ML20209C682
| ML20209C682 | |
| Person / Time | |
|---|---|
| Site: | 07001207 |
| Issue date: | 02/13/1987 |
| From: | Anderson C NAVY, DEPT. OF |
| To: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20209C661 | List: |
| References | |
| 6470, NUDOCS 8704290049 | |
| Download: ML20209C682 (3) | |
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9 DEPARTMENT OF THE NAVY "L',L R
' NAVAL SURFACE WEAPONS CENTER DAHLGREN, VIRGINIA 22448 5000 r
3 N RERY RERR TO 6470 1
t X30-GJC 13 Feb 1987 I
From:
Commander, Naval Surface Weapons Contor i
To:
Director, United States Nuclear Regulatory Commission j
Region I, King of Prussia, PA 19406 1
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Subj:
RESPONSE TO NRC INSPECTION 86-01 REPORT Reft (a) NRC Inspection 86-01 Report of 17 Dec 86 j
(b) NSWC ltr X30-RTW of 23 Dec 86 1.
The Naval Surface Weapons Center (NSWC) received the Nuclear 1
Regulatory Commission report, reference (a), on 23 December 1986.
1 Due to our end of the year closing, a request for an extension of
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the deadline (reference (b)) was initiated on the same day.
On 7 January 1987, a member of our Health Physics staff contacted the j
Region I Inspection Office and was given a verbal approval of the 1
above letter.
2.
The following is a response to reference (a), Appendix A.
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FINDING A Condition 11 of License No. SNM-ll47 requires that refresher training in radiation protection be provided annually to each individual using radioactive materials and l
that the training be appropriate to the type of licensed material used and for the individuals using the materials.
Contrary to the above, as of 13 August 1986, refresher training had not been provided to individuals using licensed i
material during the calendar year 1985 or to date in 1986.
NSWC RESPONSE:
NSWC does not concur with this finding.
A total of five sessions of the required refresher training were given in 1985; a total of nine sessions were given in l
l 1986.
Records of this training are available for review.
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FINDING B(1)):
Condition 9 of Licenso SNM-ll47 requires that licensed material be possessed and used in accordance with the statements, representations, and procedures con-l tained in an application dated 18 March 1981.
Page 5 of this application, entitled " Administration and Organization," requires that the Radiation Safety Committee meet semiannually; and section C of the Radiation Safety Manual included with this application requires that records 1
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of Committee actions be maintained, a
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Subj:
RESPONSE TO NRC INSPECTION 86-01 REPORT Contrary to the above, ac of 13 August 1986, the Radiation Safety Committee did not meet semiannually.
Specifically,
'the Radiation Safety Committee met only once during calendar years 1984 and 1985.
NSWC RESPONSE:
NSWC does not concur with the above find-ing.
The Radiation Safety Committee met twice in 1985 and four times in calendar year 1986.
The minutes of these meetings are on file.
Although two meetings were held in 1984, minutes for only one are available for review.
FINDING B(2):
Page 8, Item L of this application requires that physical inventories of all sealed sources be conducted quarterly and utilization logo be maintained.
Contrary to the above, as of 13 August 1986, quarterly inventories were not conducted.
Specifically, during 1984 and 1986 one inventory was conducted; during 1985 no inventory was conducted.
NSWC RESPONSE:
NSNC concurs with this finding.
During the years 1984, 1985, and 1986 two inventories per year were conducted.
The records of the inventories are on file.
Quarterly inventories are scheduled for calendar year 1987.
FINDING B(3):
Page 17, Item E of the attachment to this application entitled _" Leak Testing Procedures," requires that leak tests be conducted quarterly.
Contrary to the above, as of 13 August 1986, leak tests were not conducted quarterly.
Specifically, during 1984 and 1985 leak tests were conducted biannually and in 1986 leak tests were corducted once in July.
NSWC RESPONSE:
NSWC concurs with the above finding.
After a review of our facilities, sources, and future plans, the Radiation Safety Committee approved a plan to have radiation supervisors perform leak tests quarterly until such time that the licenses can be amended to permit biannual leak tests.
Records will be maintained for review.
FINDING B(4):
The Radiological Safety Manual attached to this application on page 20, in Section R, entitled
" Radiation Survey Procedures," require that laboratory surveys be conducted on a frequency ranging from one week to one month dependent upon the use and amount of materials used.
Contrary to the above, as of 13 August 1986, laboratory surveys were not conducted on a weekly or
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RESPONSE TO NRC INSPECTION 86-01 REPORT monthly basis.
Specifically, during 1985 and 1986, some active laboratories were surveyed only once.
NSWC RESPONSE:
NSWC concurs with this finding.
A plan was presented by llealth Physics to the Radiation Safety Committee at the December 1986 meeting in which the radiation super-visors will be tasked with the conduct of these surveys, while the IIealth Physicists will continue to conduct periodic and spot inspections.
A proposal to reduce the number of surveys will be made a part of our next licence revision request.
This is now anticipated to be prepared and sent in the second quarter of calendar year 1987.
3.
In general, the NSWC position is that violations can be placed into two groups:
- a. Administrative:
As a result of your inspection, we revised our record keeping / filing system so that information retrieval can be done in a timely manner.
Inclusion of these records as part of a new computerized safety progran should be completed by September 1987, b.
Staffing:
At present Safety and flealth personnel are being utilized to accomplish many routine tasks, i.e., badging program, which allows our llealth Physicists to concentrate on priority items related to our license and safety requirements.
Also, a high grade !!calth Physicist who has been on a long term assignment will be returning during July 1987.
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