ML20206R808
| ML20206R808 | |
| Person / Time | |
|---|---|
| Site: | 07000971 |
| Issue date: | 06/13/1986 |
| From: | Little G Oregon State University, CORVALLIS, OR |
| To: | Thomas R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20206R782 | List: |
| References | |
| NUDOCS 8607070230 | |
| Download: ML20206R808 (5) | |
Text
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Safety Office University Corvams, Oregon 97331-6408
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June 13, 1986 U. S. Nuclear Regulatory Commission Region V 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596 Attention:
Mr. R. D. Thomas, Chief Nuclear Materials Safety Section Gentlemen:
Violation of 10CFR150.20 This letter is in response to your letter of May 28, 1986, identifying violation of terms of 10CFR150.20 as reported to you by this office on May 14, 1986.
Investigation shows that the violation consists of late notification to your office of our Intent to use a nuclear moisture gauge at a federal-Jurisdiction location. The cause of the violation was mishandling by our Radiation Safety Officer of written information received from the gauge user. The mishandling was discovered by the Radiation Safety Officer during normal review of records.
Remedial steps taken were immediate telephone notification of your office followed by proper written report of proposed use via NRC-241 form plus license copies.
Confirmation by your office of receipt of the written material has been received.
Preventive measures taken include:
1.
Written procedure for processing reciprocity approval requests has been prepared and distributed to each member of the Radiation Safety Office.
The procedure has been formally discussed with Office staff.
2.
Written specific provisions for moisture / density gauge use have been prepared which specify the presence of a copy of the NRC-241 form whenever a gauge is used or stored at a federal-Jurisdiction location.
Copy of the provisions is being distributed to each Program Director having such a gauge. The requirement of no work without a NRC-241 form present will he reiterated during future training sessions for gauge users.
8607070230 860627 P
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1 U. S. Nuclear Regulatory Commission June 13, 1986 Page 2 Radiation Safety Office procedure is complete and discussion has been held.
Written gauge use provisions are completed and distribution will be com-pleted by June 17 The cause of this violation is clear.
The preventive measures listed are adequate to prevent future recurrence.
Should you have questions or comments concerning this matter please contact me at the address and phone number above.
Sincerely, y qbst b
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u Gordon A. Little Radiation Safety Officer GAL:Jw Enclosure cc w/ enclosure:
Dr. T. D. Parsons, Vice President, OSU Dr. C. V. Smith, Director of Radiation Center, OSU Dr. J. Byrne, President, OSU 9
Oregon State University Specific Provisions for Soil Moisture / Density Gauge Radiation Use Authorizations
- 1. Whenever the device is in use, in transit, or not in its routine storage location it must:
- a. be under direct supervision of a person authorized by the RUA.
- b. when unattended, be secured in a locked compartment or in its container and chained to prevent theft, loss, or inadvertant close approach.
- c. be accompanied by the following documents:
- 1. Copy of the soil moisture gauge emergency procedures.
- 2. Copy of the normal operating procedures (usually manufacturer's manual)
- 3. Copy of the University's radioactive materials license plus validation.
- 4. Copy of the University-i'ssued Radiation Use Authorization for the device.
- 5. Copy of the completed NRC 241 form if federal-jurisdiction locations are involved.
- 6. Copy of the landowner's written permission if private land is involved.
- 7. Copy of Oregon Form X, " Notice To Employees".
- 8. Copy of form NRC-3, " Notice To Employees", if federal-jurisdiction locations are involved.
- 9. Up-to-date device log.
- 10. Generic DOT packaging-shipping form unless no travel will take place over non-0SU property. Note that this document must be kept in the vehicle's drivers door, on the seat, or otherwise within the driver's reach.
II. Use or storage at federal-jurisdiction locations requires a copy of the com-pleted NRC-241 form listing the specific locations, dates, personnel, and devices authorized. The form is valid only for the calendar year; renewal is not automatic.
III. Use or storage on privately owned land requires a copy of written permission from the land owner, with copy on file in the Radiation Safety Office.
IV. Transport requires preparation by the Radiation Safety Office of specific or generic DOT shipping. papers plus verification that packaging and lab-elling are in accordance with DOT regulations. The device must not be trans-ported in the vehicle driver's compartment; it must be secured at all times against theft, loss, or inadvertant near approach.
V. The device may not be destroyed, loaned, given away, or sent for repair without written permission of the Radiation Safety Office.
VI. Each device must be leak-tested upon acquisition, af ter being in storage, after each repair, after each accident which might cause harm to the sources, and each six months (normally May and November). Device supervisor must arrange for leak test results to be forwarded to the Radiation Safety Office.
VII. In event of suspected or known personnel exposure, device malfunction, or any accident follow the emergency procedures kept with the device.
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.A Processing of Reciprocity Requests Discussion Reciprocity is a simple means for obtaining approval for OSU personnel to use radioactive material or radiation producing machines at locations outside the Jurisdiction of the Oregon Radiation Control Section, which issues the radioactive materials license for the University. Reciprocity is limited to.
activities which would be permitted under terms of the University's license if performed at a location listed in the license.
Terms and conditions for obtaining reciprocity approval vary from regulatory
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agency to regulatory agency.
Those used for approval by the US NRC for work by Agreement State licensees at federa l-J uri sdict ion locations are given in 10CFRISO.20. Criteria used by other agencies rust be.obtained from the par-ticular agency.
In general, all use about the same criteria, but different fee structures.
Reciprocity work is limited to no more than 180 days in any calendar year.
Reciprocity approval takes time; thus timely, accurate processing of reci-procity requests is mandatory to insure approval before the activity is scheduled to begin.
The following procedure shall be used.
Procedure 1.
Reciprocity requests may be received by the Radiation Safety Office via written memo, telephone reques:, or face-to-face request.
Each request must be directed immediately to the Radiation Safety Officer, or in his absence, to the Specialist in Charge.
That Individual must, for each oral
. request, prepare a written memo containing all the pertinent information within one working day of receipt of the request.
Each written memo must be date-stamped when received or prepared.
2.
Within one working day of the date-stamp the RSO, or SIC, must review the request memo to determine if the requested activity is in accordance with a valid RUA, if reciprocity time is available, if there is sufficient time to obtain reciprocity approval before the scheduled start date, or if there is any other reason to deny reciprocity.
3 If the work is not authorized, there is Insufficient time, or for any other reason reciprocity cannot be obtained the RSO, or SIC, must contact the Project Director as soon as possible to explain the situation and determine the course of action to be taken, i.e.,
cancel the request, phone the agency having jurisdiction, obtain RUA amendment, etc.
4.
If reciprocity is feasible the RSO, or SIC, must obtain any additional Information, prepare an official request for reciprocity, and forward the request to the appropriate agency.
If there is a charge the request must be forwarded via the requesting group, who must arrange payment.
The formal request must be completed and out of the Radiation Safety Office within five working days of receipt of the necessary information 4
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Processing of Reciprocity Requests - Page 2 3
and forms needed to process the request. The RSO, or SIC, must inform the requesting group of the date when the activity may be started, and forward a copy of the request to that group.
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For reciprocity requests involving activities at federal-Jurisdiction locations the reciprocity request must be on NRC-241' form (copies are in the reciprocity file).
Original and three copies of the one page form, plus four copies of license ORE-0005-3 including validation, plus a cover letter must be sent to the NRC.
Address and samples of cover letters are in the Correspondence binder and in the reciprocity-NRC file, i
Copies of the NRC-241 form and the cover letter shall be placed in the j
Correspondence binder and reciprocity-NRC file. Copy of the NRC-241 j-form shall be routed to the using group.
4 6.
For reciprocity requests involving non-federal, non-Oregon locations contact the regulatory agency having jurisdiction via phone to determine i
format required, charges, mail address, and any additional information l
needed. Prepare formal letter of request and assemble any additional information wanted by the agency.
Then forward with copies to Corre-spondence and reciprocity files and the using group.
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