ML20198L834
| ML20198L834 | |
| Person / Time | |
|---|---|
| Site: | 15000003 |
| Issue date: | 10/02/1997 |
| From: | Bellamy R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | James Shepherd J.L. SHEPHERD & ASSOCIATES |
| References | |
| 15000003-97-01, 15000003-97-1, NUDOCS 9710270176 | |
| Download: ML20198L834 (34) | |
Text
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OCT ~ 2 l997
- J.L.- Shepherd -
-~J.L. Shepherd & Associates 1010 Arroyo Avenue San'Fernando, California 91340 1822'
SUBJECT:
INSPECTION NO. 15000003/97-001
Dear Mr. Shepherd:
On September 26 & 30,1997, Mr. Steve Shaffer of this office conducted a safety inspection at the U.S. Army base at Fort Monmouth, New Jersey of activities authorized by the Cali.fornia license listed below. Your activities in NRC jurisdiction are a
authorized by a general license granted by 10 CFR 150.20(a). The inspection was an examination of your licensed activities as they relate to radiation safety and to compliance with.the Commission's regulations and the license conditions. The inspection was limited to observations by the inspector, interviews with personnel and selective examination of records related to activities within the NRC's jurisdiction. The findings of the inspection were discussed with Messrs. Ralph Jacobs and Mike Novak, at the conclusion of the inspection.
Within the scope of this inspection, no violations were identified, in accordance with Section 2.700 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter will be placed in the Public Document Room. No reply to this letter is required.
Your cooperation with us is appreciated.
Sincerely, gr. a r~.,..
m,,
[*
&r,.lX2.fitein>
Ronald R. Bellamy, Chie(P Decommissioning & Laboratory Branch Division of Nuclear Materials Safety 1
. Docket No.: 15000003'
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k California License No.- 1777-19 a76pj3 OFFICIAL RECORD COPY lE:07~ M;$,P liUTU '!! T ' E'NAL TO IL.CiLili 9710270176 971002'
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-3 Distribution: w/enct PUBLIC Nuclear Safety Information Center (NSIC)
Region i Docket Room (w/ concurrences)
C. Buracker, Pi (with fieldnotes)
DOCUMENT NAME: C:\\ TYPING \\lNSPECT\\JLSHEPH 97 To receive a copy of this document. Indicate in the boa: *C" = Copy w/o attach / encl, 'E' = Cofy w/ sttach/, w:t
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DATE 10/01/97 10/ k /97 10f /97\\
10/ /97 OFFICIAL RECORD COPY 9
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APPENDlX A INDUSTRIAL / ACADEMIC /RESEARCH INSPECTION FIELD NOTES l
RegionI Inspection Report No.
97-00/
License No. (AL,'[.<ms t.m oe.
Licensee (Name & Address):
Docket No, /#o -oo% 3
- 3. L. 5%LJ
+ Assoc.
/O/o Ar<It s e, Atm.
.$. s ?u e, >$
(A 9/S4'O * / % 21 Licer.see Contact ra /g/ %dr Telephone No.
Amendments Issued Since Last inspection: (Nurabers)
/h.~dm / A4 7.g Dates of Above Amendments:
4.//4,m7 Priority:
A m c./7 Program Code ch;25 Date of Last Inspection B
h/
am,
Date of This inspection
/W ' /' ' '
9A..us ac-su arq Type of Inspection:
( ) Annourfced (N Unannounced
( ) Routine
( ) Special
( ) Initial
( ) Reinspection Next Inspection Date / L.oy.m./1/
( ) Normal ( ) Reduced ( ) Extended
/
Justification for change in normal inspection frequency:
Summary of Findings and Action:
(4 No violations cit.ed, Clear NRC Form 591 or regional letter issued
( ) Violation (s) NRC Form 591 issued
( ) Violation (s)
( ) Followup on pru,gional letter issued 1ous violations
/c;///n Inspector:
fdM f//dt Date (Signatu
/ /
Appioved:
cM[ (, }
(%
Date C I 4.,/6 9 )
(Signature) d~
Issue Date:
02/03/97 A-1 87110. Appendix A
~
Field notes are to be used by the inspector to assist with the performance of the inspection. Note that all areas indicated in the field notes are not i
required to be addressed during egh inspection.
However. for those areas not covered during the inspection, a notation ("Not Reviewcdf) should be I
made in each section where applicable. Additionally, all areas covered during the inspection should be doctmented in sufficient detail to describe what activities and/or records the inspector observed.
For exaaple, the types of records that were reviewed and the time periods covered by those records should be noted.
If the licensee demonstrates any practices at your request, desciIbe those damnstrations.
The observations and demonstrations you describe in this report along with measurements and some records review, should substantiate your inspection findings.
NOTE: For ir.spections of radioactive drug distributors, ensure that all applicable sections (regarding 10 CFR Part 32) of the radiopharmacy field notes are completed.
1.
JESPECTION. LICENSING. AND INCIDENT HISTORY A.
Violations were identified during anv of the last two inspections or two years, whichever is longer. (N/A - Initial insp.)
% N/A ( ) Y ( ) N 4<;
B.
Response letter (s) or 591(s) dated C.
Violations from previous inspection (s):
REQUIREMENT CITED STATUS D.
Any repeat violation (s) identified?
()Y(/)N If "Yes " explain:
/
C 87110. Appendix A A-2 Issue Date:
02/03/97
~
E.
License amendments issued since last inspection, or program changes noted in the license:
ph AMENDMENT #ffT2 SUBJECT F.
During this inspection. was the licensee's program changes inspected / observed? implementation of all of th f
G.
During this inspection. were any violations identifieo involving any of the above f(j)N/A()Y()N amendments or program changes?
H.
List any incidents or events reported to NRC since the last inspection (Note:
"None" indicates that regional event logs, event files, and the licensing file have no evidence of any incidents or events since the last inspection):
[)None INCIDENT OR EVENT 1.
During this inspection, were the incidents / events reviewed with the licensee, and was the licensee's follow-up
[)N/A()Y()N to the incidents / events examined?
Issue Date:
02/03/97 A-3 87110. Appendix A
C - '.
- I J.
Describe the licensee's follow.up in response to the events / incidents listed in 1.H.
Comments:
2.
ORGANIZATION AND SCOPE OF PROGRAM A.
Describe the licensee's organizational structure to indicate the
" chain.of-command" from senior management to-authorized users of licensed material, Show or describe where the RSO and Chairperson of the RSC are located in the licensee's organization and to whom they report:
M. Ja.l', t fit. IV0^ h-fe h ~ 44 3 r -
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A. ilf ~~./ CJ~. Ay " *ny felej. < c-s{ m er
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87110, Appendix A A-4 Issue Date:
02/03/97
8.
Identify. licensee personnel contacted during-the
- Inspection (including those individuals contacted by telephone);
- t n ec Ahv l(.
yRJ(L % 4s t); r,4,,,
asu, &.
HAznnr r~h o~r 1
(Use the_following identification symbols:)
- Individuals present at entrance meeting
- Individuals present at exit meeting
+ Individuals contacted by telephone C.
Authorized for multiple locations of use
)( Y()N If yes, may use ATTACHMENT A as a guide for inspecting laboratories.
D.
Authorized for multiple permanent field office locations
()Y/y))N (1)
Inspection performed at multiple field offices
()Y N
(2)
If "Yes." list office locations inspected:
E.
Authorized for temporary -job site locations (dY()N (1)
Inspection performed at temporary job site (s)
(/)Y()N (2)
If not, describe why not:
%yerayjd-vle o~I.f c.
4 Issue Date:
02/03/97 A-5 87110, Appendix A
n_._ 7 F.
Briefly describe scope of activities, including types and quantities of use involving licensed materia', frequency of use. staff size, etc.
/ yuk-of M ^- v ' 7 o f ~
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3.
MANAGEMENT OVERSIGHT A.
Radiation Safety Committee (RSC) required [L/C]'
W ()Y()N (1)
RSC fulfills license requirements [L/C]
()Y()N (2)
Records maintained [L/C]
()Y()N B.
Radiation Safety Officer (RS0)
MI (1)
Authorized on license [L/C]
()Y()N (2)
Fulfills duties as RSO
()Y()N C.
Audits. Reviews, or Inspections p[
(1)
Audits are required [L/C]
()Y()N (2)
Audits or inspections are conducted
()Y()N Audits conducted by Frequency (3)
Content and implementation of the radiation protection program reviewed anniially by the licensee [20.1101(c)]'
()Y()N (4)
Records maintained [20.2102]
()Y()N D.
Use by authorized individuals [L/C]
/)Y()N E.
If supervision permitted by the license or by regs, authorized users supervise adequately [L/C] f ( ) Y ( ) N Here and throughout the field notes.
"L/C" means
" license condition."
Here and throughout the field notes, sections of 10 CFR are 2
referenced only by their section numbers.
87110. Appendix A A-6 Issue Date:
02/03/97
')
4.
FACILITIES h) t A.
Facilities as described in license application [L/C)
()Y()N B.
Facilities are secured to prevent unauthorized access [L/C]
()Y()N C.
Describe any self-contained dry-source-storage irradiators and/or survey instrument i
calibrators (model, radionuclide, activity, use, etc.)
( ) N/A (1)
Maintenance of safety-related com)onents performed by authorized persons [./C]
()Y()N (2)
Access to keys and/or material controlled
[20.1801-1802,L/C]
()Y()N (3)
Access to high/very high radiation areas controlled [20.1601-1602. L/C]
()Y()N (4)
Adequate protection of shield integrity, fire protection [L/C]
()Y()N Basis for findings:
5.
EQUIPMENT AND INSTRUMENTATION A.
-instruments and equipment:
(1)
Appropriate operable survey instrumentation possessed and readily accessible [L/C]
/
(2)
Calibrated as required [20.1501. L/C]
/))Y()N Y()N (3)
Calibration records maintained [20.2103(a)] g
()Y()N B.
Procedures established to identify and report safety component defects [21.21]
/)Y()N Basis for Findings:
Issue Date:
02/03/97 A-7 87110. Appendix A
9 6.
MATERIALS RECEIPT. USE. TRANSFER. AND CONTROL A.
Isotope, chemical form. quantity, and use. as authorized [L/C]
(/)Y()N B.
Licensed materials secured to prevent unauthorized removal or access [20.1801-1802]
gy
()Y()N (1)
Licensed material in storage in controlled or unrestricted areas is secured from unauthorized removal or access (20.1801]
()Y()N (2)
Licensed material in controlled or unrestricted areas and nuc in storage is controlled and under constant surveillance [20.1802]
()Y()N (3)
Access to restricted areas is limited
[20.1003]
()Y()N C.
Describe how packages are received and by whom: f
( ) N/A D.
Written package opening procedures established and followed [20.1906(e)]
(;Y()N E.
All incoming packages with DOT labels wiped unless exempted (gases and special form) [20.1906(b)(1)]
()Y()N F.
Incoming packages surveyed [20.1906(b)(2)]
()Y()N G.
Monitoring in (E) and (F) above performed within time J/
specified [20.1906(c)]
()Y()N H.
Transfer (s) between licensees performed [30.41]
( )Y()N I.
All sources surveyed before shipment and transfer
/
s
[20.1501(a). L/C]
()Y()N J.
Records of surveys and receipt / transfer maintained
[20.2103(a). 30.51]
()Y()N K.
Transfers among licensee's authorized users or locations performed as required [L/C]
( ) N/A ( ) Y ( ) N L.
Arrangements made for packages containing quantities of radioactive material in excess of Type A quantity [20.1906(a)]
( ) N/A ( ) Y ( ) N M.
Package receipt / distribution activities evaluated for compliance with 20.1301 (20.1302]
( ) N/A ( ) Y ( ) N Basis for Findings:
C 87110. Appendix A A-8 Issue Date:
02/03/97
e 7.
TRAINING. RETRAINING. AND INSTRUCTIONS TO WORKERS A.
Instructions to workers / students [10 CFR 19.12]
J/) Y ( ) N B.
Training program required [L/C) y)Y()N (1)
If so, briefly describe t"aining program:
~1k. -C.A/.u rker:, r: o a x wu ~ l n'j I~A'*'**<
ic/L </ w ~ ^ +
(2)
Trai:11ng program implemented V)Y()N (3)
Periodic training program required V) Y ( ) N (4)
Periodic training program implementesi V)Y()N (5)
Records maintaired d
( ) Y.( ) N C.
Individual's understanding of procedures and regulations is adequate
%Y()N (1)
Current operating procedures
[())Y()N Y()N (2)
Emergency procedures pf (3)
Use of survey instrumentation f)Y()N D.
Revised Part 20 Workers cognizant of requirements for:
(1)
Radiation safety program [20.1101]
(2)
Annual dose limits [20.1301-1302]
/))Y()N VY()N (3)
New NRC Forms 4 and 5
( ) N/A V) Y ( ) N (4) 10% monitoring threshold [20.1502]
(/) Y ( ) N (5)
Dose limits to embryo / fetus and declared pregnant worker [20.1208]
()Y()N (6)
Grave danger posting [20.1902]
( ) N/A V) Y ( ) N (7)
Procedures for opening packages
[20.1906]
V) N/A ( ) Y ( ) N (8)
Sewer disposal limits [20.2003]
) N/A ( ) Y ( ) N Basis for Findings:
8.
AREA RADIATION SURVEYS AND CONTAMINATION CONTROL A.
Briefly describe area survey requirements [20.1501(a). L/C]:
e Issue Date:
02/03/97 A-9 87110. Appendix A
~
4 4.
B.
Performed as required [20.1501(a). L/C]
()Y()N (1)-
Centamination found
(.) Y ( ) N (2)
Corrective action taken and documented
()Y()N C.
Records maintained [2r.2103. L/C]
()Y()N D.
Handling and use of radioactive materiais [L/C]
(1)-
Protective clotm ng worn
( )-Y ( ) N-(2)
Personnel routinely monitor or frisk themselves
- after procedures or before leaving
()Y()N
-(3)
No eating / drinking / smoking in use/ storage areas ( ) Y ( ) N (4)
No food, drink, or personal effects stored in use/ storage areas
()Y()N (5)
Proper dosimetry worn
()Y()N (6)
Radioactive waste disposed in proper containers ( ) Y ( ) N (7)
No pipetting by mouth
()Y()N (8)
Use of shielding / distance while using/ storing material
()Y()N Basis for Findings:
/
6.
Protection of members of the public
/
(1)
Licensee made adequate surveys to demonstrate either: (1) that the TEDE to the individual likely to receive the highest dose does not exceed 100 mrem in a year: or (2) that if an indiv. dual were continuously present in an unrestricted i.rea, the external dose would not exceed 2 mrem in any hour and 50 mrem in a year [20.1301(a)(1). 1302(b)]:
and (3) the air-emmissions to the atmosphere are withing the constraint level-[20.1101]
()Y()N (2)
Unrestricted area radiation levels do not exceed 2 mrem in any one hour [20.1301(a)(2)]
( ) Y-( ) N (3)
Records maintained [20.2103, 20.2107]
()Y()N F.
Leak tests and Inventories [L/C]
(1)
Performed as required
()N/A([Y()N (2)
Adequate analysis methodology and sensitivity
( ) N/A (/) Y ( ) N (3)
Records maintained [L/C]
()Y()N g
Basis for Findings:
lc $. ),g r w es e.
~4<~
~~ W
"j# N.
87110. Appendix A.
A-10 Issue Date:
02/03/97
9.
RADIATION PROTECTION A.
Licensee performed exposure evaluation [20.1501]
()Y()N B.
Licensee incorporated ALARA considerations in th?
radiation protection program [20.1101(b))
( ) Y (.) N C.
External Dosimetry
( ) N/A (1)
Licensee monitors workers [20.1502(a). L/C]
K)Y()N (2)
External exposures account for coltributipns from airborne activity [20.1203]
(M N/A ( ) Y ( ) N (3)
Processor U Or i.)
Frequency AdM),
(4)
Processor is NVLAP-approved [20.1501(c)]
V)Y()N (5)
Dosimeters exchanged at required frequency [L/C]V) Y ( ) N D.
Internal Dosimetry J4N/A (1)
Licensee monitors workers [20.1502(b). L/C]
()Y()N (2)
Briefly describe licensee's program for monitoring and controlling internal exposures
[20.1701-1702. L/C]:
(3)
Air sampling performed
()Y()N (4)
Monitoring / controlling program implemented
()Y()N (5)
Respiratory protection equipment [20.1703. L/C] ( ) Y ( ) N E.
Reports
( ) N/A (1)
Reviewed by Frequency (2)
Inspector reviewed personnel monitoring records for period to (3)
Prior dose determined for individuals likely to receive doses [20.2104]
()Y()N (4).
Maximum exposures TEDE Other (5)
Maximum COEs Organs (6)
Maximum CEDE i
(7)
Licensee-sums internal and external [20.1202]
()Y()N (8)
TEDEs and TODEs within limits [20.1201]
()Y()N Issue Date:
02/03/97 A-11 87110, Appendix A
(9)
NRC forms 00 equivalent (20.2104(d). 2106(c))
(a)
NRC form 4
()Y()N Complete:
()Y()N (b)
NRC form 5 ()Y()N Complete:
()Y()N (10) Worker declared her pregnancy in writing during inspection f,eriod (review records)
( ) N/A ( ) Y ( ) W If yes. licensee in compliance with dose to embryo / fet,is (20.1200)
( )Y()N and records maintained [20.2106(e)]
()Y()N f.
Who performed PSEs at this facility (number of people involved and doses received)? [20.1206. 20.2104 2105.
20.2204)
N/A G.
Records of exposures, surveys, monitoring, and evalm tions maintained (20.2102-2103. 20.2106, l/C)
()Y()N 11.
l'ecosec advises each worker annually of worker's dose [19.13(b)]
g]
()Y( )N Basis for findings:
i 10.
[M0106CllVLWASIUiA!MG@QG
/\\
( ) N/A A.
Disposal
( ) N/A (1)
Decay in storage
( ) N/A (a)
Pror,edures approved [20.2001(a)(2). L/C)
()Y()N (b)
In accordance with (t./C]
( )Y()N (c) labels removed or defaced [20.1904(b)]
()Y()N
/^>
Special procedures performed as required [L/C3
()Y( )N (3)
Liquid scintillatior. (LS) media and animal carcasses [20.2005]
( ) N/A ( i Y ( ) N (4)
Improper / unauthorized disposals (20.2001)
()Y()N (b)
Records maintained
[20.2103(a).20.2108. L/C)
()Y()N 87110. Appendix A A-12 issue Date:
02/03/97
B. Effluents
( ) N/A (1)
Release into sanitary sewer [20.2003]
( ) N/A ( ) Y ( ) N (a)
Material is readily soluble or readily dispersible [20.2003(a)(1)]
()Y()N (b)
Monthly average release concentrations do not exceed Appendix B values
[20,2003]
()Y()N (c)
No more than 5 C1 of 11-3. 1 Ci of C-14 and 1 Ci of all other radionuclides combined released in a year [20.2003]
()Y()N (d)
Procedures to ensure representative sampling and anal sis properl'v implemented [20.lb01(a)(2). L/C]
()Y()N (2)
Release to septic tanks [20.2003]
( ) N/A ( ) Y ( ) N (a)
Within unrestricted limits [ App B. Table 2] ( ) Y ( ) N (3)
Waste incinerated
( ) N/A ( ) Y ( ) N (a)
License authorizes [20.2004(a)(3)]
()Y()N (b)
Licensee directly monitors exhaust
()Y()N (c)
Airborne releases evaluated and controlled [20.1501, 20.1701]
()Y()N (4)
Control of effluents and ashes [20.1201.
(N/A) 20.1301, 20.1501, 20.2001. L/C]
(SeealsoIP87102.RG8.37)
(a)
Air effluent less than 10 mrem constraint limit [20.1101]
( )Y ( ) N (b)
If no, licensae reported appropriate information to NRC
()Y()N 1.
Corrective actions implemented and on schedule
()Y()N e
issue Date:
02/03/97 A-13 87110. Appendix A
(c)
Description of effluent monitoring program (i)
Monitoring system hardware equipment adequate
()Y()N (ii) Equipment calibrated as appropriate ( ) Y ( ) N (iii) Air samples / sampling technique (atarcoal. HEPA. etc.) analyzed with appropriate equipment
()Y()N Basis for findings:
C Waste Management
( ) N/A (1)
Wastecompacted[L/C)
()Y()N (2)
Storage area (s)
( ) N/A (a)
Protection from elements and fire [L/C)
()Y()N (b)
Control of waste maintained [20.1801)
()Y()N (c)
Containers properly labeled and area aro)erly posted [20.1902. 20.1904]
()Y()N (d) 3accage integrity maintained [L/C]
()Y()N c
87110. Appendix A A-14 Issue Date:
02/03/97 m_.
---__m d8
(3)
Packaging. Control and Tracking
[Part 20. App. F.Ill.] [20.2006(d)):
Note: The licensee's waste is likely to be Class A.
)
(a)
Not packaged for disposal in cardboard 1
or fiberboard boxes [61.56(a))
()Y()N i
(b)
Liquid wastes solidified. (i.e.. less than 1% freestanding liquid) and void spaces minimized [61.56(a). (b))
()Y()N (c)
Does not generate harmful vapors [61.56)
()Y()N (d)
Structurally stable (will maintain its physical dimensions and form under expected disposal conditions) [61.56(b))
()Y()N (e)
Packages properly labeled
[ App. F.lli.A.2)
()Y()N (f)
Licensee conducts a OC rogram to ensure compliance with 61.55-56) and includes management eva uation of audits [ App F.Ill.A.3]
()Y()N (g)
Shipments not acknowledged within 20' days after transfer are investigated and reported
[ App. F.Ill.A.8)
( ) N/A ( ) Y ( ) N (4)
Transfers to land disposal facilities
( ) N/A (a)
Transferred to person specifically licensed to r_er.ejve waste
[30.41, 20.2001(b)]
()Y()N (b)
Each shipment accompanied by a manifest prepared as specified in Section I of Appendix F [20,2006(b). App. F.lll.A 4)
()Y()N (c)
Manifests certifled as specifled in Section 11 of Appendix F [20.2006(c)]
()Y()N D.
Records of surveys and material accountability are maintained [20.2103, 2108]
()Y()N 8 asis for Findings:
(.
I' Issue Date:
02/03/97 A-15 87110. Appendix A
11.
RECORDKEEPING FOR DECOMMISSIONIN))
A.
Records of information important to the safe and effective decommissioning of the facility maintained in an independent and identifiable location until license termination.
()Y()N B.
Records include all required information (30.35(g)]
()Y()N (1)
List of restricted areas [30.35(g)(3))
indicates that laboratories or other rooms have been released since the last inspection
()Y()N (2)
Confirmatory measurements show that each room is within release limits, and licensee records adequately document the basis for releasing each room
()Y()N C.
Copics of the licensee's deconrnissioning cost estimates and funding methods on file
()Y()N D.
If the licensee uses a parent company guarantee or a self guarantee as funding method, does the file contain a copy of the financial test performed for the licensee's most recently completed fiscal yeari
( ) N/A ( ) Y ( ) N E.
If "Yes" to D.
do the financial test ratios meet the criteria in 10 CFR Part 30.
Appendix A. Section 11 for parent company guarantees and Appendix C. Section 11 for self guarantees?
()Y()N F.
Date that licensee's financial assurance instrument
( ) N/A was submitted to NRC. if applicable:
G.
Date that licensee's decommissioning plan was
( ) N/A submitted to NRC. if applicable:
H.
liave radiological conditions at the licensee's facility changed since the financial assurance mechanism and/or decommissioning plan was submitted due to:
(1)
Incidents or events?
( ) N/A ( ) Y ( ) N (2)
Unplanned process upsets or changes?
( ) N/A ( ) Y ( ) N (3)
Unauthorized material. form.-or possession limit changes?
( ) N/A ( ) Y ( ) N (4)
Any other changes?
( ) N/A ( ) Y ( ) N If "Yes" to any of the above (1)-(4).
notify regional management.
Basis for Findings (include comments and measurements on any areas the licensee released for unrestricted use):
c 87110. Appendix A A.16 Issue Date:
02/03/97 N
r-
I 4
12.
@ TJANCE WITH DECOMMISSIONING TJfELINESS RULE I'
.icense to conduct a principle activity has expired or been revoked
()Y()N 6.
Licensee h n made a decision to )ermanent'y cease principal activities, at t1e entire s1te, or any separate buildings, or any outdoor areas, including inactive burial grounds
()Y()N L
C.
A 24-month duration has passed in which no princfpal activitles, have been conducted under the license at the site, or at an buildings, or any outdoor areas, y separate including inactive burial grounds
()Y()N D,
if "Yes" to either A or B or C:
(1)
Identify Site / Bldg / Area:
(2)
Date of occurence of A, B, or C:
NOTE: If "No" to A and B and C, decommissioning timeliness rule does not apply.
If "Yes" to either A or B or C, then complete Attachment B. " Decommissioning Timeliness Field Notes," for this licensee.
Basis for Findings:
13.
TRANSPORTATION (10 CFR 71.5(a) and 49 CFR 170 189)
( ) N/A A.
Licensee Transoorts: [cmplete sections (1) - (4) as applicable]
(1)
Limited Quantities, and/or instruments and p()N/A Manufactured Articles:
(Radioactive Material, excepted package, [ additional info]. 7 UN 2910)
(a)
Package meets general design requirements [173.410]
()Y()N (b)
Radiation level 5 0.005 mSv/hr (0.5 mrem /hr) (Exclusive use instruments and articles. 2 mrem /hr)
()Y()N (c)
Contamination less than 173.443 limits.
OC examination / test performed prior to each shipment [173.475(1)]
()Y()N (d)
Limited Quantity Package marked
" Radioactive" [173,421(a)(4)]
()Y()N (e) 173.422 certificat. ion statement attached / enclosed ("This package conforms to the conditions and limitations specified in.
")
()Y()N Issue Date:
02/03/97-A 17 87110. Appendix A
=
(2)
Type A Quantities (Radioactive Material, nos,
( ) N/A 7, UN 2982)
(a)
Packaging:
(1)
Packaging is proper for contents (i.e., DOT 7A), is unimpaired, and is prepared correctly
[173.475(a)-(f)]
()Y()N (ii) All packages meet general design requirements [173.410]
y')Y()N (iii) DOT 7A Package meets additional Type A design requirements
[173.412. 178.350]
()Y()N (b)
Recordkeeping:
(1)
Special Form source records
[173.476(a)]
[)Y()N (ii) 00T 7A performance / design documentation [173,415(a)]
()Y()N (c)
Hazards communications requirements (consult the "NRC field reference charts" that correspond to elements (1) through (v) below):
(1)
Shi1 ping Paaers (172.200 205]
Y()N (ii) Marcing Pactages [172.300 338]
Y()N (iii) Labeling Packages (172.400 450]
Y()N (iv)
Placarding Vehicles (172,500-560]v4
)Y()N (v)
Emergency Response information and guidance [172.600 604]
[)Y()N (d)
Radiation level / Contamination limits
[173.441,173.443]
+
(1)
Package levels within limits piY()N (ii) OC examination / test performed prior / Y ( )
to each shipment [173.475(1)]
(3)
Type 8 Quantities (Radioactive Material, nos.
( ) N/A
- 7. UN 2982)
(a)
Packaging is proper for contents (i.e..
Type 8), is unimpaired, and is prepared correctly [173.475(a)-(f)]
f/) Y ( ) N (b)
Inspector must complete Section 2 of NRC L
Inspection Procedure (IP) 86740 (c)
Sections 2.c. and 2.d., shown in the pre-vious section for Type A Quantities, also apply.
Complete those sections, c:
87110.-Appendix A A-18
-Issue Date:
02/03/97
. = =
= -. - -.
i (4)
LSA Material and SCO (Radioactive Material, f)() N/A LSA nos. 7. UN 2912) or (Radioactive Material.
SCO. nos. 7. UN 2913)
(a)
If licensee makes significant LSA/SCO shipments. inspector should complete Inspection Requirement 03.02 of Temporary Instruction (TI) 2515/133 (issued 3/15/96)
(b)
Otherwise, if licensee has a minor LSA/SCO program:
(1)
Licensee pro)erly characterizing material as.SA/SCO [173.403]
()Y()N (ii) All packages meet general design requirements [173.410]
()Y()N (iii) Froper LSA/SCO packaging selected and used (173.475. 173.427)
()Y()N (iv) Placarding exclusive use vehicles, marking package " Radioactive-LSA" or " Radioactive SCO." as a)propriate [173.427(a)(6)]
()Y()N (v)
Slipp)NRC field reference chart" ng Papers [172.200-205]
(see for content and exceptions)
()Y()N B.
00T HAZMAT Employee Trainino Prooram [49 CFR 172.700-704]:
(1) tested [172.70b]loyeereceivestrainingandis /)Y()N Each HAZMAT em (2)
Recurrent training at least every 2 years
[172.704(c)(4)]
jdY()N (3)
HAZMAT employee training includes general awareness, function.5pecific. and safety training (172.704]
(/fY()N (4)
HAZMAT employer recordkeeping includes employee name, completion date.
description / copy / location of training A/p materials. name and address of training provider, and certification [172.704(d)]
()Y()N C.
Carrier Modal Soecific Reauirements. Hiahway
( ) N/A Transoortatioll [49 CFR Part 177):
(1)
Oriver Training, or COL w/ HAZMAT endorsement
[177,800. 177.816]
.(!)Y()N (2)
Incident Reporting to DOT [177.807, seealsoI.
171.15 and 171.16]
()Y()N (3)-
Shipping Paper Accessibility (on seat or in driver's side door Jocket. readily visible)
/)Y()N (4)
Placarded Vehicles touting and Driver Training requirements [177.825 and 49 CFR 397 Subpart 0 (i.e., the motor carrier regs)]
MA
()Y()N (5)
Sum of total Jackage tis on non-exclusive use!i vehicle < 50 [177.842(a)]
V
()Y()N (6)
Packages blocked / braced for transport
[177.842(c)]
Y()N issue Date:
02/03/97 A-19 87110. Appendix A
..--n
.~
O.
Miscellaneous Reauirements (1)
No labeled packages carried in passenger compartments [173.448(c)]
(Y)Y()N (2)
Overpack requirements observed if packages are offered in overpack.
Over shipping name and number, pack marked w/ proper package and overpack labeled as needed, marked ' inner package complies...." [173.24]
k)Y()N (3)
Expanded and changed A1/A2 values from the 4/1/96rulechangeshavebeenim$lemented /M()Y()N
[173.435) (verify only once per 1censee)
(4)
Written instructions included with exclusive use shipments (173.403]
()Y()N Basis for Findings:
14.
POSTING AND LABELI.NS A.
NRC form 3
- Notice to Workers" is posted (19.11]
()Y()N B.
Parts 19, 20, 21. Section 206 of Energy Reorganization Act, procedures adopted pursuant to Part 21. and license documents are posted or a notice indicating where documents can be examined is posted
[19.11,21.6]
()Y()N C.
Other posting and labeling per 20.1902 and 20.1904, respectively, and the licensee is not exempted by 20.1903 or 20.1905
()Y()N Basis for Findings:
87110. Appendix A A-20 Issue Date:
02/03/97
15.
GENERIC COMMUNICATION OF INFORMATIQN A.
Bulletins. Information notices. NMSS Newsletters.
i etc., received by the licensee
()Y()N B.
Licensee took appropriate action in response to bulletins. generic letters, etc.
()Y()N Basis for Findings:
/
16.
NOTIFICATION AND REPORTS A.
Licensee in compliance with 19.13. 30.50 (reports to individuals, public and occupational, monitored to show compliance with Part 20)
( ) N/A ( ) Y ( ) N B.
Licensee in compliance with 20.2201, 30.50 (theft or loss)
( ) None ( ) Y ( ) N C.
Licensee in compliance with 20.2202, 30.50 (incidents)
( ) None ( ) Y ( ) N D.
Licensee in compliance with 20.2203, 30=50 (overexposures and high radiation levels)
( ) None ( ) Y ( ) N E.
Licensee aware of NRC Ops Center phone number
()Y()N
[(301) 816-5100]
F.
Licensee in compliance with [20.2203]
( ) None ( ) Y ( ) N (constraint on air emmissions)
Basis for Findings:
17.
SPECIAL LICENSE CONDITIONS OR ISSUEj M
( ) N/A
~
A.
Special license conditions or issues to be reviewed:
B.
Evaluation:
C.
Issue Date:
02/03/97 A-21 87110. Appendix A
+
18.
OBSERVATIONS / DEMONSTRATIONS OF LICENSED ACTIVITIES Briefly describe the activitles and procedures observed and/or danonstrated during the inspection.
For exanple, if you observed licensee personnel working in radfation areas using 1icensed materla1 or performing functtons associated with radiation safety such as receiving or transporting licensed malertal: conductin disposing of radioactive waste:
conducting surveys;g or receiving training:
or making measurements, then describe what you saw.
If the licensee demonstrated any practices at your request, describe those dcmonstrations.
The observations and dmonstrations you describe here, and elsewhere in the ~ Basis for Findings" sections of this report, along with measurenents and sane records review, should substantiate your inspection findings.
Describe what activities or procedures were observed and/or demonstrated by the licensee during the inspection:
c.
87110. Appendix A A-22 Issue Date:
02/03/97
The following secttons should be cmpleted in a narrative format by the inspector to briefly describe the neasurements perfonned by the inspector.
inspect ton findings, and any post-inspection cmmunications with regional staff.
19.
NRC INSPECTOR'S MEASUREMENTS
( ) N/A A.
Survey instrument Serial No.
Date of calibration
/20 2 A of ti2r 5/>tl19 B.
Inspector performed CONFIRMATORY measurements (dY()N C
Inspector perforned INDEPENDENT measurements J/)Y()N 0.
Briefly describe the types of measurements Jerformed (i.e..
exposure rates, wipe tests, soil samples, air f' ow measurements, etc.)
locations where measurements were taken, the results of these measurements (mR/hr. dpm. etc.), and whether inspector's results conflicted with the licensee's measurements.
If independent measurements were not made, justify why they were not performed on this inspection:
/?rLe. / A<v q / /k irrub r [ '
f' 5).
4 20.
CQNTINUATION OF REPORT ITEMS
( ) N/A t
i Issue Date:
02/03/97 A-23 87110. Appendix A
1 21.
y10LATIONS NON CITED VJDLAT10t{$_(KV3). AND DIER ISSUES k)N/A NOTE: Briefly ctate (1) the requirement and (2) how and when the licensee violated the requirement.
For non cited violations (NCVs), indicate why the violation was not cited.
Attach copies of all licensee documents needed to support the violation.
22.
QE.BRIEF WITH REGIONAL STAFF A.
Was inspection feedback provided to regional licensing staff?
()Y()N If "Yes," name of individual on the licensing staff:
If "Yes," describe issues discussed:
B.
Briefly describe post-inspection communications with other regional staf f (inspector's supervisor, Agreement State officer.
State liaison officer, etc.):
c 87110, Appendix A A-24 Issue Date:
02/03/97
e I
23.
PERFORtBNCE EVALUATION FACTORS (PEFs)
A.
Lack of senior management involvement with the radiation safety program and/or Radiation Safety Officer (RS0) oversight
()Y()N B.
RSO too busy with other assignments
()Y()N C.
Insufficient staffing
()Y()N D.
Radiation Safety Committee fails to meet or functions inadequately
( ) N/A ( ) Y ( ) N E.
Inadequate consulting services or inadequate audits conducted
( ) N/A ( ) Y ( ) N Remarks (consider the above assessment and/or other pertinent PEFs with regard to the licensee's oversight of the radiation safety program):
Regional follow-up on above PEFs citations:
END Attachments:
A.
" Laboratory inspection Field Notes" 8.
" Decommissioning Timeliness inspection Field Notes" Issue Date:
02/03/97 A-25 87110. Appendix A
2 n_, _ _ _,
e i
AP_PB4 DIX A A'TACHMENT A LABORA10RY INSPECT ON FIELD NOTES 1.
Date Authorized User (s) 2.
Location (s) Building Room (s) 3.
Person (s) Contacted 4.
Describe scope of lab use (nuclides, form, frequency, purpose, etc):
5.
Training A.
Frequency:
Conducted by:
B.
Individuals interviewed understand safety practices
()Y()N Basi-er Findings:
6.
Surveys A.
Types of surveys performed (daily, weekly, monthly, etc.)
B.
Instrumentation properly calibrated and used
()Y()N C.
Efficiency of counting system (s) determined
()Y( )N D.
Hood airflow adequate and checked as required ( ) N/A ( ) Y ( ) N E.
Records maintained: trigger levels established, area diagram, instrument used, individual performing survey, results in proper units, decontamination performed as necessary, etc.
()Y()N F.
Inspector performed independent and/or confirmatory measurements
()Y()N Basis for findings:
Issue Date:
02/03/97 Att. A-1 87110. Appendix A. Att. A
~
7.
Receipt and Transfer A.
Incoming packages properly surveyed
()Y()N B.
Interlaboratory transfers performed as specified in the license
( ) N/A ( ) Y ( ) N C.
Records maintained
()Y()N Basis for Findings:
)
i 8.
Personnel Dosimetry A.
Appropriate dosimetry assigned and worn
( ) N/A ( ) Y ( ) N
-B.
Results available to lab personnel
()Y()N C.
Bioassays performed
( ) N/A ( ) Y ( ) N Basis for Findings:
i t
9.
Handling Waste A.
Procedures followed
(_) Y ( ) N B.-
Proper storage (area, containers, labeling, etc.)
()Y()N C.
Liquid / solid waste disposal
()Y()N D.
Incineration
( ) N/A ( ) Y ( ) N E.
Compaction
( ) N/A ( ) Y ( ) N F.
Sewer discharge
( ) N/A ( ) Y ( ) N G.
Records maintained
()Y()N Basis for Findings:
10.
Inventory
( ) N/A A.-
Inventory conducted
()Y()N B.
Records maintained
()Y()N Basis _for Findings:
87110. Appendix A. Att. A
_Att. A-2 Issue Date:
02/03/97
~. -
11.
Storage and use of licensed material A.
Adecuate method to prevent unauthorized access
()Y()N B.
Concition of areas acceptable
()Y()N C.
Personnel wear disposable gloves and protective clothing while handling material
()Y()N 0.
Personnel routinely monitor or frisk themselves after procedures or before leaving
()Y()N No food,g/ drinking / smoking in use/ storage areas E.
No eatin
()Y()N F.
drink, or personal itens stored in use/ storage areas
()Y()N G.
Use of shielding / distance while using/ storing material ( ) Y ( ) N H.
RAM is under surveillance and control (when not in storage) in an unrestricted area
()Y()N 1.
Proper dosimetry worn
()Y()N J.
Radioactive waste disposed of in proper containers
()Y()N K.
No pipetting by mouth
()Y()N Basis for findings:
12.
Posting and Labeling A.
NRC form 3 " Notice to Workers"
()Y()N B.
Parts 19, 20, 21. Section 206 of Energy Reorganization Act, procedures for Part 21. and license documents or a notice indicating where documents can be examined
()Y()N C.
Other posting and_ labeling requirements met
()Y()N Basis for Findings:
13.
Violations identified:
L l
c:
Issue Date:
02/03/97 Att. A-3 87110. Appendix A. Att. A
. = -.. - - -. -
APPDDR A ATTARMEt(LB DECOMMISSIONING TlHELINESS FIELD NOTES Licensee:
Date of Inspection:
1.
QMPU ANCE WITH QECOMMISSIONING_IlhELINESS RULE (NTil: Repeat the answers given in Section 12 of the main body of the field notes.
The issues in subsequent sections are dependent on the answers to these questions.)
A.
L1 cense to conduct a principle actfvity %
expired or been revoked
()Y()N B.
Licensee M made a decision to )ermanently cease principal activities, at t1e entire site, or any separate buildings, or any outdoor areas.
including inactive burial grounds
()Y()N C.
A 24. month duration has passed in which no prfncipal actiVf tfes. have been conducted under the license at the site, or at any separate buildings, or any outdoor areas. including inactive burial grounds
()Y()N 0.
If "Yes" to either A or B or C above:
(1)
Identify Site / Bldg / Area:
(2)
Octe of occurence of A. B. or C:
2.
NOTIFICATION REQURffilS A.
Licensee has provided written notification to NRC within 60 days of the occurrence of 1. A.,1.B.. or 1.C. above
()Y()N If "Yes." date of notification:
B.
If the licensee is requesting to delay initiation of the decommissioning process, the licensee hn provided written notification to NRC within 30 days of occurrence of 1.A., 1.B., or 1.C. above
( ) N/A ( ) Y ( ) N If "Yes." date of notification:
i Comments:
c l
l Issue Date:
02/03/97 Att. B-1 87110. Appendix A. Att. B l
3.
DECOMMISS10NING PL#f/ SCHEDULE REQUIREMENTS A.
Licensee is required to submit a decommissioning plan )er 10 CFR 30.36(g), 40.42(g), 70.38(g), or 10 Cf1 Part 727
()Y()N I
If "No" to 3.A., answer the following items B.
F.:
B.
The decomissioning work scope is covered by current license conditions
()Y()N C.
Decomissioning has been initiated within 60 days of notification to HRC, or NRC has granted a delay
()Y!)N D.
If licensee has initiated decomissioning, give date the decommissioning was initiated:
Initiation date:
E.
If decommissioning has been completed, it was completed within 24 months of notification to NRC
( ) N/A ( ) Y ( ) N F.
If decommissioning is still scheduled to be com)leted, it is on schedule to be completed witlin 24 mcnths of notification to NRC
( ) N/A ( ) Y ( ) N Comments:
If "Yes" to 3.A., answer the following items G. - J.:
G.
The decommissioning plan has been submitted to NRC within 12 months of notification
()Y()N If "Yes," date of submittal: _
If NRC approved, date of NRC approval:
11.
Has the licensee submitted an alternative schedule request?
()Y()N c
If "Yes," date of submittal:
87110. Appendir. A. Att. 8 Att B-2 Issue Date:
02/03/97
, ~.
~
v 4
1.
If decomissioning has been completed. It was completed within 24 months after approval of the decomissioning plan
( ) N/A ( ) Y ( ) N l'
If decomissioning is still scheduled to be completed. It is on schedule to be completed within 24 months after approval of the 3
decomissioning plan
( ) N/A ( ) Y ( ) N Coments:
Viol &tions tdendf M, li any:
l i
c l-I l
' Issue Date:
0.2/03/97 Att. B 3 87110. Appendix A. Att, B
_.,. _ _,....