ML20134C446
| ML20134C446 | |
| Person / Time | |
|---|---|
| Site: | 15000009 |
| Issue date: | 09/06/1996 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20134C426 | List: |
| References | |
| 15000009-96-10, NUDOCS 9609270181 | |
| Download: ML20134C446 (7) | |
See also: IR 015000009/1996010
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U. S. NUCLEAR REGULATORY COMMISSION
REGION II
Docket No.:
150-00009
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Report No.:
150-00009/96-10
Organization:
Edward M. Chadbourne, Inc.
Location:
Pensacola, Florida
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Dates:
August 8-9, 1996
Inspector:
Wade T. Loo, Health Physicist
Approved by:
Charles M. Hosey, Chief
Materials Licensing / Inspection Branch 1
Division of Nuclear Materials Safety
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Enclosure
9609270181 960906
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EXECUTIVE SUMARY
Edward M. Chadbourne, Inc.
NRC Inspection Report 150-00009/96-10
This special, unannounced inspection was conducted to evaluate
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Edward M. Chadbourne, Inc.'s (EMCI's) radiation safety program for moisture
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density testing activities conducted in areas of exclusive Federal
jurisdiction. Through discussions with cognizant EMCI representatives,
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reviews of documents, and direct observations of licensee equipment and
instrumentation, the inspector found EMCIs overall radiation safety program to
be adequate. The inspector also found however, that the company did not have
a specific NRC license nor did the company file for reciprocity in accordance
with 10 CFR 150.20. The company, thus, did not have an NRC license to use
byproduct material in areas of exclusive Federal jurisdiction.
Program areas
discussed in this report are management oversight, organization and scope of
the program, leak test and inventory, training, retraining and instruction to
workers, personnel radiation protection, and transportation.
Manaaement Oversicht
The inspector identified an apparent violation regarding EMCI's failure
to file reciprocity with the NRC prior to using radioactive materials
for conducting moisture density testing at Pensacola Naval Air Station,
Florida, an area of exclusive Federal jurisdiction.
Oraanization and Scope of the Licensee Proaram
EMCI had a State of Florida license to possess and use radioactive
material contained in portable moisture density gauges to measure
properties of construction materials or soils. The use of byproduct
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materials was conducted at temporary job sites throughout the State of
Florida including areas of exclusive Federal jurisdiction.
Leak Test and Inventory
EMCI's portable moisture density gauges had been leak tested by a
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company authorized to conduct such tests on a semiannual basis.
EMCI's
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Radiation Safety Officer conducted semiannual inventories of the gauges.
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Trainina Retrainina, and Instructions to Workers
EMCI personnel were found to have been properly trained in EMCI's
radiation safety program, and radiation workers had received
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instructions commensurate with their involvement in activities using
byproduct material.
Personnel Radiation Protection
EMCI's external radiation monitoring program was found to be adequate
for monitoring personnel and no external radiation exposures exceeding
NRC regulatory limits were identified.
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Postina and Labelina
The portable moisture density gauges were available for inspection,
observed by the inspector in EMCI's storage area, and found to be
properly labeled to identify the radiation hazards present.
In
addition, EMCI's storage area was observed and found to be properly
posted for the radioactive materials present at the facility.
Transoortation
The inspector reviewed EMCI's transportation activities involving
byproduct materials and found them to be in accordance with NRC and DOT
regulatory requirements.
Miscellaneous issues
During the onsite inspection the inspector determined that EMCI's had
previously been inspected by the State of Florida on two occasions with
items of noncompliance being identified.
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REPORT DETAILS
01.
Manaaement Oversiaht (87100)
10 CFR 30.3 requires in relevant part, that no person shall possess or
use byproduct material except as authorized by a specific or general
license issued by the NRC.
10 CFR 150.20(a) provides in part that any person who holds a specific
license from an Agreement State is granted an NRC general license to
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conduct the same activity in non-Agreement States subject to the
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provisions of 10 CFR 150.20(b).
10 CFR 150.20(b)(1) requires,- in part, that any person engaging in
activities in non-Agreement States shall, at least 3 days before
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engaging in each such activity, file 4 copies of NRC Form 241, " Report
of Proposed Activities in Non-Agreement States," with the Regional
Administrator of the appropriate NRC regional office.
On August 5, 1996, the inspector reviewed the conduct of activities
involving the use of byproduct material at Pensacola Naval Air Station
(PNAS), Florida with cognizant Navy representatives.
From discussions
and reviews of records for activities that involved moisture density
testing, the inspector determined that EMCI had conducted asphalt paving
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at PNAS in past years.
However, Naval representatives were not able to
confirm if EMCI utilized portable moisture density gauges (PMDGs).
Also, the inspector was unable to verify EMCI's use of PMDGs due to the
volume of documents available for review.
For those records sampled,
the inspector was not able to determine if EMCI had conducted activities
using PMDGs.
On August 8-9, 1996, the inspector conducted an onsite inspection of
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EMCI to determine if EMCI had conducted activities requiring an NRC
licensee at PNAS, Florida. The inspector discussed those activities
with EMCI representatives and reviewed those EMCI records available at
the time of the onsite inspection.
From those discussions and reviews,
the inspector independently verified that EMCI had used a PMDG for
moisture density testing purposes at PNAS, Florida.
EMCI
representatives stated that the last time the PMDG had been used at PNAS
was on one hot day for approximately one half to one hour, probably
during the summer of 1992 or 1993 at PNAS, Florida. However, the
inspector was not able to determine the exact dates of use for those and
other activities in past years. Activities conducted under EMCI's State
of Florida radioactive materials license did not require them to
maintain a utilization log.
Furthermore, EMCI used the PMDGs for
quality control purposes and was not required to document each time the
PMDGs were used at PNAS. During discussions with the inspector < EMCI
representatives could not recall the exact dates but only an estimate of
when the PMOGs had been used at PNAS.
EMCI representatives stated that
they were under the assumption that they had a State of Florida
radioactive materials license which allowed them to conduct moisture
density activities at temporary job sites in the State of Florida
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including PNAS.
EMCI representatives also stated that they were not
aware of the requirement for filing reciprocity with the NRC. Although
the inspector could not independently verify the use of EMCI's PMDGs at
PNAS, the inspector concluded based on those discussions with EMCI
representatives that EMCI had not filed for reciprocity to conduct
licensed activities at PNAS, areas of exclusive Federal jurisdiction.
Failure of the licensee to file for reciprocity for licensed activities
conducted in areas of exclusive Federal jurisdiction was identified as
an apparent violation of 10 CFR 30.3.
02.
Oroanization and Scone of the Licensee Proaram (87100)
Through discussions with cognizant licensee representatives, the
inspector determined that EMCI was licensed by the State of Florida to
possess and use radioactive materials contained in PMDGs.
EMCI was
authorized to possess and use the PMDGs for measuring properties of
construction materials or soils. Through those discussions and from a
review of records, the inspector determined that EMCI possessed and used
three PMDGs that contained millicurie quantities of cesium-137 and
americium-241. Also, the inspector determined that four individuals
were trained to use the PMDGs; they included the Radiation Safety
Officer (RS0) and three laboratory technicians.
EMCI representatives
stated that company activities primarily involved asphalt paving of
roads.
EMCI used the PMDGs at temporary job sites located throughout
the State of Florida including areas of Federal exclusive jurisdiction.
EMCI representatives stated that the PHDGs were used for quality control
purposes at these temporary job sites. When conducting asphalt paving,
EMCI was required to use an independent testing laboratory to verify the
density of the materials tested.
03.
Leak Tests and Inventories (83822)
The inspector reviewed leak test and inventory records from June'1990 to
March 1996 and discussed those records with EMCI representatives.
From
those reviews and discussions, the inspector determined that EMCI
conducted leak tests and inventories of the PMDGs on a semiannual
frequency.
EMCI utilized leak test kits supplied by a leak testing
consultant authorized to conduct such tests.
Upon completion of the
leak test, EMCI sent the leak test samples to the consultant for
analysis.
From a review of those leak tests results, the inspector did
not observe any sample results greater than 0.005 microcuries.
04.
Trainina Retrainina, and Instructions to Workers (83822)
Through discussions with cognizant EMCI representatives and a review of
training records, the inspector determined that EMCI personnel
authorized to use the PMDGs had received appropriate radiation safety
training from the PMDG manufacturer. The inspector noted that EMCI
maintained each PMDG user's training certificates in the RS0's office.
The inspector reviewed and discussed EMCI's operating and emergency
procedures with those EMCI representatives available at the time of the
onsite inspection. During those discussions and reviews, the inspector
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found the individuals to be knowledgeable in those procedures to ensure
that appropriate and adequate actions be taken in the event of an
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emergency at a temporary job site.
05.
Personnel Radiation Protection (83822)
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10 CFR 20.1502 requires monitoring of occupational exposures to
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radiation to demonstrate compliance with radiation dose limits specified
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in 10 CFR 20.1201, 20.1207, and 20.1208.
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The inspector reviewed external radiation dosimetry reports from January
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1990 to June 1996 and discussed those reports with cognizant EMCI
representatives. Through those discussions and reviews, the inspector
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determined that EMCI utilized external radiation dosimetry supplied by a
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National Voluntary Laboratory Accreditation Program approved vendor for
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monitoring personnel.
EMCI exchanged the dosimetry on a quarterly
frequency.
From a review of those dosimetry reports, the inspector
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observed annual total effective dose equivalent radiation exposures
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ranging from 0 to 159 millirem.
Based on those discussions and reviews,
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the inspector determined that EMCI had no external radiation exposures
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exceeding NRC regulatory limits.
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06.
Postina and Labelina (83822)
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10 CFR 20.1904 and 10 CFR 71.5 require that containers of licensed
material contain certain information.
10 CFR 20.1401 requires that
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areas containing licensed materials be posted with warning signs.
10 CFR 20.1302 requires that radiation dose rates in unrestricted areas
be limited.
The inspector observed the PMDGs that EMCI possessed and independently
verified that the PMDGs. were properly labeled to ensure compliance with
NRC and DOT regulatory requirements.
In addition, the inspector
conducted independent radiation surveys of the PMDGs and storage area
with measurements ranging from 0.0 to 0.3 millirem / hour.
Based on those
independent measurements the inspector observed that the licensee
adequately posted and labeled the storage area and PMDGs in accordance
with NRC and DOT regulatory requirements.
07.
Transportation (86740)
10 CFR Part 71 requires that licensed materials be transported in
accordance with specified requirements, including referenced Department
of Transportation (DOT) regulations.
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Through discussions with cognizant EMCI representatives and a review of
transportation records,
e inspector determined that EMCI transported
the PMDGs in the bed of
pany pickup trucks.
EMCI representatives
informed the inspector that when transporting the gauges, the
individuals would chain and lock the gauge transportation boxes to the
beds of the pickup trucks. The inspector reviewed EMCI's transportation
records maintained for each gauge and discussed those records with EMCI
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representatives.
EMCI representatives informed the inspector that the
transportation records were kept in the front of EMCI's vehicles within
arms reach of the driver. From those discussions and reviews, the
inspector determined that EMCI maintained appropriate documentation to
ensure compliance to NRC and DOT regulatory requirements.
08.
Miscellaneous Issues (87100)
Through discussions with EMCI representatives and from a review of
records, the inspector determined that EMCI had previously been
inspected by the State of Florida on November 19, 1992 and November 21,
1995. During the November 19, 1992 inspection, EMCI had been cited for
two items of noncompliance:
1) Unavailability of personnel records; and
2) Inventory records did not include all of the required information.
During the November 21, 1995 inspection, EMCI had been cited for three
items of noncompliance:
1) Leak test records did not include all of the
required information; 2) Licensee did not advise radiation workers of
their annual exposure; and 3) Inventory records were not available at
the time of the onsite inspection. At the time of the onsite
inspection, the inspector did not identify any items similar to the
findings of the state.
EXIT MEETING SUMMARY
An exit meeting was held with EMCI representatives on August 9, 1996.
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overall findings from the inspection, including the apparent violation were
discussed. No dissenting comments were received from EMCI, and EMCI did not
specify any information reviewed during the inspection as proprietary in nature.
LIST OF PERSONS CONTACTED
Licensee
R. Kelly, Laboratory Technician
T. Perry, Vice President
J. Strother, Laboratory Foreman, Radiation Safety Officer
INSPECTION PROCEDURES USED
IP 87100:
Licensed Materials Program
IP 83822:
Radiation Protection
IP 86740:
Inspection of Transportation Activities
ITEMS OPENED, CLOSED, AND DISCUSSED
OPENED
96-001
FAILURE TO OBTAIN A LICENSE TO POSSESS AND USE RADI0 ACTIVE
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MATERIAL
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