours0.0154 days <br />0.369 hours <br />0.0022 weeks <br />5.06065e-4 months <br />
[
Is the case closed?:
No Is record of incident in RAM files?:
Yes What enforcement action was taken?: Departmental letter senu on 4/4/91 to licensee explaining source recovery requirements.
Compliance letter / enforcement action will follow upon recovery of source.
(DRAFT)
INCIDENT REPORTING CHECK LIST (JULY 30, 1987)
~
1.
Date of Incident: Februarv ?. 1991 Date RCP Notified: Februarv 5. 1991 2.
Type of Incident or Alleged Incident: radioactive check sources were found bv a Silver Sorine. Marvland individual 3.
Was an investigation conducted by your staff? ves Date:
2/7/91 4.
Did the investigation reveal:
(check all appropriate blocks)
[]
Loss of package effectiveness or contamination?
I]
Theft or loss of licensed material?
[]
Overexposure of individual to radiation or radioactive material?
[ ]
Excessive levels of radiation or concentrations of RAM?
[]
Safety failure of GL device?
[]
Equipment failure that could occur on similar devices?
[]
Leaking source?
[]
Misadministration?
[]
Trahsportation incident?
l
[]
Uranium mill occurrence?
[x]
Other If any boxes are checked or if the event is newsworthy, the event must be reviewed against the reporting criteria for Agreement State Materials Events (see All Agreement State letter dated July 22, 1986) and a description of the incident should be summarized as follows for the next NRC review.
(Use extra sheets if necessary).
SUMMARY
OF EVENT Licensee:
Yone License No.:
N/A i
tocation of event:
Canital P1nstics. 4217 Howard Avenue. Kensinrten. Maryland Description of event:
Mr. Tom Shoemaker, a Cauital Plastics ennlovee.
rurchased drums of buildine materials from Mrs. Robert Golden. 1811 Sanford Road. Silver Sprine, MD.
He found the sources inside one of the drums.
The sources belonged to Robert Golden. Radiation Soecialist, who recentiv died.
Isotope:
Cs-137 Amount:
Two 10uci check sources Event date-9 /'> / 91 Report date:
2/11/91 Identify any other licensees involved:
]
Licensee:
N/A License No.:
N/A Jurisdiction:
N/!
Reciprocity Licensee:
Y/N Describe clean-up actions taken by you:
Sources were imoounded.
Documentation of source transfer was sent to Mrs. Golden on 3/12/91.
I What measurements were taken: dose rate: 1 mR/hr at contacts, wine surrev:
<.005 uCi/ wine and contamination survevs What other action was required of you?: stored sources at RHP. discussed incident with Mrs. Golden What action was taken to notify the NRC, other Agreement States or licensees 7:
None Is the case closed?:
Yes Is record of incident in RAM files?:
Yes What enforcement action was taken?: None/ sources were imoounded & taken to RHP
(DRAFT)
INCIDENT REPORTING CHECK LIST (JULY 30, 1987) 1.
Date of Incident: June. 1990 Date RCP Notified: December 26. 1939 2.
Type of Incident or Alleged Incident: abandoned radioactive material.
licensee vacated oremise 3.
Was an investigation conducted by your staff? yes Date:
12/28/90 4.
Did the investigation reveal:
(check all. appropriate blocks)
[]
Loss of package effectiveness or contamination?
[]
Theft or loss of licensed material?
[ ]
Overexposure of individual to radiation or radioactive material?
[]
Excessive levels of radiation or concentrations of RAM?
[]
Safety failure of GL device?
[]
Equipment failure that could occur on similar devices?
[]
Leaking source?
[]
Misadministration?
[ ]
Tra.nsportation incident?
[]
Uranium mill occurrence?
[x]
Other If any boxes are checked or if the event is newsworthy, the event must be reviewed against the reporting criteria for Agreement State Materials Events (see All Agreement State letter dated July 22, 1986) and a description of the incident should be summarized as follows for the next NRC review.
(Use extra sheets if necessary).
SUMMARY
OF EVENT Licensee: Capital Medical Laboratories License No.:
MD-33-096-01 Location of event:
5100 Philadelphia Wav. Suite J. Lanham, Maryland Description of event:
The licensee vacated premises without notification.
In addition, the licensee failed to remove radioactive materials, and the landlord wanted to clean the lab, discose of the radioactive materials and rent it to another tenant.
2 drums of Bactec Vials (C-14 Isotope:
C-14. 1-125 Amount:
1 drum (3/4 full) 1-125 Event date: Licensee vacated in 6/90 Report date:
2/22/91 Identify any other licensees involved:
Licensee:
Ecology Services. Inc.
License No.:
MD-33-107-01 Jurisdiction:
Marvland Reciprocity Licensee: YA3)
Describe clean-up actions taken by you:
A radiological close-out survev will be conducted bv the RHP What measurements were taken: dose rate and contamination survevs What other action was required of you?: investiention was conducted What action was taken to notify the NRC, other Agreement States or licensees?:
NRC and Agreement States will be notified. RHP discussed incident with Lloyd Bolline, USNRC on 3/4/91 at 1045 hours0.0121 days <br />0.29 hours <br />0.00173 weeks <br />3.976225e-4 months <br /> Is the case closed?:
No Is record of incident in RAM flies?:
Yes What enforcement action was taken?: Investigation is ongoint. and a Department letter will be sent to Dr. Monica K. Rifaat. M.D.
(owner and RSO of Caoital Medical Laboratories), when tailine address becomes known.
l (DRAFT)
INCIDENT REPORTING CHECK LIST (JULY 30, 1987)
(
1.
Date of Incident: h2vember 21, 1990 Date RCP Notified: Xgvember 24. 1990 2.
Type of Incident or Alleged Incident: reuuest br oriv.ns_q_i.l ur_a to I
-va!n W c:n.cs.rL_;;di artjvt_ cat 3t._al._
f i
3.
Was an investigation conducted by your staff? yes Date:
11/ N / 30._
1.
Did the investigation reveal:
(check all appropriate blocks)
[]
Loss of package effectiveness or conta::iination?
[ ]
Thef t or loss of licensed material?
[]
Overexposure of individual to radiation or radioactive material?
[X]
Excessive levels of radiation or concentrations of RA>l?
[ ]
Safety failure of GL device?
[ ]
Equipment failure that could occur on similar devices?
[ ]
Leaking source?
I
[]
)lisadministration?
!]
Transportation incident?
[ ]
Uranium mill occurrence?
l If any boxes are checked or if the event is newsworthy, the event must be reviewed against the reporting criteria for Agreement State 3!aterials Events (see All A::;reement State letter dated July 22, 1986) and a description of the incident should be summarized as follows for the next NRC review.
(Use extra sheets if necessary).
SDi\\!ARY OF EVENT Licensee:
3 License No.:
l Location of event: 12. '. ci. -ju re b r i '. e. Eeva rn a Fark. Ra_rdar :i Description of event: __.LO nieno_nurier of declat+d qr.ali)um w ;nimi_.th.hht m ei*I sale l
_s1 ni1Ltd _pf ata um Amount:
10 u::i Isotope:
2 1
Event date:
_!.12._4.O_ '
Report date: __,__f[2 h/
/
Identify any other licensees involved:
Licensee:
- r. / a License No.:
n/a Jurisdiction:
n /r Reciprocity Licensee: Y / ',
Describe clean-up actions taken by you: i t em wr. s e : rv--vad 1.p.I.EIL r.t i n a t i c,_,
t a
and im rea j
l What measurements were taken:
1.0 mR/hr at centac-l What other action was required of you?: names to c:tt act.lgi_db ucs11_larm;ses What action was taken to notify the NRC, other Agree:::ent States or licensees?:
ne k
Is the case closed?:
Yn Is record of incident in RAi! files?:
.__.',.--s What enforcement action was taken?:
None i
l
(DRAFT)
INCIDENT REPORTING CHECK LIST (JULY 30, 1987) 1.
Date of Incident: November 2. 1990 Date RCP Notified: Wovember 2. 199Q 2.
Type of Incident or Alleged Incident: a private resident felt that she h_ad acauired Ra-226 3.
Was an investigation conducted by your staff? ves Date:' 11/20/90 4.
Did the investigation reveal:
(check all appropriate blocks)
[]
Loss of package effectiveness or contamination?
[]
Theft or loss of licensed material?
[]
Overexposure of individual to radiation or radioactive material?
[]
Excessive levels of radiation or concentrations of RAM?
[]
Safety failure of GL device?
[]
Equipment failure that could occur on similar devices?
[]
Leaking source?
[]
Mishdministration?
[]
Transportation incident?
[]
Uranium mill occurrence?
ly]
04her If any boxes are checked or if the event is newsworthy, the event must be reviewed against the reporting criteria for Agreement State Materials Events (see All Agreement State letter dated July 22, 1986) and a description of the incident should be summarized as follows for the next NRC review.
(Use extra sheets if necessary).
SUMMARY
OF EVENT Private Resident Licensee: __3rs. John Baker License No.:
N/A Location of event:
2639 Colston Drive. Chevy Chase. Marvland Description of event:
Telephone reauest bv a orivate resident to survev an unknown ob.iect which she susoected was radium-226.
Isotope:
N/A Amount:
N/A Event date:
11/2/90 Report date:
11/29/90 Identify any other licensees involved:
Licensee:
none License No.:
none Jurisdiction:
N/A Reciprocity Licensee:
Y/N Describe clean-up actions taken by you:
None What measurements were taken:
Instrument surveys and wines were negative What other action was required of you?: None What action was taken to notify the NRC, other Agreement States or licensees?:
None 1
Is the case closed?:
Yes Is record of incident in RAM files?:
Yes What enforcement action was taken?:
None i
(DRAFT)
INCIDENT REPORTING CHECK LIST (JULY 30, 1987) v 1.
Date of Incident: November 1. 1990 Date RCP Notified: November 1.
1990 2.
Type of Incident or Alleged Incident: a nuclear densitv cause was damaged bv a backhoe at a State Highway Administration site 3.
Was an investigation conducted by your staff? ves Date:
11/1/89 4.
Did the investigation reveal:
(check all appropriate blocks)
{]
Loss of package effectiveness or contamination?
[ ]
Theft or loss of licensed material?
[
Overexposure of individual to radiation or radioactive material?
[]
Excessive levels of radiation or concentrations of RAM?
[]
Safety failure of GL device?
[]
Equipment failure that could occur on similar devices?
[ ]
Leaking source?
[]
Misadministration?
[]
Transportation incident?
[]
Uranium mill occurrence?
[x]
Other If any boxes are checked or if the event is newsworthy, the event must be reviewed against the reporting criteria for Agreement State Materials Events (see All Agreement State letter dated July 22, 1986) and a description of the incident should be summarized as follows for the next NRC review.
(Use extra sheets if necessary).
SUMMARY
OF EVENT Licensee: Marvland State Highway Administration License No.:
MD-05-049-01 Location of event: Rt. 2 0 & Middlebrook Road, Germantown Maryland Description of event: The bucket from a backhoe struck the control nanel of a Troxler model 3440 nuclear density cauce and submerged a nortion of the rance into the soil.
Isotope:
8 mci. 40 mci Event date:
11/1/89 Report date:
12/3/90 Identify any other licensees involved:
Licensee:
Troxler Electtgnic Laboratories License No.:
MD-27-040-01 Jurisdiction:
Maryland Reciprocity Licensee: Yl[)
Describe clean-up actions taken by you:
None What measurements were taken:
wine / leak test. contamination survey of soil.
dose rate surver What other action was required of you?: investigation was conducted What action was taken to notify the NRC, other Agreement States or licensees?:
None Is the case closed?:
Yes Is record of incident in RAM files?:
Yes What enforcement action was taken?:
None
(DRAFT)
INCIDENT REPORTING CHECK LIST (JULY 30, 1987)
-(
~
1.
Date of Incident: October 29, 1990 Date RCP Notified: October 29. 1990 2.
Type of Incident or Alleged Incident: Contamination of construction worker in vicinity of a radioactive material incinerator.
3.
Was an investigation conducted by your staff? ves Date:
10/29/90 4.
Did the investigation reveal:
(check all appropriate blocks)
{]
Loss of package effectiveness or contamination?
[]
Theft or loss of licensed material?
[]
Overexposure of individual to radiation or radioactive material?
[]
Excessive levels of radiation or concentrations of RAM?
[]
Safety failure of GL device?
[]
Equipment failure that could occur on similar devices?
[]
Leaking source?
[]
Misadministration?
[]
Tran'sportation incident?
[]
Uranium mill occurrence?
CxJ Othea.
If any boxes are checked or if the event is newsworthy, the event must be reviewed against the reporting criteria for Agreement State Materials Events (see All Agreement State letter dated July 22, 1986) and a description of the incident should be summarized as follows for the next NRC review.
(Use extra sheets if necessary).
SUMMARY
OF EVENT Licensee: Johns Honkins Medical Institutions (JHMI) License No.: MD-07-005-013 Location of event:
Johns Honkins in Baltimore, Marvland Description of event:
A construction crew working on a building ad.iacent to the JHMI radioactive material incinerator. complained of illness when exoosed to incinerator effluent smoke.
Isotope:
N/A Amount:
N/A Event date:
10/29/90 Report date:
1/25/91 Identify any other licensees involved:
Licensee:
none License No.:
none Jurisdiction:
N/A Reciprocity Licensee:
Y/N Describe cican-up actions taken by you:
None necessarv What measurements were taken: Review of JHM1 effluent evaluation What other action was required of you?:
None i
What action was taken to notify the NRC, other Agreement States or licensees?:
_ Sone l
I-j Is the case closed?:
Yes Is record of incident in RAM files?:
Yes What enforcement action was taken?:
None
f (DRAFT)
INCIDENT REPORTING CHECK LIST (JULY 30, 1987) i N
1.
Date of Incident: October 26. 1990 Date RCP Notified: October 26, 1990 2.
Type of Incident or Alleged Incident: denleted uranium was found in a barn in Dickerson Maryland 3.
Was an investigation conducted by your staff? ves Date:
10/26/90 4.
Did the investigation reveal:
(check all appropriate blocks)
{ ]
Loss of package effectiveness or contamination?
[]
Theft or loss of licensed material?
[]
Overexposure of individual to radiation or radioactive material?
[]
Excessive levels of radiation or concentrations of RAM?
[]
Safety failure of GL device?
[ ]
Equipment failure that could occur on similar devices?
[ ]
Leaking source?
[ ]
Misadministration?
[ ]
Transportation incident?
[ ]
Uranium mill occurrence?
[x]
Other If any boxes are checked or if the event is newsworthy, the event must be reviewed against the reporting criteria for Agreement State Materials Events (see All Agreement State letter dated July 22, 1986) and a description of the incident should be summarized as follows for the next NRC review.
(Use extra sheets if necessary).
SUMMARY
OF EVENT Licensee:
';eutron Preducts, Inc. (NPI)
License No.:
MD-31-025-03 Location of event: Eert tvtla's P,arn. 20520 Mouth of Monocaev Rd. Dickerson M3-Description of event:
Sir (6) teletheraov collimators certaining declete.i uranium (DC) were foun U n this barn, and not authorized under the license.
The door to the barn was unlocked and unattended.
The barn is owned bv Mr.
Eart Ldle, Montcomerv County resident, and is rented to NPI.
Isotope:
Amount: 6 teletheraov collinators Event date:
10/26/90 Report date:
2/11/91 Identify any other licensees involved:
Licensee:
None License No.:
N/A Jurisdiction:
N/A Reciprocity Licensee:
Y/N Describe clean-up actions taken by you:
None What measurements were taken:
dose rate survey. wipe surver What other action was required of you?: jnvestication of incident conducted What action was taken to notify the NRC, other Agreement States or licensees?:
None Is the case closed?:
No Is record of incident in RAM files?:
Yes What enforcement action was taken?: Departmental Letter / Civil Penalty
(DRAFT)
INCIDENT REPORTING CHECK LIST (JULY 30, 1987)
(
l.
Date of Incident: October 4, 1990 Date RCP Notified: October 4. 1990 2.
Type of Incident or Alleged Incident: ootential contamination of aluminum targets used for denleted uranium shells 3.
Was an investigation conducted by your staff? ves Date:
8/5/90 4.
Did the investigation reveal:
(check all appropriate blocks)
{]
Loss of package effectiveness or contamination?
[]
Theft or loss of licensed material?
[]
Overexposure of individual to radiation or radioactive material?
[]
Excessive levels of radiation or concentrations of RAM?
[ ]
Safety failure of GL device?
[]
Equipment failure that could occur on similar devices?
[]
Leaking source?
[ ]
Misadministration?
[]
Tran'sportation incident?
[]
Uranium mill occurrence?
C61 t)+h cA.
If any boxes are checkad or if the event is newsworthy, the event must be reviewed against the reporting criteria for Agreement State Materials Events (see All Agreement State letter dated July 22, 1986) and a description of the incident should be summarized as follows for the next NRC review.
(Use extra sheets if necessary).
SUMMARY
OF EVENT Non-licensee Licensee:
Clark Machine Company License No.:
N/A location of event:
1000 Todd lane. Baltimore. Maryland Description of event: _ Unidentified Clark Machine emoloyee complaint regarding concern of denleted uranium contamination of artillerv targets acauired from the Aberdeen Proving Ground.
Isotope:
N/A Amount:
N/A Event date:
10/4/90 Report date:
11/29/90 Identify any other licensees involved:
Licensee:
Aberdeen Proving Ground License No.:
USNRC Jurisdiction:
USSRC Reciprocity Licensee: _1/3}__
{
Describe clean-up actions taken by you:
Instrument survevs confirming that there was no DU contamination What measurements were taken:
All measurements background What other action was required of you?: Letter of findines to carties involved What action was taken to notify the NRC, other Agreement States or licensees?:
John McGrath. NRC. Rerion-I notified bv ohone i
l Is the case closed?:
Yes Is record of incident in RAM files?:
Yes l
What enforcement action was taken?:
None l
\\
(.
(DRAFT)
INCIDENT REPORTING CHECK LIST (JULY 30, 1987)
\\
1.
Date of Incident:gentember 24. 1990 Date RCP Notified:Sentember 25, 1990 2.
Type of Incident or Alleged Incident: hospital oersonnel were contaminated with Thallium-201 3.
Was an investigation conducted by your staff? ves Date:
9/26/90 4.
Did the investigation reveal:
(check all appropriate blocks)
[]
Loss of package effectiveness or contamination?
[]
Theft or loss of licensed material?
[]
Overexposure of individual to radiation or radioactive material?
[ ]
Excessive levels of radiation or concentrations of RAM?
[ ]
Safety failure of GL device?
[]
Equipment failure that could occur on similar devices?
[]
Leaking source?
[]
Misadministration?
[]
Trahsportation incident?
[ ]
L'ranium mill occurrence?
[x]
Other If any boxes are checked or if the event is newsworthy, the event must be reviewed against the reporting criteria for Agreement State Materials Events (see All Agreement State letter dated July 22, 1986) and a description of the incident should be summarized as follows for the next NRC review.
(Use extra sheets if necessary).
SUMMARY
OF EVENT Licensee: Peninsula Genaral Hesnital License No.:
'!D-45-001-03 Location of event:
100 East Carroll Street. Salisbury, Maryland 21801 Description of event:
Four hotnital employees were contaminated with Thalliun-201, when an IV connection ruptured on a natient that was beine in.iected for a Atrial Pacine Thallium Scan.
Isotope:
l
_Th;t li um-201 Amount:
3.8 nCi Event date:
9/24/90 Report date:
10/2/90 Identify any other licensees involved:
Licensee:
None License No.:
N/A Jurisdiction:
N/A Reciprocity Licensee: _1/N Describe clean-up actions taken by you: None What measurements were taken: Contamination surver, wine surver What other action was required of you?: investication of incident conducted What action was taken to notify the NRC, other Agreement States or licensees?:
None Is the case closed?:
Yes Is record of incident in RAM files?:
Yes What enforcement action was taken?:
None
7--
r e
r (DRAFT)
INCIDENT REPORTING CHECK LIST (JULY 30, 1987) 1.
Date of Incident: Aucust 29.1990 Date RCP Notified: aun:n ip 1990 2.
Type of incident or Alleged Incident: _ Cc_- 0 i r.2 n11an_b e e:91 cn.; x _
'3 l.:C ' 1:'.Lu f s r._..... __. _._ __ _ _.....,..
a 3.
Was an investigation conducted by your staff?
"es Date:
4.
Did the investigation reveal:
(check all appropriate blocks)
{ }
Loss of package effectiveness or contamination?
[ ]
Theft or loss of licensed material?
[ ]
Overexposure of individual to radiation or radioactive material?
!X]
Excessive levels of radiation or concentre.tions of RA>l?
[ ]
Safety' failure of GL device?
[ ]
Equipment failure that could occur on si ilar devices?
.' ]
Leaking source?
( }
>!isadministration?
[ }
Transportation incident?
{ )
Cranium mill occurrence?
If an-boxes are checked or if the event is newswcrthy, the event must be reviewed against the reporting criteria for Agreement State >!aterials Events (see All Agreement State letter dated July 22, 1996) and a description of the t
incident s:r.culd be summarized as follows for the next NRC review.
(l'se extra sheets :f necessary).
SDDIARY OF EVENT License No.: JQ-31 -015-01 Licensee:
.-rr.-
' -..u"ts, b
' '~
4 Location of event:
2 2.'31 \\: t.J h r '+ : n E mi.1 'd e:-M ri_:;;,_. x.r sia,! 2 0 Y h Description of event:
S P.i ' :e radiati n nfe'- 0.! c e r unitt +;i m;:!Lika!ij y__
-(_igi!cvinc. bo t c-i 1 c !-w.;;. y;3_i,;, it nj,,,.1 : _ outh tt:jpgfn
& r i.::
- t. h e ': r - u d r. n e rora <iu ty_._..
Isotope:. _. _..i.-ps _
-Arount:
__.hy -;; -:!
_]D_ u O Event date:.1 'EF 99 Report date:
._,f, L/ 3 0 Jdentify any other licensees involved:
Licensee:
n/a license No.:
n/a Jurisdiction:
n/a Reciprocity Licensee:
Y/S Describe clean-up actions taken by you:
None What measurements were taken:
What other action was required of you?:
Inver.i m :. el ut;t;Lqi.ast i.,n 2: n t m. W i t. irs st; t ou rsizht ahat action was taken to notify the NRC, other Agreement States or licensees?:
I
..w Is the case closed?:
Yes Is record of incident in RA>l files?:
Yo What enforcement action was taken?:
None m__
l
)
i (DRAFT)
INCIDENT REPORTING Ci!ECK LIST (JULY 30, 1987) f
(
1.
Date of Incident: 3urus._'.L _ 1990 Date RCP Notified: Aucust 10, 1990 2.
Type of Incident or Alleged Incident: 1 Lt_1 i.0.5 _kitqntpra.ou rm____ __
f d1. mink.a Aa(i.ent iqJ ua 3.
Was an investigation conducted by your staff?
Date:
-1.
Did the investigation reveal:
Icheck all appropriate blocks)
[ ]
Loss of package effectiveness or contamination?
[X)
Theft or loss of licensed material?
[ ]
Overexposure of individual to radiation or radioactive material?
[ ]
Excessive levels of radiation or concentrations of RAM?
!]
Safety failure of GL device?
[ ]
Equipment failure that could occur on similar devices?
[ ]
Leaking source?
[ ]
Nisadministration?
[ ]
Transportation incident?
[ ]
Uranium mill occurrence?
If any boxes are checked or if the event is newsworthy, the event must be reviewed against the reportin;; criteria for Agreement State Materials Events (see All Agreement State letter dated Jcly 22, 1986) and a description of the incident should be summarized as follows for the next NRC review.
(Use extra sheets if necessary).
SDiMARY OF EVEST Licensee:
a.v h u. U. :
C'.
n_t _.e_ u_.... j_67 ' d. License No.:.).1D-1 901 - TJ Location of event:
2.4. Kiu..
.. e.. n f. ; r e -- ; :
M r "s t own, Mar.yJ n':0 Description of event:. C!o m _;.:.,D;2iant of I - l '15 s e ed s i TLt.t.t_p_ p a_tj e_p * '_s
' a l t b j - seeds w+ re t.J.e;p ei _tri;;_timArj_;;bi._31.jgs at d ! cur s eens t
. _6 1
u._. ; Ml v !cyt.
141 Isotope:
! r - -h
_______.._ _ Amount: *00 t:Ci 1 er seed Event date:
F l / 9')
.. _. _ _. _.. _ _ _ Report date: _J_03 490 Identify any other licensees involved:
Licensee:
nS License No.:
n/a Jurisdiction:
n" Reciprocity Licensee: 7/S Describe clean-up actions taken by you: I.i:Xg i ca: Inn t f licensee oversi rl;.L__.
- nj_j c v"'
t-c:.nicues follcy!. t h ;.p_t of th*rst" sa What neasurements were taken: M p.L_13, #::er : m;;.a Jytector for search t 1 l_[AM s t i t.':1 What other action was required of you?:
- 5. :. e-f What action was taken to notify the NRC, other Agreement States or licensees?:
1 un.
' 0. at h m;t i uni _S5miqtd w.;_:i ndt:ni s: n ien of seeds in wrone 1: ne Is the case closed?:
Yee Is record of incident in RAM files?:
Tes What enforcement action was taken?: Notice ef Vic!=. tion issued to licensee
E g
(DRAFT)
INCIDENT REPORTING CHECK LIST (JULY 30, 1987) i l.
Date of Incident: July 10, 1990 Date RCP Notified: July 10, 1990 2.
Type of Incident or Alleged Incident: unauthorized diagnosis of oatients under the license 3.
Was an it.vestigation conducted by your staff?
ves Date:
7/18/90 4.
Did the investigation reveal:
(check all appropriate blocks)
[]
Loss of package effectiveness or contamination?
[]
Theft or loss of licensed material?
[]
Overexposure of individual to radiation or radioactive material?
[]
Excessive levels of radiation or concentrations of RAM?
[]
Safety failure of GL device?
[]
Equipment failure that could occur on similar devices?
[]
Leaking source?
[]
Misadministration?
[]
Transportation incident?
[]
Uranium mill occurrence?
Cg]
Ot hc A.
If any boxes are checked or if the event is newsworthy. the event must be reviewed against the reporting criteria for Agreement State Materials Events (see All Agreement State letter dated July 22, 1986) and a description of the incident should be summarized as follows for the next NRC review.
(Use extra sheets if necessary).
SUMMARY
OF EVENT Licensee:
Cardiac consultants Chartered (CCC1 License No.:
>ID-31-110-01 Location of event:
6410 Rockledge Drive. Bethesda, Marvland Description of event:
From April, 1986 to July 10, 1990, ohysicians at CCC vere diagnosing (reading) nuclear cardiologv natient's scan without being authorized by the license.
Isotope:
N/A Amount:
N/A Event date:
7/10/90 Report date:
9/28/90 Identify any other licensees involved:
Licensee:
none License No.:
none Jurisdiction:
N/A Reciprocity Licensee: Y/N Describe clean-up actions taken by you:
None What measurements were taken:
None What other action was required of you?: Investigation What action was taken to notify the NRC, other Agreement States or licensees?:
None k
Is the case closed?:
Yes Is record of incident in RAM files?:
Yes 1
What enforcement action was taken?: Temocrary suspension of RAM ooerations 1
e i
j (DRAFT 1 INCIDENT REPORTING CHECK LIST (JULY 30, 1987) t 1.
Date of Incident: June 6, 19'30 Date OCP Notified: Julv 7, 1990 2.
Type of Incident or Alleged Incident:
Extre. tite overexuosure 3.
Was an investigation conducted by your staff? ves Date:
7/11/00 4.
Did the investigation reveal:
(check all appropriate blocks)
[]
Loss of package effectiveness or contamination?
[]
Theft or loss of licensed material?
[X]
Overexposure of individual to radiation or radioactive material?
[ ]
Excessive levels of radiation or concentrations of RAM?
[]
Safety failure of GL device?
[ ]
Equipment failure that could occur on similar devlees?
[]
Leaking source?
[ ]
Misadministration?
[ ]
Transportation incidenL?
[ ]
Cranium mill occurrence?
If an: boxes are checked or if the event is newsworthy, the event must be reviewed against the reporting criteria for Agreement State Materials Events (see All Agreement State letter dated July 22, 1986) and a description of the incident should be summarized as follows for the next NRC review.
(Use extra sheets if necessary).
SUMMARY
OF EVENT Licensee:
Ncotron f_rnducts. I t.r.
' "i )
___ License No.:.lD-31-013-O L__ _
Location of event:
TB01 9. r+ hmi: f.c ad. Cickemn. Marylaqi 2034; Description of event:
Rout ine nrx e% W_ of an en-l_;;yee's exj;remi ty badges hni ell cliatun 1:a g.ated t~.at his 3 conth ext.osure exceedec e n en :ert to a r
t t.t _L c /4 RD! limit Isotope:
Co d0 Amount:
- ot - exncsu.r_e-20.512 EEM Ecent date:
t /QLd0
_ Report date:
t /21_f Q0 Identify any other licensees involved:
Licensee:
n/a License No.:
n/a Jurisdiction:
n/a Reciprocity Licensee:
Y/S Describe clean-up actions taken by you:
None What measurements were taken:
bjl4 E What other action was required of you?:
2nvestitati:n of circumstances What action was taken to notify the NRC, other Agreement States or licensees?:
(
Is the case closed?:
Yes Is record of incident in RAM flies?:
Yes What enforcement action was taken?:
Notice of Violation issued civil cenaltv 13-Notice of Violation issued
(DRAFT)
INCIDENT REPORTING CHECK LIST (JULY 30, 1987) ik'-
1.
Date of Incident: June 13,1993
__ Date RCP Notified: June 13. 1990 2.
Type of Incident or Alleged Incident: emolocee intestien of cobyit-GO at tunnfsetu ri ng_[aqLi[tv 3.
Was an investigation conducted by your staff? yes Date:
7/9/90 4.
Did the investigation reveal:
(check all appropriate blocks)
[]
Loss of package effectiveness or contamination?
[]
Theft or loss of licensed material?
[ ]
Overexposure of individual to radiation or radioactive material?
[X)
Excessive levels of radiation or concentrations of RAM 7
[]
Safety failure of GL device?
[]
Equipment failure that could occur on similar devices?
4
[ ]
Leaking source?
~!
[ ]
Misadministration?
[ ]
Transportation incident?
[ ]
Uranium mill occurrence?
If any boxes are checked or if the event is newsworthy, the event cust be i
reviewed against the reporting criteria for Agreement State Materials Events (see All Agreement State letter dated July 22, 1986) and a description of the incident should be summarized as follows for the next SRC review.
(Use extra sheets if necessary).
SUMMARY
OF EVENT Licensee:
Neutr.:m rv W;tt, ?nc. ( W' )
License No.:._'R _.d - T ' - C L _.
Location of event: _;$ 91 W Echrnit Fo:.c. i;i rkerre..i r l;ggl_;t %
Description of event:
S PL_r m niev-intested i d2 uCi of cobsit
',0 udie.
nLtjna _t_l e man 2f act i*.s b;L cell. fodavinc a c lea *.u ' er t hat ( +13 l
lsotope:
Co-69 Amount: _1 1 'e uti Event date:
6/13/9C Report date:
E 11/23 l
Identify any other licensees involved-Licensee:
n/a License No.:
t/a
-l Jurisdiction:
n/a Reciprocity Licensee:
yin j
Describe clean-up actions taken by you:
None What measurements were taken:
What other action was required of you?:
Inves:icatien of ';PI manacement hot gall cleanur oversicht What action was taken to notify the NRC, other Agreement States or licensees?:
None Is the case closed?:
Yes is record of incident in RAM files?:
Yes What enforcement action was taken?: - Notice of Violation is sued wiLite t her collectise vfolaticns, reFMItinf in h Civi! Den 3}tV
1 e
e
,r (DRAFT)
INCIDENT REPORTING CHOCK LIST (JULY 30, 1987) k i
1.
Date of Incident: May. 1990 Date RCT Notified: May 31. 1990 1
2.
Type of Incident or Alleged Incident: lost cesium-137 sealed source 5/31/90 3.
Was an investigation conducted by your staff? yes Date: 6/1.5 & 26/90 4.
Did the investigation reveal:
(check all appropriate blocks)
[]
Loss of package effectiveness or contamination?
[x]
Theft or loss of licensed material?
{]
Overexposure of individual to radiation or radioactive material?
[ ]
Excessive levels of radiation or concentrations of RAM?
[]
Safety failure of GL device?
[ ]
Equipment failure that could occur on similar devices?
[]
Leaking source?
[]
Misadministration?
()
Transportation incident?
[]
Uranium mill occurrence?
If any boxes are checked or if the event is newsworthy, the event must be reviewed against the reporting criteria for Agreement State Materials Events (see All Agr?cment State letter dated July 22, 1986) and a description of the incident sho.:1d be summarized as follows for the next NRC review.
(Use extra nheeta if ne:essary).
SUMMARY
OF EVENT Licent.ee: CTl Consultants. Inc.
License No.: MD-33-101-01 Location of 2 vent: Eield sites (s); (1) Naval Intelligence Ctr. in Suitland. MD and (2) Metro Station. Reedie Road & Georgia Avenue in Wh pton. MD t
Description of event:
Licensee was informed by Troxler Labs' Maryland office, that this cesium-137 sealed source was broken off at the weld.ioint and missing from a M/D 3401-B gauge. #4029.
Intensive searches of both field sites and licensee's office were nerformed by MDE-RHP and the licensee's egnsultant. Radiation Service Organization of Laurel. MD.
Source was never t.ecovered.
Isotope:
Cesium-137 Amount:
8 millicuries Event date:
5/90 Report date:
5/31/90 Tientify any other licensees involved:
Troxler Electronic Labs, MD-27-040-01 & NRC 32-05998-03 Licensee:
Radiation Service Organization License No.: MD-33-021-02 Jurisdiction: Maryland Const! tant Reciprocity Licensee: Y/R) 1 Describe clean-up actions taken by you:
None What mensurements were taken*. Radiation surveys of field sites involved. All background (BKG).
What other action was required of you?: Additional field site visits with consultant aad licensee with monitoring of all subseauent activities.
What action was taken to notify the NRC, other Agreement States or licensees?:
Telecons wit) NRC-Region 1. Troxler Labs & North Carolina Radiation Program.
Also, there was written correspondence from CTI. Troxler Lab & Rad. Serv. Orat Is the case closed?:
Yes Is record of incident in RAM files?:
Yes Fhat enforce nent action was taken?: Comoliance letter to CTI
~
(DRAFT)
INCIDENT REPORTING CHECK LIST (JULY 30, 1987) 1.
Date of Incident: Mav 23, 1990 Date RCP Notified: May 23, 1990 2.
Type of Incident o: Alleged Incident: cossession of radioactive material without a license 3.
Was an investigation conducted by your staff? ves Date:
5/24/90 4.
Did the investigation reveal:
(check all appropriate blocks)
[]
Loss of package effectiveness or contamination?
[]
Theft or loss of licensed material?
[]
Overexposure of individual to radiation or radioactive material?
[]
Excessive levels of radiation or concentrations of RAM?
[]
Safety failure of GL device?
[]
Equipment failure that could occur on similar devices?
[]
Leaking source?
[ }
Misadministration?
[]
Transportation incident?
[]
Uranium mill occurrence?
[>G CfheA If any boxes are checked or if the event is newsworthy, the event must be reviewed against the reporting criteria for Agreement State Materials Events-(see All Agreement State letter dated July 22, 1986) and a description of the incident shc-Id be summarized as follows for the next NRC review.
(Use extra sheets if net ;sary).
SUMMARY
OF EVENT Non-licensee Licensee:
Soil Safe Inc. (SSI)
License No.:
N/A Location of event:
4600 E. Favette Street. Baltimore Marvland Description of event:
SS1 uurchased a noisture/ density cause via nuetion without initiallv acuuirine a license.
Isotope:
Cs-137 Amount:
100 mC1. 60 mci Event date: _5/23/90 Report date:
9/7/90 Identify any other licensees involved:
Licensee: ___
none License No.:
none Jurisdiction:
n/a Reciprocity Licensee:
Y/N Describe clean-up actions taken by you:
None What measurements were taken:
Instrument survevs of device What other action was required of you?:
Transfer to l'niversity of Maryland What action was taken to notify the NRC, other Agreement States or licensees?:
(
Is the case closed?:
So Is record of incident in RAM files?:
Yes What enforcement action was taken?:
None
(DRAFT)
INCIDENT REPORTING CHECK LIST (JULY 30, 1987) k 1.
Date of Incident: Aoril 26. 1990 Date RCP Notified: May 4. 1990 2.
Type of Incident or Alleged Incident: lost Co-57 marking source at Francis Scott Kev Medical Center in Baltimore. Maryland 3.
Was an investigation conducted by your staff? yes Date:
7/3/90 4.
Did the investigation reveal:
(check all appropriate blocks)
[]
Loss of package effectiveness or contamination?
[x]
Theft or loss of licensed material?
[]
Overexposure of individual to radiation or radioactive material?
[]
Excessive levels of radiation or concentrations of RAM?
[]
Safety failure of GL device?
[]
Equipment failure that could occur on similar devices?
[]
Leaking source?
[]
Misadministration?
[]
Transportation incident?
l]
Uranium mill occurrence?
If any boxes are checked or if the event is newsworthy, the event must be reviewed against the reporting criteria for Agreement State Materials Events (see All Agreement State letter dated July 22, 1986) and a description of the incident should be summarized as follows for the next NRC review.
(Use extra sheets if necessary).
SUMMARY
OF EVENT Licensee: Francis Scott Kev Medical Center License No.:
MD-07-008-07 Location of event:
Nuclear Medicine Deut., 4940 Eastern Ave.. Baltimore MD Description of event:
A 25 uCi. Co-57 marking source was misolaced in the Nuclear Medicine Dept.
The source was in a shielded container and placed in an unearked wooden box.
Annarentiv, this box containine the source, was inadvertently discarded into the regular trash.
Isotope:
Co-57 Amount:
25 uCi Event date:
4/26/90 Report date:
8/16/90 Identify any other licensees involved:
Licensee:
None License No.:
N/A Jurisdiction:
N/A Reciprocity Licensee: Y/N Describe clean-up actions taken by you:
None What measurements were taken: None What other action was required of you?: investigation of incident conducted What action was taken to notify the NRC, other Agreement States or licensees?:
None Is the case closed?:
Yes Is record of incident in RAM files?:
Yes What enforcement action was taken?: Licensee was cited for failure to secure radioactive materials against unauthorized removal from olace of storare and the unauthorized disposal of radioactive materials.
9 1
e s
a
- (DRAFT)
INCIDENT REPORTING CHECK L'!ST (JULY 30, 1987) e i
\\
2.
Date of incident:
1/90 Date RCP notified:
all a /qn 2.
Type of Incident or Alleged Incident:
Nuclaar racemaker was removed
__frnm rmtient and mailed to company but lost in transit.
3.
Was an investigation conducted by your staff? vec Date: av>nion 4.
Did the investigation reveal:
(check all appropriate blocks)
{
} Loss of package effectiveness or contamination?
([ X)) Thef t or loss of licensed materf al?
Overexposure of IndivJdual to radiation or radioactive materfal?
[
] Excessive levels of radiation or concentrations of RAM 7
[
] Safety failure of GL devjce?
[
} Equipment failure that could occur on sim!!ar devices?
[
] Leaking source?
(
} Misadministration?
(
) Transportation incident?
[
] Uranium mill occurrence?
If any boxes are checked or if the event is newsworthy, the event must be reviewed against the reporting criteria for Agreement State Materials Events (see All Agreement State letter dated July 22, 1986) and a description of the incident should be suamarized as follows for the next NRC review. (Use extra sheets jf necessary.)
SUMMARY
OF EVENT Licensee: Einai Hoscita1 License No.:
MD-07-011-03 Location of event: Ashton-Bradlev Funeral Home-2135 Dundalk Avenue Description of event: Nuclear nacemaker was removed from tatient at the Sere-al h-ma. mhe madical examiner was informed of the nacemaker bu dur4 m autorsv did not remove or return it to Sinai as instructed.t vailed to 7melant Technoloav in Bothell, Washincton but lost in trardit Isotope:
D-M P Amount:
169 mi))icrams Event Date:
4/11/00 Report Date:
4/11/90 Identify any other. licensees involved:
Licensee:
NONE License No.:
N Jurisdiction:
N /4 Reciprocity Licensee: Y/N Describe clean-up actions taken by you:
Mnne reouived What sensurements were taken?
NONE What other action was required of you?
rnnt er wi+b nex+n nf washinntnn What action was taken to notify the NRC, other Agreement States or licensees?
(
Both NFC and Washincton notified when we became aware of loss.
Is the case closed?
NO In record of incident in RAM files? YES What enforcement action was taken? NO)J6
f (DRAFT)
INCIDENT REPORTING CHECK LIST (JULY 30, 1987) l l.
Date of Incident: Earch 21. 1990 Date RCP Notified: April 6. 1990 2.
Type of Incident or Alleged Incident: notification of notential ngrsonnel overexoosure 3.
Was an investigation conducted by your staff? ves Date:
4/17/90 4.
Did the investigation reveal:
(check all appropriate blocks)
[]
Loss of package effectiveness or contamination?
[]
Theft or loss of licensed material?
[]
Overexposure of individual to radiation or radioactive material?
[x]
Excessive levels of radiation or concentrations of RAM?
[]
Safety failure of GL device?
[]
Equipment failure that could occur on similar devices?
[]
Leaking source?
[ ]
Misadministration?
[]
Transportation incident?
[]
Uranium mill occurrence?
If any boxes are checked or if the event is newsworthy, the event must be reviewed against the reporting criteria for Agreement State Materials Events (see All Agreement State letter dated July 22, 1986) and a description of the incident should be summarized as follows for the next NRC review.
(Use extra sheets if necessary).
SUMMARY
OF EVENT Licensee:
Genstar Stone products Compant License No.:
MD-05-019-01 Location of event: Marriottsville Maryland Description of event: Translocation of Ohmart level gauces bv non-radiation, non-badced personnel.
The shutter of one 86 mci Cs-137 cause was open durinc
_transnort for an undetermined amount of time.
Isotope:
Cs-137 Amount:
86 mci Event date:
3/21-22/90 Report date:
6/5/90 Identify any other licensees involved:
Licensee:
Ohmart Corn.
License No.:
34-00639-01 Jurisdiction:
l'SNRC Reciprocity Licensee: ([)N Describe clean-up actions taken by you:
What measurements were taken:
t What other action was required of you?: investigation reenactment with calculated doses for carticipants What action was taken to notify the NRC, other Agreement States or licensees?:
Is the case closed?:
Yes Is record of incident in RAM files?:
Yes What enforcement action was taken?: NOV sent to Genstar and Ohmart
-(DRAFT)
INCIDENT REPORTING CHECK LIST (JULY 30, 1987)
I k -
1.
Date of Incident: 3t'ril 4. D90 Date RCP Notified: 3 ril 5. J22.Q_.__
2.
Type of Incident or Alleged Incident: po_teni b_L ac-:Tripg uing_pdri;e;t 11esJc4itut_;bnLnun _
3.
Was an investigation conducted by your staff? res Date: _4M/90 4.
Did the investigation reveal:
(check all appropriate blocks)
[]
Loss of package effectiveness or contamination?
[]
Theft or loss of licensed material?
[ ]
Overexposure of individual to radiation or radioactive material?
[ ]
Excessive levels of radiation or concentrations of RA>l?
[ ]
Safety failure of GL device?
{]
Equipment failure that could occur on similar devices?
[ ]
Leaking source?
[ ]
Silsadministration?
[ ]
Trarisportation incident?
[ ]
Cranium mill occurrence?
DG OtheA If any boxes are checked or if the event is newsworthy, the event must be revit-wed against the reporting criteria for Agreement State >laterials Events
!see All Agreement State letter dated July 22, 1986) and a cescription of the incident should be summarized as follows for the next NRC review.
(Use extra sheets if necessary).
SU)l>1ARY OF EVENT Licensee:
'+ !J;jn t_ i
- e e.1 License No.: 21 i-J'.i.i2.-l.;___
Location of event:. i tr.i-icint. h r_s ! nd Description of event:
k n~n thor t;;ed t ram leca. lien ( : : DA:: sautes, c ne o f __ _ _
_h G t he y qql.Lt_Qi.sj.i m P V hm e b+eji eten.
Ftgr c oc x - WIyyn;;t i _w3 tu.,_
M :. o ;' ed w O h_f. in n1.i_'il._t f__stgj dos e.
l Isotope:
C a-Mi Amount: _s.kJ_.fj Event date:
4/4 8.
Report date:
U1M Identify any other licensees involved:
Licensee:
n/a License No.:
ris Jurisdiction: __n/n Reciprocity Licensee:
d';
Describe clean-up actions taken by you:
What measurements were taken: _OAuce surveys What other action was required of you?:
A restrurture cLnnre pt. overgj g What action was taken to notify the NRC, other Agreement States or licensees?:
ne l
5 Is the case closed?:
'f % Is record of incident in RA'l files?:
What enforcement action was :aken?: Enf. 1-t ter foll>.i i t r7L. ce, fe rw:e
)
i 1
1 DRAFT)
INCIDENT REPORTING CHECK LIST (JULY 30, 1987) 1.
Date of Incident: March 28, 1990 Date RCP Notified: _ March 28, 1990 _
2.
Type of Incident or Alleged Incident; fire in facil!U._U.at dlS.irilutts t mMa_.5Letar.:10r.L 3.
Was an investigation conducted by your staff? _Eas Date:
3/28/90 4.
Did the investigation reveal:
(check all appropriate blocks)
[X)
Loss of package effectiveness or contamination?
[ ]
Theft or loss of licensed material?
[ ]
Overexposure of individual to radiation or radioactive material?
[ ]
Excessive levels of radiation or concentrations of RAM?
[ ]
Safety failure of GL device?
[ ]
Equipment failure that could occur on similar devices?
[ ]
Leaking source?
[ ]
Misadministration?
[ ]
Tra6sportation incident?
!)
Cranium mill occurrence?
If any boxes are checked or if the event is newsworthy, the event must be reviewed against the reporting criteria for Agreement State Materials Events (see All Agreement State letter dated July 22, 1986) and a description of the incident should be summarized as follows for the next SRC review.
(Use extra sheets if necessary).
SUMMARY
OF EVENT Licensee:
- m al t,-eurits ins t row. Inc.
License No.:
'8 000-01 Location of event:
1 J 3 4 Scm h DN f ! c-:.;_E_e.n.d. N i t.n Mi 11s. ':D 21117 Description of event:
Fire vithin ec m nv vareh:use whery 'd0 e.moke de e rtcrs were vi;ren, htensive fire danac+ to unit s oc rred with 0:,tential Insni_
o.n t a wn: w! centarination of facilits.
Isotope:
An-241 Amount: 000 4:1 eer unit Event date: _.f dLiG
_,. Report date:
4 O/90 Identify any other licensees involved:
Licensee:
n/a License No.:
n/a Jurisdiction:
n/a Reciprocity Licensee; n/a Describe clean-up actions taken by you:
Surv+ve and vices indicated no loss or cot.tsinment or contamination. Fu.it s vere cel!+ ted and nla:ed in secure storare.
What measurements were taken:
4!cha detector surter and 6 ires What other a.: tion was required of you?:
Se r.e What action was taken to notify the SRC, other Agreement States or licensees?:
(
' <n e Is the case closed?:
Yes Is record of incident in RAM files?:
Yes What enforcement action was taken?:
Vone
,, -. ~. -
(DRAFT)
INCIDENT REPORTING CilECK LIST (JULY 30, 1987) e
.I 1.
Date of Incident: March 11. 1990 Date RCP Notified: March 11. 1990 2.
Type of Incident or Alleged Incident: abandoned sources / contaminated container 3.
has an investigation conducted by your staff? ves Date:
3/11/90 4.
Dic the investigation reveal:
(check all appropriate blocks)
[x]
Loss of package effectiveness or contamination?
[]
Theft or loss of licensed material?
['
overexposure of individual to radiation or radioactive material?
IJ Excessive levels of radiation or concentrations of RAM?
[]
Safety failure of GL device?
[]
Equipment failure that could occur on similar devices?
[ ]
Leaking source?
[]
Misadministration?
[]
Transportation incident?
[]
Uranium mill occurrence?
If any boxes are checked or if the event is newsworthy, the event must be reviewed against the reporting criteria for Agreement State M terials Events (see All Agreement State letter dated July 22, 1986) and a description of the incident should be summarized as follows for the next NRC review.
(Use extra sheets if necessary).
SUMMARY
OF EVENT Licensee:
N/A License No.:
MD-05-019-01 Location of event: 1201 East Cold Sprine Lane, P.altinore. Maryland Description of event:
Two radiut check sources were found in a cor.tamir:ated Pb centainer and were abandoned at the Marvland Civil Defense. Baltimore Feadouarters.
2 check sources Isotope:
Padium-226 Amount: pnknown activitI_
Event date:
3/11/90 Report date:
3/9/90 Identify any other licensees involved:
Licensee:
N/A License No.:
N/A Jurisdiction:
N/A Reciprocity Licensee:
Y/N Describe clean-up actions taken by you: Decontaminated Pb nic I
What measurements were taken:
Dose rate survev. contamination surver, wines What other action was required of you?: investication of incident l
What action was taken to notify the NRC, other Agreement States or licensees?:
None i
Is the case closed?:
Yes Is record of incident in RAM files?:
Yes What enforcement action was taken?: Impounded sources & taken to RHP
'l 4
4 0
(DRAFT)
INCIDENT REPORTING CHECK LIST (JULY 30, 1987)
.(
1.
Date of Incident: February 10. 1990 Date RCP Notified: Februtrv 10. 1990 2.
Type of Incident or Alleged Incident: unlicer. sed distributien of a
_ general li.quigd dev ist._
3.
Was an investigation conducted by your staff? res Date:
2/15/90 4.
Did the investigation reveal:
(check all appropriate blocks) 1)
Loss of package effectiveness or contamination?
[]
Theft or loss of licensed material?
[]
Overexposure of individual to radiation or radioactive material?
[]
Excessive levels of radiation or concentrations of RAM?
[ ]
Safety failure of GL device?
[]
Equipment failure that could occur on similar devices?
[]
Leaking source?
[]
Misadministration?
[ ]
Transportation incident?
[]
Uranium mill occurrence?
[x]
o fbet If any boxes are checked or if the event is newsworthy, the event must be reviewed against the reporting criteria for Agreement State Materials Events (see All Agreement State letter dated July 22, 1986) and a description of the incident should be summarized as follows for the next NRC review.
(Use extra-sheets if necessary).
SUMMARY
OF EVENT un-lica.aee Licensee:
2-
-t r Thrift S cr#
License No.:
"/A Location of event:
Amtets Thrif t 5 :re. Laurel. '!ar*' land i
Description of event:
TTit ateleisin)t nurchased H-3 lichtine devices f rom h et charity tilstrii;ution center.
A ve_Ls was not 'icensed to distribute thig n31trlnj.
Isotope:
___li-E Amount:
35 Ci Event date:
/10/9C Report date:
C/7/90 Identify any other licensees involved:
.)
Licensee:
n/a License No.:
n/a Jurisdiction:
n/a Reciprocity Licensee: Y/N Describe clean-up actions taken by you:.None recuired What measurements were taken:
None reauired Khat other action was required of you?:
Interview of Amvet Adcinistration-What action was taken to notify the NRC, other Agreement States or licensees?:
Llevd Dolline (NRC) f Is the case closed?:
Yes Is record of incident in RAM files?:
Yes What enforcement action was taken?:
None l
Q e
(DRAFT)
INCIDENT REPORTING CHECK LIST
.LY 30, 1987)
(
1.
Date of Incident: Egbruarv 7, 1990 Date RCP Notified: Februarv 8. 1990 l
2.
Type of Incident or Alleged Incident: alleged whole bodv radiation overexposure of a Nova Pharmaceutical emplovee. Reported: 3.320 mrem on film badge reoort.
3.
Was an investigation conducted by your staff? ves Date:
2/9/90 4.
Did the investigation reveal:
(check all appropriate blocks)
[]
Loss of package effectiveness or contamination?
[]
Theft or loss of licensed material?
[x]
Overexposure of individual to radiation or radioactive material?
[]
Excessive levels of radiation or concentrations of RAM?
[]
Safety failure of GL device?
[]
Equipment failure that could occur on similar devices?
[]
Leaking source?
[]
Mis ~ administration?
[ ]
Transportation incident?
[]
Uranium mill occurrence?
If any boxes are checked or if the event is newsworthy, the event must be reviewed against the reporting criteria for Agreement State Materials Events (see All Agreement State letter dated July 22, 1986) and a description of the incident should be summarized as follows fo'r the next NRC review.
(Use extra sheets if necessary).
SUMMARY
OF EVENT Licensee:
Nova Pharmaceutical Corp.
License No.:
MD-07-149-01 Location of event: 333 Cassell Drive. Baltimore. Maryland 21224 Description of event:
A Nova Pharmaceutical emplovee received a whole bodv 3.320 mrem on the monthly film badge report. Siemens re-e'aluated their assessment and reported no radiation exoosure to the indyvidual.
Isotope:
None Amount:
N/A Evr date:
2/7/90 Report date:
2/23/90 Identify any other licensees involved:
Licensee:
None License No.:
N/A Jurisdiction:
N/A Reciprocity Licensee:
Y/N Describe clean-up actions taken by you:
None What measurements were taken:
None What other action was required of you?: investigation was conducted What action was taken to notify the NRC, other Agreement States or licensees?:
None i
Is the case closed?:
Yes Is record of incident in RAM files?:
Yes What enforcement action was taken?: None
a (DRAFT)
INCIDENT REPORTING CHECK LIST (JULY 30, 1987) f 1.
Date of Incident: April 26. 1989 Date RCP Notified: April 26.1989 2.
Type of Incident or Alleged Incident: a Troxler moisture / density raure was struck by a front end loader 3.
Was an investigation conducted by your staff? ves Date:
5/1/89 4.
Did the investigation reveal:
(check all appropriate blocks)
[]
Loss of package effectiveness or contamination?
[]
Theft or loss of licensed material?
[]
Overexposure of individual to radiation or radioactive material?
[ ]
Excessive levels of radiation or concentrations of RAM?
[ ]
Safety failure of GL device?
[]
Equipment failure that could occur on similar devices?
[]
Leaking source?
[ ]
Misadministration?
[ ]
Transportation incident?
[ ]
Uranium mill occurrence?
[x]
Other If any boxes are checked or if the event is newsworthy, the event must he, reviewed against the reporting criteria for Agreement State Materials Events (see All Agreement State letter dated July 22,-1986) and a description of the incident should be summarized ar follows for the next NRC review.
(Use extra sheets if necessary).
SUMMARY
OF EVENT Licensee:
Oosterbaan Associates License No.: MD-31-176-01 Location of event: Et. 3 and Rt. 50. Bowie. Maryland Description of event:
A Troxler model 3400 moisture / density raure was struck by a front end loader.
The source remained in the shielded cosition.
Isotope:
8 mci. 40 mci Event date:
4/26/89 Report date:
5/23/89 Identify any other licensees involved:
Licensee:
None License No.:
N/A Jurisdiction:
N/A Reciprocity Licensee:
Y/N Describe clean-up actions taken~by you: None What measurements were taken:
leak test, dose rate survey.
What other action was required of you?: investigation of incident, insoection What action was taken to notify the NRC, other Agreement States or licensees?:
None Is the case closed?:
Yes Is record of incident in RAM files?:
Yes What enforcement action was taken?: Six (6) violations were cited as a result of the investigation / inspection
a.
(DRAFT)
INCIDENT REPORTING CHECK LIST (JULY 30, 1987)
C 1.
Date of Incident: April 5. 1989 Date RCP Notified: Aoril 5. 1989 2.
Type of Incident or Alleged Incident: missing radioactive waste at a Georgetown University Laboratory 3.
Was an investigation conducted by your staff? yes Date:
4/5/90 4.
Did the investigation reveal:
(check all appropriate blocks)
[]
Loss of package effectiveness or contamination?
[x]
Theft or loss of licensed material?
[]
Overexposure of individual to radiation or radioactive material?
[]
Excessive levels of radiation or concentrations of RAM?
[]
Safety failure of GL device?
[]
Equipment failure that could occur on similar devices?
[]
Leaking source?
I)
Misadministration?
[]
Transportation incident?
[]
Uranium mill occurrence?
If any boxes are checked or if the event is newsworthy, the event must be reviewed against the reporting criteria for Agreement State Materials Events (see All Agreement State letter dated July 22, 1986) and a description of the incident should be summarized as follows for the next NRC review.
(Use extra sheets if necessary).
SUMMARY
OF EVENT Licensee: - Georretown l'niversity License No.:
MD-31-100-01 Location of event:
5640 Fishers Lane. Rockville. Marvland Description of event:
Radioactive waste was recorted missing from the laboratorv.
1-125 waste was encaosu. lated in aooroximately 100-200 nolvstyrene tubes that nav have been inadvertently disposed of with the recular trash.
Isotope:
1-125 Amount:
.1-1.0 uCi Event date:
4/5/89 Report date:
6/15/89 Identify any other licensees involved:
Licensee:
None License No.:
N/A Jurisdiction:
N/A Reciprocity Licensee: Y/N Describe clean-up actions taken by you:
None What measurements were taken: survevs of lab. dumpster. rad area transfer station What other action was required of you?: investication of incident conducted What action was taken to notify the NRC, other Agreement States or licensees?:
i None k
Is the case closed?:
Yes Is record of incident in RAM files?:
Yes What enforcement action was taken?: None 1
e*
(DRAFT)
INCIDENT REPORTING CHECK LIST (JULY 30, 1987) 1.
Date of Incident: Januarv 31. 1989 Date RCP Notified: Januarv 31. 1989 s
2.
Type of Incident or Alleged Incident: _ bulldozer backed over a Troxler moisture /densite gauce at a field site 3.
Was an investigation conducted by your staff? ves Date:
1/31/89 4.
Did the investigation reveal:
(check all appropriate blocks)
[]
Loss of package effectiveness or contamination?
[]
Theft or loss of licensed material?
[]
Overexposure of individual to radiation or radioactive material?
[]
Excessive levels of radiation or concentrations of RAM?
[]
Safety failure of GL device?
[]
Equipment failure that could occur on similar devices?
[]
Leaking source?
[]
Misadministration?
[]
Tra'nsportation incident?
[]
Uranium mill occurrence?
[x]
Other If any boxes are checked or if the event is newsworthy, the event must be reviewed against the reporting criteria for Agreement State Materials Events (see All Agreement State letter dated July 22, 1986) and a description of the incident should be summarized as follows for the next NRC review.
(Use extra sheets if necessary).
SUMMARY
OF EVEST Licensee:
Fidde C3nsultnnte, Inc.
License No.:
MD-05-037-01 Location of event: Ginger CcVe Life Care Cemeunitv. 3003 Riva Trace Pkuv.
Apnapolis 50 Description of event:
At 1300 hours0.015 days <br />0.361 hours <br />0.00215 weeks <br />4.9465e-4 months <br />, a bulldozer backed over a moisture /densitv cauge. No damace occurred to either of the radioactive uurces. but there was circuitov danace to the cauge.
't Isotope:
Cesium-137 and Americium-241 Amount:
7.7 mci and 40 mci Event date:
1/31/89 Report date:
2/7/89 Identify any other licensees involved:
Licensee:
None License No.:
n/a Jurisdiction:
n/a Reciprocity Licensee:
Y/S Describe clean-up actions taken by you:
None What measurements were taken:
Dose rate measurement with a GM sursev meter and leak testing What other action was required of you?: Informed licensee to file report w/RHP What action was taken to notify the NRC, other Agreement States or licensees?:
Sone Is the case closed?:
Yes Is record of incident in RAM files?:
Yes What enforcement action was taken?:
None, incident will be followed un during next scheduled insoection
,. 3..
..,A QUESTION 3.9 1 C h. a.a b.y A U. ? b uf f~/7fA p
OFFICE OF THE SECRETARY DEPARTMENT OF HEALTH AND MENTAL HYGIENE 1
201 WEST PRESTON STREET e BALTIMUdE, MARYLAND 21201 i
William Donald Schaefer
AdW Witsack, MLN., M.S., $ecretary Governor
]
June 23,1987
-l 1
l i
Carlton C. Kammerer, Director State, Local and Indian Tribe Programs United States Nuclear Regulatory Commission Washington, D.C.
20555
/
Dear Mr. Kammerer:
l Thank you for your letter of May 27, 1987 regarding the Nuclear Regulatory Commission's (NRC) review and evaluation of the Maryland radiation control program.
We are pleased that the NRv recognized the commitment and action taken by the Department to structure a program which protects the public health and safety. Although major strides 'have been made in-program' enhancement, we recognize that the. inspection backlog and the regulations governing low-level waste *:*ed additional attention. These two areas have a high priority.-
Your comments regarding the technical aspects of our program will be responded to under separate cover by Mr. Roland G. Fletcher Director of Radiation Control. In addition,-Mr. Fletcher will insure that the letter of explanation of policies and practices for reviewing Agreement.
State programs as well a:s a copy of your Maryland critique are made available for public review.
On July 1, 1987, the radiation control program will be-transferred
~
from the Department of Health and Mental Hygiene to. a' newly created Department of Environment.- At that time, the~ responsibility.for the program will shift to a yet unnamed Secretary of Environment. The new Department of Environment will benefit from-the close cooperation which has been established between staffs.
TTY for the Deaf:
Baltimore Atee 3&M555
$65 0451 Mo f(0N
. -D.C.MetroAree Area Code 301 225-6500 v
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i Carlton C. Kammerer U.S. Nuclear Regulatory Commission Page Two I am most appreciative of the assistance provided by the NRC, to this agency, during the years of our association.
Sincerely, Adele Wilzack, N., M.S.
Secretary AW:dpw cc:
Mr. William H. Eichbaum Mr. David L. Resh, Jr.
Mr. Roland G. Fletcher l
)
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