ML20135D125
| ML20135D125 | |
| Person / Time | |
|---|---|
| Site: | 07000968 |
| Issue date: | 01/31/1997 |
| From: | Seigley L GANNON UNIV., ERIE, PA |
| To: | Kinneman J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20135D120 | List: |
| References | |
| NUDOCS 9703050071 | |
| Download: ML20135D125 (6) | |
Text
i GAMON
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U N I V E R S t T Y 109 University Square + Erie, Pennsylvania 16541-0001 814/871-7618 a
January 31, 1997 John D.
Kinneman, Chief Nuclear Materials Safety Branch 2 Division of Nuclear Materials Safety
Dear Mr. Kinneman:
Attached you will find the Gannon University response to the notice of violation which followed an inspection of the Zurn Science Building at Gannon University.
As requested, the response documents specific actions taken at this time as well as planned actions to prevent recurrence.
Gannon University would like to inform you that as of January 29, 1997, the PuBe source is now in possession of Bionomics, Inc. and is en route to Los Alamos National Laboratory.
If there is anything further that we can do to satisfy requirements of the license, feel free to contact us.
Sincerely, I
AL.
!/? PhD Loretta Seigley, Ph.D.
Interim Dean cc:
Dr. Thomas Ostrowski Dr. Paul Griesacker Mr. William Martin RETURN ORIGINALTO REGION I 9703050071 970224 FEB I 01997 PDR ADOCK 07000968 C
PDR COLLEGE OF S C I E N C E S, E N G I N E E R I N G, AND HEALTH SCIENCES 9'bhoaW4
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William R. Martin Mgr Emironmental Health & Safety Gannon University i
University Square, Box G Erie, PA 16541-0001 i
January 15,1997 4
i i
i Dr. Loretta Seigley i
. Dean, College of Science, Engineering & Health Science l.
Gannon University l
University Square p
Zurn Science Hall j
Erie, PA 16541
Dear Dr. Seigley:
This letter is in response to our safety inspection at our facility on Deu:mber 10,19% at Zurn Science l
Hall.
BACKGROUND f
The background of activities at Gannon University pertaining to this source are as follows:
l The University has not been using the source; The source has been contained in an isolated vault; The j-vault is secured with the door locks and only two (2) keys are in existence; Further security is achieved with a external padlock, also with only two keys in existence. The radiation Safety Officer (RSO) has been concentrating on the disposal process. The lack of use of the source, the knowledge of the high level of security, and the expectation ofimminent disposal have lead to an oversight of some of the conditions of
- license,
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Oversight occurred because only one person assumed the responsibility for implementing the conditions of the license. Disposal through LosAlamos is imminent. When this disposal takes place the requirements for fulfilling the conditions of the license will lie with another institution, and Gannon University will no longer be responsible.
In the unlikely event that the planned disposal does not take place the following actions have been taken:
1.) Multiple persons are responsible for overseeing recordkeeping and requirements.
2.) A schedule of documented inspections are posted and will be recorded on a semi-annual basis.
3.) A schedule of documented calibrations of survey meter will be done on a quarterly basis.
RESPONSE
In the nodce of violation document addressed to Gannon University on January 7,1997, the NRC has found our facility in violation in two conditions. The following is Gannon University's submission of written statement and explanation of said violations.
' A.
Condition 14 of License No. 070-00%8 requires that a physical inventory be conducted every six month: to acccunt for all sources and devices received and possessed under the license and that records of inventories be maintained for five years from the date of each inventory.
fiETUrTJ ORIGIN /,L 70 REGION I
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d Contrary to the above, as of December 10,1996, physical inventories had not been conducted for over twelve months.
Thisis a Severity LevelIV violation l
Gammon Uniseraity's reason for violation response:
i j
Under Condition 14 of License No. 070-00%8, actions taken by Gannon University's (RSO) as follows:
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e A undocumented visual inspection of the secured vault containing the source was conducted on a daily basis by the staff of the metalliding institute occupying the i
laboratory, containing the vault, in which the source was secured. They were aware of the content of the vault and were aware that they should report any disturbance of the vault or vadt entrance.
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The RSO hesitated to disturb the vault by opening it in order to tonduct a physical e
inventory, considering only two keys are in existence to the vault. One key is in possession of the Radiation Safety Officer and the other key is with the Security Director.
in 1990 Gannon University reserved a storage / transportation container from LosAlamos e
Laboratories in order to recycle the source. We were informed that the container was shipped in January 1997. The date for pick up and transportation of the Pu Be source is on February 10,1997, at which time Gannon University will no longer possess the source. A purchase order has been issued to Bionomics Inc. for the expenses im ohrd with the removal and transportation of the source to LosAlamos includica 'he required surveys and wipe tests.
A quality assurance program approval for the shipment was issued on Dec. 5,1996.
(Docket No. 71-0868). Relinquishment of onership was sent to LosAlamos National Laboratory on Nov. 25,19%
Gannon University's corrective steps taken and nmits achieved:
Gannon University's Radiation Safety Officer has set up a biannual checklist of sisual e
physical inventories conducted, dates of im entory will be recorded, the inventory inspector (RSO) will sign in and out on inventory dates. All sources and desices received and paccaccai under the license will be inventoried and maintained for five years from the date of each inventory. This procedure is now being conducted until the source is removed on February 10,1997. Responsibility for these procedures lies with the Emironmental Health & Safety Officer Dean of Science & Engineering, Chairman of Math and Physics and the Radiation Safety Officer.
B.
Condition 17 of License No. 070-00968 requires that licensed material be pacceccai and used in accordance with the statements, representations, and procedures contained in an application dated July 2,1988. Item 6 on page two of the application requires that radiation sun ey instrumentation, calibrated quarterly, be available for use.
Contrary to the above, as of December 10,19%, radiation survey instrumentation, calibrated quarterly, had not been available for over twelve months.
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This is a Severity LevelIV siolation 4
4 Gannon Univenity's reason for violation response:
Under Condition 17 of License No. 070-00968, it was interpreted by Gannon University's Radiation Sefety Officer as follows:
Prior to the last twelve months Gannon University had ceased using the source for a
2 educational purposes. At that time the source was placed in storage. Security of the j
storage vault was ver; high. Im'entories of the contents of the vault were always proceeded by calibration of the suncy meter.
4 Calibration of the survey me*er was always done before entering the area where the source is stored. This practice has always been conducted since Gannon University gained ownership of the source. This procedure was always thought as a best practice while the source is in Gannon University's possession.
s Since Gannon University was not using the source an:1 had a confirmed removal date of e
February 10,1997, and was actively seeking to dispose of the source, and since knowledge of high level of security and anticipation of disposal led to the physical inventory being overlooked, calibration of the metering device was overlooked due to personnel not entering the storage vault.
Gannon University's corrective steps taken and results achieved:
The RSO has leased a survey meter in accordance with our license until our source is shipped. The meter that has been leased is a portable ratemeter/ scaler Model PRS-1 " Rascal" (serial #202). This meter is manufactured by Eberline Instrument Corporation in SanteFe, New Mexico.
Also:
1.) Multiple persons are responsible for overseeing recordkeeping and requirements..
2.) A schedule of documented inspections are posted and will be recorded on a semi-annual basis.
3.) A schedule of documented calibrations of sun cy meter will be done on a quarterly basis.
This letter of response contains no personal privacy, proprietary or safeguards information so that it can be placed in the Public Docum:nt Ro.3n in its entirety.
If you have any further questions regarding Gannon Universities response to the above stated violations, please do not hesitate to contact me.
Sincerely, k
William R. Martin Emironmental Health and Safety Oflicer