ML20215L069

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp on 860707-10.Clarification Re Refresher Training,Survey Records & Documentation of Determination of Assigned Radiation Dose Provided

ML20215L069
Person / Time
Site:	07000025
Issue date:	10/24/1986
From:	Jonathan Montgomery NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Sanchini D ROCKBESTOS CO.
Shared Package
ML20215L072	List: ML20215L069 ML20215L093
References
NUDOCS 8610280453
Download: ML20215L069 (2)

Text

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OCT 241986 ._ .

Docket No. 70-25 Rockwell International Corporation Rocketdyne Division Atomic International 6633 Canoga Avenue Canoga Park, California 91304 Attention: Mr. D. J. Sanchini, Vice President Atomics International 3 Gentlemen:

Subject:

Licensee's Response to the Notice of Violation dated July 31, 1986 This will acknowledge the receipt of Dr. M. E. Remley's letter dated August 28, 1986 which was in response to our Notice of Violation dated July 31, 1986.

We have reviewed the comments relative to the items of noncompliance and have prepared the following clarifications for your information:

(1) Item A.1. Refresher Training Section 2.6 of Part I requires retraining of certain employees at

" appropriate intervals" to assure continued safe practices. Section 11.6(5) of Part II apparently defines the " appropriate interval" as a 2 year interval. This is our understanding based upon the license condition stated in Section 2.6. Apparently this is your understanding also since you stated in your letter that, "the correct reference in Part I is Section 2.6 which requires that refresher training be given every 2 years." In our opinion the violation is valid.

(2) Item A.2. Survey Records Apparently there was a misunderstanding on the inspector's part as to the enforceability of the Part II sections. Section 2.10 of Part I would be more appropriate for the basis of the violation. Your discussion of the reduced frequency of surveys is well taken; however, the basis for the violation is the lack of records of surveys conducted and is independent of the frequency of the surveys. The requirement of 10 CFR 20.201(b)(2) is directly applicable to your situation of reduced suaveys. Also, 10 CFR 20.401(b) requires records be maintained of surveys conducted pursuant to 20.201(b), regardless of the frequency of the surveys. In our opinion the violation is valid.

(3) Item B. Documentation of Determination of Assigned Radiation Dose ,

a 8610280453 861024 DR ADOCK 07000025 PDR e'h I l

OCT 241986 The reference to 10 CFR 20.201(b) is correct. The emphasis is placed on the word evaluation in 20.201(a). The word evaluation infers the actions taken by the licensee to comply with the regulations. Also, 10 CFR 20.401(b) requires that records shall be maintained of results of surveys (evaluations) required by 20.201(b). A copy of IE Information Notice No. 86-41 is enclosed for your information. The guidance given in this Information Notice would be applicable also to special nuclear material (SNM) licensees. In our opinion the violation is valid as stated.

Pursuant to the provisions of 10 CFR 2.201, Atomics International is hereby required to submit to this office within twenty days of the date of,this letter, a written statement or explanation in reply to item A.2. of the July 31, 1986 Notice of Violation, (also see item (2) A.2. above) including: (1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further items of noncompliance; and (3) the date when full compliance will be achieved.

If you have any further questions, we would be glad to discuss them with you.

Sincerely, James L. Montgomery, Chief Nuclear Materials Safety and Safeguards Branch cc w/ copy of letter dated 8/28/86:

Dr. M. E. Remley, Director Nuclear Safety and Licensing bcc w/ copy of letter dated 8/28/86:

RSB/ Document Control Desk (RIDS)

State of CA B. Faulkenberry J. Martin Joan Zollicoffer Region V R t JMontgomery 10g3/86 10/13/86

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SSINS No.: 6835 IN 86-41 UNITED STATES ,

NUCLEAR REGULATORY COMMISSION .

OFFICE OF INSPECTION AND ENFORCEMENT WASHINGTON, D.C. 20555 ,

June 9, 1986 IE INFORMATION NOTICE NO. 86-41: EVALUATION OF QUESTIONABLE EXPOSURE READINGS OF LICENSEE PERSONNEL DOSIMETERS Addressees:

All byproduct material licensees.

Purpose:

This notice is (1) to alert licensees of cases reported to the NRC where questionable exposure readings have been recorded for personnel dosimetry devices used by licer:see personnel and (2) to provide recipients with information on evaluation methodology used by some licensees to evaluate and report such readings.

It is expected that recipients will review this notice for applicability to their facilities. Itowever, suggestions contained in this information notice do not constitute NRC requirements; therefore, no specific action or written response is required.

Description of Circumstances:

The NRC has encountered a number of cases in which byproduct material licensees have received TLD or film badge reports showing a questionable high-exposure reading. Licensees' evaluations found such readings to be erroneous since the exposure purportedly was recorded on the dosimeter while it was not being worn by the individual. The majority of these cases have involved dosimeters that were inadvertently left in high-radiation areas or left for long periolis of time near byproduct material storage containers. Notwithstanding the requirements for proper use of personnel dosimeters, many licensees do not know how these cases should be evaluated and reported to NRC.

Discussion:

Surveys are necessary to evaluate questionable exposure readings on licensee personnel dosimeters. Improper evaluation of such readings may lead to a citation for violation of an NRC requirement and possible enforcement action.

Byproduct material licensees should be aware of their responsibilities with respect to 10 CFR Part 20.101, which requires that licensees control radiation exposure to individuals so that no individual receives an exposure in excess

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of the radiation dose standards. 10 CFR 20.201 requires that licensees make or cause to be made such surveys as may be necessary for the licensee to comply with the radiation dose standards specified in 10 CFR 20.101 and that the surveys are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present. As used in the regulations, " survey" means an g h{p ^

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.- j IN 86-41  !

June 9, 1986  !

Page 2 of 2 C..

l evaluation of the radiation hazards incident to the production, use, release, disposal, or presence of radiation under a specific set of conditions. In some cases, the evaluation may be supported by a physical survey. 10 CFR 20l401 requires each licensee to maintain records showing the results of surveys required by 10 CFR 20.201.

The information that has been documented by some licensees that meets NRC's requirements for a reasonable evaluation of questionable exposure readings is as follows:

Signed and dated statements from individuals present at the time of the possible false exposure, including helpers or witnesses. Such statements have been written by the individuals independently and have included all pertinent information known by them.

Documentation of the Radiation Safety Officer's evaluation and conclusions,,

including results of interviews of personnel involved, records of telephonse conversations, examination of equipment (when applicable), surveys, and corrective action to prevent recurrence.

Estimation of the actual exposure by measurement, calculation, or other appropriate methods.

In addition to the above, reviews of existing documentation have been made to ensure that records are complete and up to date. Such documents include utili-zation logs, dosimeter logs, exposure files, equipment maintenance checks, cali-brations, and training.

If a Radiation Safety Officer's evaluation of a high TLD or film badge reading cannot conclusively prove that the reading was erroneous, a report is made to the NRC in accordance with 10 CFR 20.403 or 20.405.

. No written response to this information notice is required. If you have any questions regarding this matter, please contact the Regional Administrator of the appropriate NRC regional office or this office.

James G. Partlow, Director Division of Inspection Programs Office of Inspection and Enforcement Technical

Contact:

H. Karagiannis, IE (301) 492-9655

Attachment:

List of Recently Issued IE Information Notices l

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