ML20134J629

Insp Rept 99990002/96-04 on 960808.No Violation Noted.Major Areas Inspected:Evaluation of Company Radiation Safety Program for Moisture Density Testing Activities Conducted in Areas of Exclusive Federal Jurisdiction

ML20134J629
Person / Time
Issue date:	08/08/1996
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20134J617	List: ML20134J615 ML20134J629
References
REF-QA-99990002-960904 99990002-96-04, 99990002-96-4, NUDOCS 9611150311
Download: ML20134J629 (5)

Text

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i U. S. NUCLEAR REGULATORY COMMISSION 1 REGION II f

Docket No.: 999-90002 ]

l Report No.: 999-90002/96-04  !

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Organization: Anderson Columbia Construction, Inc.  !

l Location: Bagdad, Florida (Plant No. 5)

Dates: August 8, 1996 Inspector: Wade T. Loo, Health Physicist Approved by: Charles M. Hosey, Chief Materials Licensing / Inspection Branch 1 Division of Nuclear Materials Safety i

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1 Enclosure 9611150311 960904 pop GA999 EPfV*****

99990002 PDR

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EXECUTIVE

SUMMARY

Anderson Columbia Construction, Inc.

NRC Inspection Report 999-90002/96-04  ;

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This special, unannounced inspection was conducted to evaluate the company's

! radiation safety program for moisture density testing activities conducted in i areas of exclusive Federal jurisdiction. Through discussions with cognizant

company representatives, the inspector determined that a State of Florida i licensee transferred a portable moisture density gauge to Anderson Columbia Construction, Inc. for use in an area of exclusive Federal jurisdiction.

e Based on those discussions the inspector determined that Anderson Columbia l Construction, Inc. did not have a license to possess and use radioactive materials contained in portable moisture density gauges. However, the e

inspector determined that the individual who used the portable moisture density gauge was knowledgeable in the practices and procedures for ensuring compliance with state and D0T regulatory requirements.

j REPORT DETAlt.S i

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01. Manaaement Oversicht (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 i license issued by the NRC.

On August 6,1996, the inspector conducted an inspection of Okaloosa Asphalt, Inc., a licensee of the State of Florida regarding moisture l density testing activities at Eglin Air Force Base, Florida (EAFB). j During that inspection, Okaloosa Asphalt, Inc. representatives stated 1 that they had transferred a portable moisture density gauge (PMDG) to Anderson Columbia Construction, Inc. for use at a temporary job site at ,

EABF as documented in NRC Inspection Report No. 150-00009/96-06. At the l

. time of the onsite inspection, Okaloosa Asphalt, Inc. was unable to i locate their records documenting the transfer of the PMDG to Anderson Columbia Construction, Inc.

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On August 8,1996, the inspector located the Anderson Columbia Construction, Inc. representatives who were involved with the transfer of the PMDG from Okaloosa Asphalt, Inc. Through discussions with these representatives, the inspector determined that they received the PMDG on June 17, 1996, for use at a temporary job site located at EAFB, Florida, to conduct moisture density testing activities. Once the job had been completed, Anderson Columbia Construction, Inc. returned the PMDG to Okaloosa Asphalt,. Inc. on June 29, 1996. Through further discussions with Anderson Columbia Construction, Inc. representatives, the inspector determined that the company did not have a license to possess and use radioactive materials contained in PMDGs. Anderson Columbia Construction, Inc. representatives stated that at the time the moisture density testing was required for the EAFB job, they were unable to utilize the services of the independent testing laboratory that they most frequently used. Anderson Columbia Construction, Inc.

representatives stated that they had an employee who: (1) had been trained to use PMDGs by the PMDG manufacturer, (2) possessed radiation dosimetry issued by the company they had contracted with, and (3) had been named on that company's State of Florida radioactive material license. Based on this information, Anderson Columbia Construction, Inc. representatives thought that the employee was " licensed" to use the PMDG.

Through discussions with cognizant Anderson Columbia Construction, Inc. I representatives and from a review of records available at the time of l the onsite inspection, the inspector determined that the Anderson Columbia Construction, Inc. employee who used the PMDG had a training certificate from the PMDG manufacturer Through further discussions, Anderson Columbia Construction, Inc. representatives stated that the company decided to file an application for a radioactive materials license with the State of Florida. Anderson Columbia Construction, Inc. '

filed for a radioactive materials license so that they could conduct the moisture density tests within the company. Company representatives also stated that the company had a subsidiary company that conducted testing

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activities and wanted to expand their testing capabilities to include

. moisture density testing using PMDGs. This would allow the company to

conduct these tests without having to pay an independent testing

laboratory to do the work. The inspector verified with a State of 4

Florida representative that the company had filed an application with the state for a radioactive materials license. In addition, through discussions with construction company representatives and a review of

! records, the inspector determined that the State of Florida did not name i individuals on state radioactive materials licenses. However, the i

applications submitted to the state by licensees named individuals who were requesting authorization to use radioactive materials under the license. Based on discussions and reviews, the inspector determined

, that Anderson Columbia Construction, Inc. did not have a license to

possess and use radioactive materials contained in PMDGs at the time i they used the PMDG at EAFB. Failure of the company to have a license to

possess and use radioactive materials was identified as an apparent f violation of 10 CFR 30.3.

j 02. Radiation Safety (83822. 86740) i 10 CFR 20.1502 requires the monitoring of exposures to radiation to

? demonstrate compliance with occupational dose limits specified in j 10 CFR'20.1201. 10 CFR 19.12 requires that individuals who are likely 4

to receive in excess of 100 mrem in a year in occupational exposure be j trained in specified radiation protection topics. 10 CFR Part 71 l requires that licensed materials be transported in accordance with

specified requirements, including-referenced Department of i Transportation (DOT) regulations.

l Through discussions with cognizant Anderson Columbia Construction, Inc.

i representatives, the inspector reviewed the training for the company l employee who used the PMDG The inspector reviewed the employee's PMDG '

i training certificate for training conducted by the PMDG manufacturer.

i The inspector also reviewed and discussed the operating and emergency j procedures and use of personnel dosimetry with the individual employee.

! In addition, the inspector discussed transportation procedures with the ,

i individual. During these discussions, the individual stated that the appropriate transportation documents had been given to him when he

received the PMDG from Okaloosa Asphalt, Inc. The inspector verified l that the transportation documents maintained by Okaloosa Asphalt, Inc.

, were appropriate to ensure compliance with NRC and DOT regulatory

' requirements as documented in NRC Inspection Report 150-00009/96-06.

Also, the individual stated that the PMDG was locked and secured in his vehicle during transport. The individual also stated that he had used radiation dosimetry from his previous. employer when he used the gauge.

.. From those discussions and reviews the inspector found the individual to

[ be knowledgeable in those procedures to ensure that appropriate and adequate actions would be taken in the event of an emergency at a 4

temporary job site. Through discussions with Anderson Columbia L Construction, Inc. representatives, the inspector determined that when 2

the PMDG was not in use at the EAFB job site, it was stored in the company's portable laboratory at Plant No. 6 located in Wright, Florida.

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03. Miscellaneous Issues (87100)

, Through those discussions with cognizant Anderson Columbia Construction, i t

Inc. representatives and from a review of records available at the time of the onsite inspection, the inspector determined that the company l possessed and stored radioactive materials contained in a PMDG at its l Wright, Florida facility. From those discussions, the inspector i determined that Anderson Columbia Construction, Inc. possessed and stored the gauge without a State of Florida radioactive materials license. The inspection findings associated with the possession and storage of radioactive materials without a State of Florida radioactive materials license will be referred to the State of Florida.

EXIT MEETING

SUMMARY

An exit meeting was held with Anderson Columbia Construction, Inc.

representatives on August 8, 1996. The overall findings from the inspection, including the apparent violation were discussed. No dissenting comments were received from company representatives, and Anderson Columbia Construction, Inc. representatives did not specify any information reviewed during the '

inspection as proprietary in nature.

LIST OF PERSONS CONTACTED  !

Licensee

• T. McRae, President K. Murphy, Materials Engineer K. Sweet, Area Manager

• Via telephone l 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 VIO FAILURE TO OBTAIN A LICENSE TO POSSESS AND USE RADI0 ACTIVE MATERIAL