ML20058G174
| ML20058G174 | |
| Person / Time | |
|---|---|
| Site: | University of Michigan |
| Issue date: | 12/06/1993 |
| From: | Axelson W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Fleming R MICHIGAN, UNIV. OF, ANN ARBOR, MI |
| References | |
| NUDOCS 9312090118 | |
| Download: ML20058G174 (3) | |
See also: IR 05000002/1993004
Text
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61333
Docket No.50-002
License No. R-28
University of Michigan
ATTN: Dr. Ronald F. Fleming, Director
Michigan Memorial - Phoenix
Project
3038 Phoenix Memorial Laboratory
Ann Arbor, MI 48109-2100
Dear Dr. Fleming:
SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT NO. 50-002/93004(DRSS))
UNIVERSITY OF MICHIGAN
This will acknowledge receipt of your letter dated September 30, 1993, in
response to our letter dated September 1,1993, transmitting a Notice of
Violation associated with the failure to follow your Health Physics procedures
by the use of expired calibration standards.
Your letter contested both examples of a use of expired calibration standards
stating that both standards had remained National Institute of Standards and
Technology (NIST) (formerly referred to as National Bureau of Standards (NBS))
traceable. The first standard was a mixed gamma standard that had an
expiration date on the 500 milliliter bottle. Your discussions with the
vendor indicated that the one year expiration date was an arbitrary date that
the vendor's auditors requested to be put on the standard. Our discussion
with the vendor indicated that the expiration date on the bottle was the date
that the shorter lived isotopes, particularly mercury-203 (Hg-203) should not
be considered useable for calibration.
Based on this new information that
your calibrations after the expiration date were based on the isotopes that
were still considered by the vendor as being NIST traceable, this example is
withdrawn.
The second contested example was for the use of a liquid cobalt-60 source for
calibration of a Capintec Ionization Chamber. You stated that Inspection
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Report No. 50-002/93004 (DRSS) incorrectly stated on page 8 that " Procedure
HP-210, ..., required that the Capintec detector be calibrated against an NBS
.
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traceable standard prior to its use in the GAD calibration". The inspection
,
report should have used the word "with" in place of "against", as was used in
the Notice of Violation.
Procedure HP-210 did not require the Capintec to be
directly calibrated against an NBS traceable standard; however, step 9.2 in
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HP-210 does require the use of a " certified NBS standard" as a part of the
calibration.
Your contention that the source used was NBS-traceable since it.
was calibrated on a Germanium / Lithium (GELI) spectrometer which in turn was
calibrated using a NBS traceable source could not be verified by our
,
inspectors. Although a GELI spectrometer count did exist for the source, the
NBS ' traceable standard used to calibrate the GELI detector could not be
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determined.
This example of the violation.still stands. However, because the
violation had only minor safety significance as verified by the new
calibration source, the severity level has been reduced to a Severity Level V.
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Your purchasing new standards and verifying the adequacy of the old standards
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against the new standards have addressed our immediate concerns.
However,
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while the first example of the violation is withdrawn, the criteria your
facility used to determine the acceptable shelf life of your mixed gamma
standard is questioned.
In your response to the violation, you indicated that
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an evaluation was done to determine the adequacy of the continued use of the
" expired" standard.
Please provide us within 30 days from the date of this
letter a written statement describing the criteria you used to determine the
shelf life of the mixed gamma standard and the evaluation that you did to
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determine the adequacy of the " expired" standard.
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Thank you for your response.
If you have any questions' please call
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Charlie Cox of my staff at (708) 790-5298.
' Sincerely,
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W. L. Axelson, Director
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Dr. William Vernetson, Director
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determined. This-example of the violation still stands. However, because the
violation had only minor safety . significance as verified by the new -
calibration source, the severity level has been reduced to a Severity Level V.
Your purchasing new standards and verifying the adequacy of the old standards.
,
against the new standards have addressed our immediate concerns. However,-
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while the first example of the violation is withdrawn, the criteria your
facility used to determine the acceptable shelf life of your mixed gama
standard is questioned.
In your response to the violation, you indicated that
an evaluation was done to determine the adequacy of the continued use of.the
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" expired" standard.
Please provide us within 30 days from the date.of this
letter a written statement describing the criteria you used to determine the
shelf life of the mixed gama standard and the evaluation that you did to
determine the adequacy of the " expired" standard.
Thank you for your response.
If you have any questions please call Charlie
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Cox of my staff at (708) 790-5298.
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Sincerely,
W. L. Axelson, Director
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