ML20133B206

Insp Rept 99990002/96-01 on 961002.No Violations or Deviations/Noncompliance Noted.Major Areas Inspected:To Evaluate Circumstances Surrounding Loss of Generally Licensed Device

ML20133B206
Person / Time
Issue date:	10/30/1996
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20133B194	List: ML20133B190 ML20133B206
References
REF-QA-99990002-961030 99990002-96-02, 99990002-96-2, NUDOCS 9701030033
Download: ML20133B206 (6)

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-U. S. NUCLEAR REGULATORY COMMISSION REGION II i

t Docket No.: 999-00002 License No.: Genercl License (10 CFR 31.5)  ;

> I Report No.:- 999-90002/96-02 '

Licensee: ITT Industries l

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Location: 7635 Plantation Road i j

Roanoke, Virginia 1

Date: October 2, 1996 a

l l Inspectors: John M. Pelchat. Health Physicist  !

i .j j Approved by: Charles M. Hosey, Chief Materials Licensing / Inspection Branch 1

Division of Nuclear Materials Safety 1

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9701030033 961030 RE02 GA999 EMV***** '

99990002. PDR

I EXECUTIVE

SUMMARY

l ITT Industries NRC Inspection Report No. 999-90002/96-01 .l l

1 This reactive, announced inspection was conducted to evaluate the i

circumstances surrounding the loss of a generally licensed device. This  !

!  : included discussions with cognizant licensee representatives and reviews of -

documents associated with the general licensee's efforts to identify, locate and dispose of several generally licensed devices.

i The inspector found the general licensee had implemented an aggressive effort

! to locate and account for all the devices in its possession upon discovery of l the missing devices. The general licensee's Environmental Health and Safety.

l purchasing, and engineering staff was knowledgeable and conscientious. The general licensee took adequate corrective actions to prevent future losses of licensed radioactive' materials. One non-cited violation regarding the loss of '

licensed radioactive materials was identified.

j LIST OF PERSONS CONTACTED Licensee ,

R. Kryczkowski. Manager Environmental Health and Safety (EHS)

( J. Wallace, Environmental Specialist. EHS ,

l P. Creasy, Purchasing Department i

• Attended October 2, 1996.. Exit Meeting i

In addition, various production engineers and mechanics were interviewed  ;

during a facility tour. I l

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REPORT DETAILS

01. Scope of Program ITT Industries (ITT) developed and manufactured night vision equipment.

The Environmental Health and Safety (EHS) department manager was responsible for the management of all hazardous materials in the facility. Interview of the EHS manager revealed that generally licensed static eliminators had been used to ensure the cleanliness of gases used in the manufacturing process. The EHS manger s hted that the static elimination devices were no longer in use at the time of the inspection.

! 02. Review of Circumstances of Loss of Generally Licensed Materials (87100)

Interview by the inspector of the EHS manager and review of records revealed that 34 static elimination devices were leased from NRD Inc.

by an_ITT staff engineer between March 1991 and October 1993. The loss of the source was discovered after the responsible engineer was trans- i ferred to a new department. The individual who assumed the previously  ;

I responsible engineer's duties reportedly became aware of the devices in '

l April 1995. The new engineer's review of records indicated that ITT had ]

returned 16 of the devices to NRD and still had 18 devices on hand. The i new engineer then began an effort to account for all of the devices. j finding all but three. I ITT has an ongoing " source reduction" program to reduce the amount of all hazardous or otherwise difficult-to dispose of materials in the j facility. During a cuarterly source reduction meeting in August 1995. l the ens :neer notifiec the EHS department manager of the missing static j elimination devices.

The EHS department manager stated that engineer previously responsible for the static elimination devices indicated during an interview that he l had discontinued tracking them. The EHS department manager initiated an  !

immediate search of the facility that located two more of the devices.  !

The remaining unaccounted device was a NRD Model P-2021 "Nuclecel" nuclear static eliminator. The device consisted of a foil source

contained in an o)en-ended stainless steel cylinder measuring 2 5/8  ;

inches by 1/2 incl. The device was manufactured on April 19, 1993. The device had an original activity of 10 millicuries of polonium 210 (half-life - 138 days). As of the date of the inspection, the activity had decayed to 18 microcuries. 1 Several additional searches were carried out of the entire plant and l several off-site storage facilities. including warehouses and trailers, i to locate the remaining missing device. In addition. " wanted" posters

! illustrating and describing the missing device were posted through out the facility.

l' Work areas and tool boxes of mechanics who maintained the systems that used the static eliminators were searched. The inspector interviewed a l

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2 l mechanic who verified that several searches had been made and that.the  !

posters describing the missing devices had been posted. j The inspector reviewed documentation.of the search. The documents included examples of the " wanted" posters and a listed of the areas  !

searched. The inspector also toured the areas in which the devices had i been used to verify the results of the search.

l ITT notif:'d the NRC Region II office of the missing device on September i 6, 1995. ITT u) dated the NRC by telephone of the results of the ongoing j search on Decem)er 21, 1995, and on January 2, 1996, j ITT declared the device lost in February 1996. At that same time, the other seventeen devices were collected and placed into-locked storage and arrangements for shipping the devices back to NRD were begun.

The remaining 17 devices were packaged with NRD's assistance and were shipped to NRD on March 25, 1996. The total remaining activity in the

'17 devices was less than 1.2 millicuries. The inspector reviewed the documentation related to the shipment and determined that the shipment complied with NRC and Department of Transportation Requirements.

ITT submitted a written report describing the circumstances of the loss and corrective actions to the NRC on April 22, 1996.

Before the loss, purchasing department staff had been trained to consult with the EHS de)artment if a requisition for a hazardous commodity was received. The EHS department manager tolf the inspector that purchasing i department. personnel did not recognize the potentially hazardous nature of a " anti-static air gun". Procedures were also in ) lace to prevent the purchase of large cost devices containing either lazardous components or unapproved chemicals. However, this requirement did not apply to relatively " low cost" items such as the generally licensed devices. ,

Interview of the EHS department manager indicated that the engineer who had initially leased the devices was not employed by ITT at the time of the inspection. The engineer had reportedly asked the EHS department manager a few years ago if alpha radiation was dangerous without any further elaboration. The EHS manager resaonded that alpha radiation was ,

generally only an internal hazard. Tne EiS manager stated that the )

engineer later cited this conversation as justification and permission to possess the devices when confronted by the EHS manager and ITT management regarding the unauthorized possession of a hazardous material at the facility. The engineer reportedly stated that he had stop)ed maintaining accountability for the generally licensed devices. T1e EHS manager stated that this individual had violated EHS and other ITT procedures on several occasions. The EHS manager also stated that these procedure violations, including the unauthorized acquisition of the devices, were cited to the employee when the employee was laid off.

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-03. General Licensee Corrective Actions Corrective actions put into place by ITT included instruction to the purchasing staff to not approve any static elimination device purchase -

without consultation with the EHS department. The inspector interviewed

.a member of the purchasing staff and verified that the individual was familiar with vari s)ecifically knew.ous hazardous Jurchase commodity purchase of any anti-static requirements device required andthat the EiS department approval. T1e EHS manager stated that all engineering and management staff were trained regarding ITT's. procedures for the acquisition of radioactive material. These procedures were also reviewed during mandatory annual supervisor training.

An additional corrective action is implementation of a procedure that requires all incoming materials and equipment to have an EHS department-assigned part number. Materials and equipment not having an EHS assigned part number will not be accepted for delivery. The EHS part number assignment allows EHS staff to assess the potential hazardous characteristics of materials and equipment received at the ITT facility.

The EHS manager stated that the staff had demonstrated increased ,

sensitivity to radioactive material issues. The EHS manager cited a' i recent example where the Department of Defense (D00) requested ITT I modify night vision devices with a tritium-illuminated compass. ITT l engineers consulted with the EHS department and determined that a exempt distribution license would be required. As a result. ITT chose to decline the D00's request.

04. Regulatory Issues 10 CFR 31.5(c)(1) requires pursuant to 10 CFR 31.5(a)comply persons possessing with devices all instructions andgenerally

)recautions licensed i

)rovided by the label on the device. The label affixed to tie NRD model  !

)-2021 static elimination device prohibited abandonment or improper J transfer of the device. - The inspector concluded that the cause of the j source's loss was the responsible engineer's failure to maintain i adequate accountability for the leased static elimination devices '

possessed by ITT. ITT identified the loss of the generally licensed device and promptly reported the loss to the NRC. The licensee implemented comprehensive corrective actions that are likely to prevent l

future unapproved acquisition of generally licensed materials. This l licensee identified and corrected violation is being treated as a Non-l Cited Violation, consistent with Section VII.B.1 of the NRC Enforcement i Manual.

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4 EXIT MEETING

SUMMARY

! The inspector presented the inspection results to licensee representatives at  !

the conclusion of the inspection on October 2, 1996. The inspector discussed the non-cited violation regarding the loss of generally licensed radioactive materials with the licensee repreoentative present. Licensee representatives l did not identify any documents or processes as proprietary in nature, and no l

. dissenting comments were received from the licensee. i INSPECTION PROCEDURE 5 USED I IP 87100: Licensed Materials Program i l t  !

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