ML20149E628
| ML20149E628 | |
| Person / Time | |
|---|---|
| Site: | 03001179 |
| Issue date: | 12/31/1987 |
| From: | Jonathan Montgomery NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Proenza L ALASKA, UNIV. OF, FAIRBANKS, AK |
| References | |
| NUDOCS 8801130416 | |
| Download: ML20149E628 (1) | |
See also: IR 05000024/2030007
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DEC 3 I 1997
. Docket No. 030-01179
University of Alaska
310 Signers Hall
Fairbanks, Alaska 99701
Attention:
Dr. Luis Proenza
Vice Chancellor for Research
Gentlemen:
Thank you for your letter of November 30, 1987, in response to our Notice of
Violation dated October 27, 1987, informing us of the steps you have taken to
correct the items which we brought to your attention.
Your corrective actions
will be verified dering a future inspection.
Your cooperation with us is appreciated.
Sincerely,
09:1 dyei 19
,
Jan$es L. Yo*n'tgomery, Chief
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Nuclear Materials Safety and
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Safeguards Branch
bec w/ copy of letter dated 12/7/87:
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State of Alaska
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UN IV E R SIT Y O F A L A S K A . F A l@]MM A 10: 12
Fairbanks, Alaska 99775
. November 30,-1987
U. S. Nuclear R3gulatory Canmission
' ATTN:
Document Control Desk
,
Washington, D. C.
20555
Gentlemen:
I am writing in response to your report on the NRC Inspection of activltles
conducted by Mr. David D. Skov on August 11-12, 1987, and authorized by NRC
License No. 50-02430-07.
I am enclosing a report from Dr. Dan Holleman, Radiation Safety Officer,
addressing each of the violations cited in your report and Informing you of
the corrective actions taken to eliminate any inadequacles that may have
existed, and to ensure compilance with NRC regulations and license
conditions.
'
Please do not hesitate to contact me at (907) 474-7314 should you require any
further clarification in this matter, or if I can be of any further
assistance.
Sinc
,
W
Luis M. Proenza
Ylce Chancellor for Research and
Dean of the Graduate School
306 Signers' Hal1 - UAF
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Fairbanks, Alaska 99775-1720
LMP/dpg
cc:
Region V
Walnut Creek, CA
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DATE:
Nov. 25,1987
TO:
U.S.
Nuclear Regulatory Commission
ATTN: Document Control Desk
Washington D.C.
20555
,
FROM:
D.
Holleman, RSO, NRC 50-02430-07
,
SUBJECT:
Reply to a Notice of Violation
The purpose of this memorandum is to comply with the regulation
that requires a written statemeat f o llowing an issuance of a
' Notice of Violation' by NRC.
This ' Notice of Violation' was
issued to the University of Alaska (NRC 50-02430-07) by corres-
pondence
dated Oct. 27,1987 signed by James
L.
Montgomery,
Chief, Nuclear Materials Safety and Safeguards Branch, Region V,
NRC.
The letter accompanying the ' Notice of Violation' expressed a
concern related to the radiation safety program and its in-
effectiveness in preventing violations.
The University Radiation
Safety Committee (RSC) discussed this concern and agrees with the
NRC inspection team that a stronger safety program is essential.
A more effective safety program means more frequent internal
inspections of the University's authorized users and more in-
formational/ training sessions for all radioisotope users.
The
RSC has instituted or is in the process of instituting several
measures to strengthen the radiation saf ety program.
The commit tee
recognizes the necessity of a more active involvement in the
safety program by the University Administration.
To promote a
more active involvement by the admicierration, the RSC has
designated that the committee represent..ive from the Office of
the
Vice ebencellor serve es the chei: person of the committee.
Direct fiscal support for the radiation saf ety program is essential
if internal inspection / informational / training efforts are to
succeed therefore the comnittee has prepared a proposed budget
and will submit the budget to the University Administration.
The person that ultimately determines compliance with the provis-
ions
of the license is the actual users of radioactive materials.
To address this concern
the RSC has directed the RSO to hold an
informational / training / inspection session with e4cn authorized
user to assure that the safety provisions of the license are
understood and compliance is being met.
Speci 1 eftorts will be
made to assure that posting and records are
complete and in proper
order, and available for inspection at all times.
The specific violations as enumerated in the NRC letter of
Oct. 27,1987 are discussed below.
As requested a statement is
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made concerning each violation and includes (1) reason for the
violation, (2) corrective steps and results achieved, (3) correc-
tive steps to avoid further violations and (4) the time when full
compliance will be achieved.
Violation A - licensed material'in an unrestricted area.
(1)
The building had been recently altered to allow handi-
capped persons to more easily access the building.
In accomplish-
ing this building alteration, a corridor that was previously
restricted became unrestricted.
The areas in question are two
incubator rooms which are accessible from the corridor.
(2)
Locks have been placed on the two incubator rooms which
restricts access to these sites where radioactive materials are
used.
(3)
Physical plant personnel have been alerted as to the
problems that can occurs when access is altered in areas wh2rc
radioactive materials are used or stored.
(4)
Full compliance has been achieved.
Violation B
quantity of radioactive material in the inventory
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exceeds the possession limit.
(1)
In the license application (letter dated May 1,1985
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page 23) the University's nicke1-63 EC detectors weve listed
individually and add up to a total of 82 millicuries.
However
when the total was entered on pagt; 2 of the same letter, a typing
error was made and 72 millicuries was inadvertently entered.
(2)
An amendment to the license requesting a higher pos-
session limit of nickel-63 is being drafted and will correct the
ambiguity.
(3) Not applicable.
(4) The amendment regiest will be submitted within 30 days.
Violation C 1 - food / drink in an area where radioactive materials
were being used.
(1)
Misunderstanding by the authorized user concerning che
proximity of
a coffee pot and the use of radioactive materials.
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(2)
The coffee pot has been removed from the room and all
personnel working in the laboratory have been instructed as to
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the importance of physically separating all food / drink from areas
were radioactive materials are used or stored.
(3) Education of personnel involved.
(4)
Full compliance has been achieved.
Violation C 2 - failure calibrate a survey meter.
(1)
The WRC was not required to have a survey meter for
radioactive material use as approved by the RSC therefore no
instrument calibration was required.
(2)
The RSC has considered the concern of the NRC inspector
and will require
that a calibrated survey meter be available to
the WRC.
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(3)
The authorized user has been advised of the additional
requirement and has been instructed as to how he can meet the
requirement.
(4)
Full compliance has been achieved.
Violation C 3
failure to provide adequate training for a
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supervised user.
(1)
The person in question was working under the direct
supervision of an authorized user.
The authorized user was
available at all times if any assistance was needed.
However in
the questioning of the user it was apparent that she did not
understand all the requirements under the Itcense.
The reason
was inadequate training and not the absence of training.
(2)
Since the inspection both the authorized user and the
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RSO have conducted informational / training sessions with the
supervised user.
(3)
An increased frequency of training sessions in the
future will prevent such occurrences.
(4)
Full compliance has been achieved.
Violation C 4
failure to conduct radiation surveys and/or
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failure to keep adequate records of such surveys.
(1)
Misunderstanding by the authorized user as to the
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frequency of surveys as required by the license and the need and
importance of survey records.
(2)
'The authorized user has been informed concerning the
f equency and records related to surveys.
He has been provided ,as
will all other authorized users, with written material which
reviews the requirements of the license including survey requite-
ments.
(3)
Surveys as well as other requirements of the iteense
will be discussed in detail with all authorized users by the RSO.
(4)
Several of these sessions have already taken place and
will continue.
All authorized users will be reviewed within a few
weeks.
Violation C 5
failure to make proper records of radiations
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surveys.
This violation involves the same laboratory and the same
authorized user as the previous violation
see Violation C 4
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Violation C 6
failure to properly label a radioactive vaste
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container with the radiation symbol and the words ' Radioactive
Waste'.
(1)
Carelessness on the part of the supervised user.
This is the same laboratory and supervised user as discussed
previously - see Violation C 3.
Violation D
using a sign with the words ' Caution Radiation
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Area'
instead of a sign with the words ' Caution Radioactive
Materials'.
(1) Misunderstanding of the regulations by the RSO.
The
building was marked with an all-weather sign with the radiation
symbol and the words "Caution Radiation Area" as well as a
document listing persons to be contacted in case of emergencies.
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(2) A sign with the radiation symbol and the words ' Caution
Radioactive Materials'
has been posted on the building.
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(3) Education of RSO.
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(4)
Full compliance has been achieved.
Violation E':- NRC-3 form not posted in the O'Neill Building.
(1) The only radioactive material in Room 325 of O'Neill
Bldg. is the EC detector containing a tritium foil.
The room was
recently altered and the instrument as well as most of the
other equipment in the room was rearranged.
The NRC-3 form was
inadvertently taken down and was not re posted following the
alteration.
(2) A new NRC-3 form has been posted and compliance has been
achieved.
(3) The user of the instrument has been instructed as to the
importance of the proper posting for the room and for the instru-
ment.
(4)
Full compliance has been achieved.
Violation F
transporting radioactive materials fron the main
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campus to the LARS without meeting DOT regulations.
(1)
Misunderstanding by the RSO concerning DOT regulations
and how they apply to the transfer of radioactive materials from
one site to another when both sites are part of the University-
campus.
(2)
DOT regulations have been reviewed with the authorized
user involved in the transfers.
A shipping form (shipping
papers) has been drawn-up which requests the information required
by DOT for the transfer of radioactive materials on public
highways.
(3)
Dot regulations will be reviewed with all authorized
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users who transport radioactive caterisis from their site of
receipt via public means.
(4)
Full compliance has been achieved.
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