ML20135C874
| ML20135C874 | |
| Person / Time | |
|---|---|
| Site: | 15000009 |
| Issue date: | 11/26/1996 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20135C870 | List: |
| References | |
| 15000009-96-18, NUDOCS 9612090128 | |
| Download: ML20135C874 (4) | |
See also: IR 015000009/1996018
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U. S. NUCLEAR REGULATORY COMMISSION
REGION II
Docket No.: 150 00009
Florida License No.: 2579-1
Report No.: 150 00009/96 18
Organization: Gulf Asphalt Corporation
Location: Panama City. Florida
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Dates: November 4. 1996
' Inspector: Wade T. Loo, Health Physicist l
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Approved by: Charles M. Hosey, Chief
Materials Licensing / Inspection Branch 1 l
Division of Nuclear Materials Safety
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Enclosure
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9612090128 961126
PCWt STPRC ESkDFL.
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EXECUTIVE SUMMARY
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Gulf Asphalt Corporation
, NRC Inspection Report 150-00009/96 18
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This special, unannounced inspection was conducted to evaluate Gulf Asphalt
Corporation's (GAC's) radiation safety program for moisture density testing
activities conducted in areas of exclusive Federal jurisdiction. Through
discussions with cognizant GAC representatives and reviews of documents, the
- inspector found that GAC 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 included in this report are
management oversight and organization and scope of the program.
Manaaement Oversicht
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. The inspector identified an ap)arent violation regarding GAC's failure
to file for reciprocity with t1e NRC prior to using radioactive
materials for conducting moisture density testing at Tyndall Air Force
Base, Florida; an area of exclusive Federal jurisdiction.
- Oroanization and Scope of the Licensee Proaram
- e GAC had a State of Florida license to possess and use radioactive
materials contained in portable moisture density gauges used to measure
properties of construction materials or soils. The use of byproduct
materials was conducted at temprary job sites throughout the State of
Florida including areas of exclusive Federal jurisdiction.
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REPORT DETAILS
01. Manacement 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
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
conduct the same activity in non-Agreement States subject to the l
provisions of 10 CFR 150.20(b). I
10 CFR 150.20(b)(1) requires, in part, that any person engaging in I
activities in non Agreement States shall, at least 3 days before
engaging in each such activity, filt 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 July 15, 1996, the inspector reviewed the conduct of activities
involving the use of byproduct material at Tyndall Air Force Base
(TAFB), Florida, with cognizant Air Force representatives. From
discussions with Air Force representatives regarding activities that
involved moisture density testing, the inspector determined that Gulf
Asphalt Corporation (GAC) had conducted moisture density testing at TAFB
in past years. However, Air Force representatives were not able to
confirm the exact dates GAC used the aortable moisture density gauges
(PMDGs). Also, the inspector was unaale to verify GAC'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 GAC had conducted
activities using PMDGs.
On November 4, 1996, the ins)ector conducted an onsite inspection of GAC
to determine if the company lad conducted activities requiring an NRC
license at TAFB, Florida. The ins)ector discussed those activities with
GAC representatives and reviewed t1ose company records available at the
time of the onsite inspection. From those discussions and reviews, the
inspector independently verified that GAC had used a PMDG for moisture
density testing purposes at TAF3 Florida. GAC representatives stated
that the PMDG had been used an average of nine times for the last year
and a half at TAFB, Florida. However, the inspector did not determine
the exact dates due to the quantity of GAC records. Activities
conducted under GAC's State of Florida radioactive materials license did
not require them to maintain a utilization log. During discussions with
the inspector, GAC representatives could not recall the exact dates of
use for those activities conducted within the aast one and a half years.
GAC representatives could only estimate when t1e PMDG was used at TAFB.
GAC representatives stated that they were under the assumption that they
had a State of Florida license which allowed them to conduct moisture
density activities at temporary job sites in the State of Florida
including TAFB. GAC representatives also stated that they were not
aware of the requirement for filing for reciprocity with the NRC.
Although the inspector could not independently verify the exact dates of
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use of GAC's PMDG at TAFB. the ins)ector concluded based discussions
'.. with GAC representatives that.GAC 1ad not filed for reciprocity to
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conduct licensed activities at TAFB, Florida, areas of exclusive Federal
jurisdiction. . Failure of GAC to file for reciprocity for licensed
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activities conducted in areas of exclusive Federal jurisdiction was
} identified as an apparent violation of 10 CFR 30.3.
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02. Oraanization and Scooe of the Licensee Proaram (87100)
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Through discussions with cognizant-GAC representatives, the inspector
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' determined that GAC was licensed by the State of Florida to possess and
use radioactive materials contained in PMDGs for measuring properties of
- construction materials or soils. Through those discussions and from a
i review of records, the inspector determined that GAC possessed and used
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only one PMDG that contained millicurie quantities of cesium 137 and
americium 241. Also, the inspector determined that seven individuals
- were trained to use the PMDGs under the license. GAC representatives
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stated that company activities primarily involved as) halt )aving. GAC
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used the PMDGs at temporary job sites located throug1out t1e State of
Florida including areas of exclusive Federal jurisdiction.
EXIT MEETING SUMMARY
l An exit meeting was held with GAC representatives on November 4,1996. The
j overall findings from the inspection, including the apparent violation were
i discussed. No dissenting comments were received from GAC representatives, and
j GAC did not specify any information reviewed during the inspection as
1 proprietary in nature.
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j LIST OF PERSONS CONTACTED
! Licensee
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- R. Dodd, President
i R. Polan, Radiation Safety Officer, Purchasing Manager
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j INSPECTION PROCEDURE USED
j IP 87100: Licensed Materials Program
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} ITEMS OPENED, CLOSED, AND DISCUSSED
- OPENED
) 96 001 VIO FAILURE TO FILE RECIPROCITY WITH NRC RII 0FFICE
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