ML20199B632
| ML20199B632 | |
| Person / Time | |
|---|---|
| Site: | University of Missouri-Columbia |
| Issue date: | 01/23/1998 |
| From: | Charlson E, Deutsch E, Mckibben J MISSOURI, UNIV. OF, COLUMBIA, MO |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-186-97-201, NUDOCS 9801280340 | |
| Download: ML20199B632 (3) | |
Text
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Research Reactor Center Reaca"* Pa'k Columisis, MO 6531i University of Mieseneri-Columble ruost. (573) 882-42 t l nu($73)882 344)
Jamiuary 23,1998 t
US Nuclear Regulatory Commissien A'ITN: Document C(.atrol Desk Washington,DC 20555
REFERENCE:
Docket No. 50-180 The Curators of the University of Missouri Licenn No. R 103
SUBJECT:
" Reply to a Notico of Violation"in Accordance with 10 CFR 2.201
Dear Sir:
%is is a written statement required by 10 CFR 2.201 in response to the December 11,1997 US NRC Notice of Violation (NHC Inspection Report No. 5018G/97201 (DRpM)) concerning events at the University of Missouri Research Reactor (MURR).
l During an NRC inspection conducted from November 3 7,1997, two Severity Level IV violations were identified requiring a written response. Each violation is quoted below from the Notice of Violation followed by the University of Missouri response to the four questions.
Violation 601969720101 states:
The Code of Federal Regulations, Title 10, Part 20, Section 1902(e) requires that areas shall be posted with a conspicuous sign bearing the radintion symbol and the words
- CAUTION, RADIDACTIVE MATERIA 148)* or " DANGER, RADIOACTIVE MATERIA 1/S)" when they are used to store quantities oflicensed radioactive material that exceed ten times the amount of such material specified in Appendix C of that Part.
Contrary to the above, the licensee stored a Plutonium 239 calibration source with a quantity 157 times that spacified in Appadix C in an unposted room.
Heply 1.' ~ heason for the violation or basis for disputing the violation.
The calibration source in question is an electroplated metal disc source containing 0.16 pCi of Pu 239.
O This activity is 15.7 times the limits as specified in 10 CFR 20.1902(e) and should have been stored in a posted area. This source was identified previously as containing activity levels which require storage in a posted area and an appropriate location had been identified. Discussions with personnel who use the source could not identify when the storage location was changed to the non posted area.
/
.The fact that a numbu of similar calibration sources that did not require posting were used in the same area could have contributed to changing the storage location inappropriately.
- 2. Corrective steps that have been taken and results achieved.
Following the discovery of the improperly stored calibration source, the area was posted immediately with a sign that included the radiation symbol and the words " CAUTION, RADIOACTIVE MATERIAL,"
meeting the requirements of 10 CFR 20.1902(e). A second area where the source is used but not stored
- was posted similarly.
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US Nuclear Regul: tory C:mmission January 23,1998 Page 2 A llealth Physics Standard Operating Procedure was in place to provide guidance to personnel who perform internal audits of the use of radioactive materie.1 at MURR. Personnel who perform these audits have been retrained on the procedure, emphasizing the requirements of 10 CFR 20.1902(e) and Appendix C of that Part.
The calibration source was scored in an unposted area. It contains a very small amount of radioactivity. The potential health risk to radiation workers and members of the general public was very low. Access is controlled in the MURH facility and untrained persons did not have unescorted access to the unposted area in question.
- 3. Correct.ive steps that will be taken to avoid further violations.
The increased awareness of personnel to the requirements of 10 CFR 201902(e) and Appendix C of that Part sFould prevent improper storage of calibration sources and will be refreshed in annual training.
- 4. Date when full compilance will be achieved.
MURR was placed in full compliance with Federal Regulations concerning storage of sources on the same day the problem was identified. The storage area was posted on that day.
Violation 501869720102 states:
Technical Specifications 0.1(b) require that written procedures shall be in effect for shipping byproduct material produced under the reactor license.
MURR Policy and Procedures Manual,04:050," Shipping and Receiving Radioactive Materials,"
Rev 4,15,1995, Characterization / Documentation, states that " Internal procedures shall ensure that the proper shipping classification, packaging, shipping papers, marking, labeling, and placarding are identified and maintained as the preparation for shipping proceeds."
Contrary to the ab'
.s. procedares to ensure proper packaging of the sample were not in effect on April 10,1997, when a 4 millicurie vial of Selenium (So.75) was being prepared for shipping.
Reply 1.
Reason for the violation or basis for disputing the violation.
On April 10,1997 a package labeled as containing 4 mci of Se-75 was shipped to a researcher at Kitasato University, Tokyo, Japan. On April 20,1997 we were informed by the researcher that his shipment arrived with no radioactive materialin the package. Two Se 75 shipments were made on April 10,1997. The second package arrived at IInhn.Meitner Institute in Germany with no problems.
Immediate follow up action by MURR staff dctermined that the radioactive sample was still inside a smsll lead pig used to transfer the sample between the processing facility in laboratory 213 and laboratory 242 where the Capintech was used to quantify the activity. The specific cause of the error was the failure of the technician to transfer the sample from the transfer pig to the shipping pis. The technician labeled both shipping pigs, inspected both sets oflabels and paperwork for accuracy and delivered the pigs to be packaged for shipping.
While the shipping procedere required double verification of critical eteps in assembling the package, the processing procedure used to prepare this sample for shipment did not require a double verification step that the sample was in the labeled shipping pig before it was turned over to the shipping group. The root cause was determined to be lack of double verification in the processing procedure.
US Nuclear Regal: tory C:mmission January 23,1998-Page 3 2.
C)rrective steps that have been taken and results achieved.
The So 75 processing procedure has been revised to two separate procedures which e.aphasize critical steps where double verification is required to ensure that the sample is identified properly and tracked. The first procedure covers opening the irradiation vial, dissolving the selenium target, and dividing the sample into storage vials. The second procedure covers preparing sample shipping vials from the storage vials and loading them in a labeled shipping pig.
These procedures incorporate double verification of critical steps. Two forms of double verification are used: independent verificat. ion and concurrent veriGention. Independent verification normally is separated by distance and time to insulate the verifier from the worker's performance and/or influence. Concurrent verification requires a worker an:1 a verifier to observe an action or step independently, and agree that it me(ts the established criteria. The 6teps are identified clearly as either independent verification or concurrent vn. ention.
Additionally a sample tracking standard has been developed to identify critical process steps requiring double verification. This standard has been applied to all active processing procedures.
The standard also includes precise definitions of what is expected of the verifier.
While the empty package was shipped to the researcher in Japan, the sample stayed in a shielded pig in a properly posted and controlled laboratory. There was no hazard to the general public, the recipient, or the hf URR stafi'.
3.
Corrective steps that will be taken to avoid further violations.
The University has requested a revision to Technical Specification 6.1.b. This request is to make explicit the requiremet.t for procedures used for preparation of byproduct material for shipping and their approval by the IIenith Physics manager. These procedures include the Se-75 procedures.
To prevent further occurrences of a similar nature, the sample tracking staralard will be used in the review and approval of all preparation / processing procedures developed in the future.
4.
Date when full compliance will be achieved.
Procedures are now in place to ensure the proper packaging of radioactive materials and being in compliance with Federal Regulations.
Sincerely, Reviewed and Approved:
Y-kQ(
llV 2 kW
- i J. Charles hicKibben Dr. E/. ward A. Deutsch Dr. Elaine hl. Charlson Associate Director, h1URR Director, h1URR Associate Provost, MU cc:
Mr, Tom Durdick, NRC Region Ill M
Mr. Alexander Adams, Jr, USNRC CHRISTINE M. FRRANTE Reactor Advisory Committee Notary Public N&y Seal Reactor Safety Subcommittee STATE OF M2 3Cm Boone Cn m My Cemmission B '- -
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