ML20151F029
| ML20151F029 | |
| Person / Time | |
|---|---|
| Site: | 05000128 |
| Issue date: | 07/13/1988 |
| From: | Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Richardson H TEXAS A&M UNIV., COLLEGE STATION, TX |
| Shared Package | |
| ML20151F031 | List: |
| References | |
| EA-88-092, EA-88-92, IEIN-81-26, IEIN-83-59, IEIN-86-044, IEIN-86-44, NUDOCS 8807260311 | |
| Download: ML20151F029 (4) | |
See also: IR 05000128/1988001
Text
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGION IV
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611 HYAN PLAZA DE E, SUITE 1000
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ARLINGTON. TEXAS 76011
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J1.I31988
Docket-No.
50-128
License No. R-83
EA 88-92
Texas A&M University
,
ATTN: Dr. Herbert H. Richardson, Director
Texas Engineering Experiment Station
College Station, Texas 77843
Gentlemen:
SUBJECT: NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF civil PENALTY (NRC
INSPECTION REPORTS 50-128/88-01 AND 88-03)
This refers to the inspections conducted'by Mr. H. D. Cheney of this office
during March 7-9 and April 11-12, 1988, at the Nuclear Science Center. During
these inspections, several violations were identified. The violations were
discussed at an enforcement conference on April 5, 1988, at the NRC Region IV
office and on April 12, 1988, at the exit meeting following the April 11-12
inspection.
The violations identified during the inspections included the failure to
provide appropriate personnel monitoring equipment-and proper placement of
personnel monitoring equipment, failure to establish proper control for high
,
radiation areas, and failure to provide radiologicci instructions to personnel
working in a restricted area. As part of the inspections, we reviewed the
circumstances surrounding a possible overexposure reported to the NRC on
December 10, 1987. Although your subsequent evaluation did not establish that
an actual overexposure to the individual occurred, the NRC inspections
uncovered evidence of sh,ortcomings in your programs to guard against such
occurrences. The violations are of significant concern to the NRC because,
collectively, they indicate that there has been a failure to exercise adequate
management oversight and control of the radiation protection program at the
Nuclear Science Center.
To emphasize the need to improve radiation protection control, I have been
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authorized, after consultation with the Director, Office of Enforcement, and
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the Deputy Executive Director for Regional Operations, to issue the enclosed
Notice of Violation and Proposed Imposition of Civil Penalty in the amount of
Five Thousand Dollars ($5000) for the violations described in the enclosed
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CERTIFIED MAIL
RETURN RECEIPT REQUESTED
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0807260311 880713
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Texas A&M University
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Notice.
In accordance with the "General Statement of Polic and Procedure for
NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1988) y(Enforcement
Policy), the violations described in Section I of the enclosed Notice have
been collectively categorized as a Severity Level III violation.
The base value of a civil penalty for a Severity Level III violation is'$2500.
The escalation and mitigation factors is the Enforcement Policy were
considered. The base civil penalty amount has been increased by 100 percent
,
because of prior notification given to you, multiple examples of the
v'iolations, and the duration of the violations, notwithstanding your prior good
enforcement history. These violations existed for approximately four months
and were not discovered by your radiation protection personnel. Given the
number of opportunities available to. identify and correct the violations, added
significance has been given to the duration of the violations. During this
..
perioC there were at least seven examples where individuals were not given
sufficient training.
In addition, there have been three NRC_Information
Notices issued since 1981 that should have alerted you to the need for
edditional controls for work in high radiation areas and non-uniform radiation
fields. The three NRC Information Notices are:
IN 86-44, "Failure to Follow
Procedures When Working in High Radiation Areas," IN 83-59, "Dose Assignment
for Workers in Non-Uniform Radiation Fields," and IN 81-26, "Placement of
Personnel Monitoring Devices for External Radiation Exposure."
'
In addition,Section II of the Notice of Violation includes a violation for
which no civil penalty is being proposed. This violation, which involves your
failure to perform a safety evaluation for a modification to a drain line from
a radioactive liquid effluent storage tank, has been categorized as a Severity
.
Level IV vie'ation.
You are required to respond to this letter and should follow the instructions
specified in the enclosed Notice when preparing your response.
In your
response, you should dccument the specific actions taken and any additional
actions you plan to prevent recurrence. After reviewing your response to this
Notice, incicding your proposed corrective actions and the results of future
inspections, the NRC will determine whether further NRC enforcement action is
necessary to ensure compliance with NRC regulatory requirements.
j
The inspection findings documented in Section 2 of NRC Inspection Report 50-128/
88-01 also indicated several significant program weaknesses, which were
documented as open items in the report. The NRC is concerned that, if action
is not taken to review and close out these items, future violations could
,
Therefore, you are requested to submit a written statemert, within
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occur.
30 days of your receipt of this letter, describing your action f a each
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significant p(rogram weakness identified as an open iten in the report 1) steps wh
including:
(3) a ichedule for completion of action.
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. _ _ _ _ _ _ _ _
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Texas A&M University
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In accordance with Section 2.790 of the NRC's "Rules of Practice," Part 2,
Title 10, Code of Federal Regulations, a copy of this letter and its enclosure
will be placed in the NRC Public Document Room.
The responses directed by this letter and the enclosed Nctice are not subject
to the clearance procedures of the Office of Panagement and Budget as required
by the Paperwork Reduction Act of 1980, Pub. L. No.96-511.
Sincerely,
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D. Martin
egional Administrator
Enclosure:
Notice of Violation and Proposed
Imposition of Civil Penalty
cc: Texas Bureau of Radiation Control
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