ML20215L093
| ML20215L093 | |
| Person / Time | |
|---|---|
| Site: | 07000025 |
| Issue date: | 08/28/1986 |
| From: | Remley M ROCKBESTOS CO. |
| To: | Jonathan Montgomery NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20215L072 | List: |
| References | |
| 86RC11042, NUDOCS 8610280465 | |
| Download: ML20215L093 (3) | |
Text
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ROCKETDYN CNPK August 28, 1986 In reply refer to 86RC11042 Mr. James L. Montgomery Chief, Nuclear Materials Safety and Safeguards Branch U.S. Nuclear Regulatory Commission Region V 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596
Subject:
Inspection at Atomics International
Dear Mr. Montgomery:
This letter is in response to the Notice of Violation attached as Appendix A to the report of the routine unannounced safety inspection performed by B. L. Brock and J. F. Pang, July 7-10, 1986. This letter seeks to clarify our understanding of the items of violation and pre-sents the corrective steps taken and results achieved; the corrective steps which will be taken to avoid further items of noncompliance; and the dates when full compliance will be achieved.
Item A.l.
Refresher Training The section referenced in the Notice of Violation, Section 11.6.4 of gI ESG-82-33, perhaps 11.6, subitem 5 (?), is not in Part I, License Con-
/p ditions, but rather is in Part II, Safety Demonstration. The correct
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reference in Part I is Section 2.6, which requires that refresher training be given every 2 years.
The particular individual involved in this item of noncompliance had missed the normal refresher training due to very irregular assignments as a radiation worker.
In response to the discovery by the inspector of this deficiency, he was given refresher training on July 17, 1986.
The current list of radiation workers, and their training status, is being reviewed to determine if there are any other individuals requir-ing refresher training. This review, and any identified supplemental training needed, will be completed by September 3, 1986.
SM 22nu 8%8jir C
86RC11042 August 28, 1986 Rockwell Page 2 International Item A.2.
Survey Records This item also incorrectly references a section from Part II, Safety Demonstration. The referenced section (13.5.1 of ESG-82-33) indicates that the normal frequency for surveys is once per week, but goes on to state that additional surveys are performed if excessive contamination is indicated, and that surveys are performed less of ten where experi-ence indicates little contamination potential; the minimum frequency for surveys is stated as once per month. Considering the signifi-cantly reduced amount of work performed at the RIHL during the time period cited, we feel that the reduced survey effort was entirely appropriate.
Part I, License Conditions, includes no specific requirement on the frequency of documented surveys; only that the requirement for com-pleting them, reporting and evaluating the results is included. See
-r it..,tions 2.10 and 3.2.4.6 of Part I.
Sec
,b"> ~" *[ We do not believe that this item of noncompliance is justified.
We
,Ah" gy;;':y ed"' believe that our performance has been and will continue to be in com-pliance with the License.
WH~
Item B.
Documentation of Determination of Assigned Radiation Dose This item references 10 CFR 20.201(b), which requires the licensee to make surveys. Section 10 CFR 20.201(a) defines survey as "an evalua-tion of the radiation hazards incident to the production, use, release, disposal, or presence of radioactive materials or other sources of radiation under a specific set of conditions." We believe that this definition is consistent with the general understanding and use of the term " survey" and does not apply to the determination of a retrospec-tive dose to be assigned to an individual in the event of a lost or damaged film badge.
This interpretation is supported by the referenced Section 10 CFR 20.401(b), which clearly refers to measurements of radiation fields, surface contamination, and quantities of radiation.
While we believe that this is not an item of noncompliance, we appre-ciate the inspector's position regarding the desirability of docu-mentation of evaluations to estimate radiation exposure doses of
e 86RC11042 August 28, 1986 Rockwell Page 3 International individuals who have lost or missing film badges. This practice is being implemented immediately in our activities.
Sincerely y M. E. Remley, Dir c tor Nuclear Safety &
- ensing Rocketdyne Division 7594A/slw 05943RC