ML20247F240
| ML20247F240 | |
| Person / Time | |
|---|---|
| Site: | 07000398 |
| Issue date: | 04/22/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20247F231 | List: |
| References | |
| 70-0398-98-01, 70-398-98-1, NUDOCS 9805190230 | |
| Download: ML20247F240 (3) | |
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4 NOTICE OF VIOLATION U. S. Department of Commerce Docket No. 070-00398
. Gaithersburg, MD License No. SNM-362 l
l l During an NRC inspection conducted from March 23 to March 26,1998, five violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," (Enforcement Policy), NUREG-1600, the violations are listed below:
! A. 10 CFR 36.23(a) requires, in part, that each entrance to a radiation room at a panoramic l irradiator have a lock that is operated by the same key used to move the sources.
10 CFR 36.31(a) requires, in part, that the key used to actuate the source movement of a panoramic irradiator be attached to a portable radiation survey meter by chain or cable, that the lock for the source control be designed so that the key may not be removed if the sources are in an unshielded position and that the same key be the key to the door to the rad;& tion room.
10 CFR 36.23(b) requires, in part, that each entrance to the radiation room at a l panoramic irradiator have an independent backup access control that upon detection of entry retums the sources to the fully shielded position and activates a visible and audible alarm to make the individual entering the room aware of the hazard. The alarm must l also alert at least one other individual who is onsite of the entry. That individual shall be trained on how to respond to the alarm and be prepared to promptly render or summon assistance.
10 CFR 36.23(c) requires, in part, that an attempted entry into the irradiator while the radiation monitor measures high radiation levels must activate the alarm described in
$36.23(b).
10 CFR 36.23(d) requires, in part, that before the sources move from their shielded position, the source control must automatically activate conspicuous visible and audible l alarms to alert people in the radiation room that the sources will be moved from the
- shielded position.
Contrary to the above, as of March 24,1998, and since September 29,1995, for the panoramic irradiators in Building 245, Rooms B034 and B036, (1) the key to the radiation room was not the same key used to move the sources and was not attached to a portable radiation survey meter; (2) the independent backup access control did not activate a visible and audible alarm to alert at least one other ' response trained" individual who is onsite of the entry, (3) attempted entry when the monitor measures high radiation levels did not activate the required alarms; and, (4) the source control did not automatically activate a conspicuous visible alarm to alert people in the radiation room that the sources will be moved from the shielded position.
This is a Severity Level IV violation (Supplement VI).
9905190230 990422 PDR ADOCK 07000398 C PDR l
Notice of Violation 2 U. S. Department of Commerce B. 10 CFR 36.27(a) and (b) require, in part, that the radiation room at a panoramic irradiator have heat and smoke detectors that alarm and automatically fully shield the sources if a fire is detected and have a fire extinguishing system capable of extinguishing a fire without the entry of personnel into the room. The extinguishing system must have a shut-off valve to control flooding into unrestricted areas.
Contrary to the above, as of March 24,1998, and since September 29,1995, for the panoramic irradiators in Building 245, Rooms B034 and B036, the radiation rooms had only smoke detectors, the alarm from the detectors did not cause the irradiator to l automatically fully shield the sources and the rooms were not equipped with a fire extinguishing system.
This is a Seventy Level IV violation (Supplement VI).
C. 10 CFR 36.51(d) requires that the licensee conduct safety reviews for irradiator operators at least annually, that a brief written test be given on the information presented l and that the safety review include specific subjects and a drill to practice an emergency j or abnormal event procedure.
10 CFR 36.51(e) requires, in part, that the licensee evaluate the safety performance of each irradiator operator at least annually to ensure that regulations, license conditions, and operating and emergency procedures are followed 10 CFR 36.51(g) requires, in part, that individuals who must be prepared to respond to alarms required by $36.23(b) and 936.27(a) be retested at least once per year.
Contrary to the above, as of March 24,1998, and since September 29,1995, for the panoramic irradiators in Building 245, Rooms B034 and B036, safety reviews and evaluations for irradiator operators were not performed and individuals who must be prepared to respond to alarms were not retested.
This is a Seventy Level IV violation (Supplement VI).
D. 10 CFR 36.53(b) requires, in part, that the licensee have and follow written emergency or abnormal event procedures appropriate for the irradiator type for a number of events including an alarm indicating unauthorized entry into the radiation room.
Contrary to the above, as of March 24,1998, and since September 29,1995, for the panoramic irradiators in Building 245, Rooms B034 and B036, the licensee's emergency procedures did not cover an alarm indicating unauthorized entry into the radiation room.
This is a Seventy Level IV violation (Supplement VI).
E. 10 CFR 36.67 requires that upon first entering the radiation room of a panoramic irradiator after an irradiation, the operator must use a survey meter, which has been checked for function with a radiation check source prior to entry, to determine that the source has retumed to the fully shielded position.
Notice of Violation 3 U. S. Department of Commerce 10 CFR 36.37(c) requires that during a power failure, the area of any panoramic irradiator where sources are located may be entered only when using an operable and calibrated radiation survey meter.
Contrary to the above, as of March 24,1998, the licensee did not require that radiation rooms of the panoramic irradiators in Building 245, Rooms B034 and B036, be entered only when using an operable and calibrated radiation survey meter upon first entering the radiation room after irradiation nor during a power failure.
This is a Severity Level IV violation (Supplement VI).
Pursuant to the provisions of 10 CFR 2.201, the U.S. Department of Commerce is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555, with a copy to the Regional Administrator, Region I, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response.
If an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Whare good cause is shown, consideration will be given to extending the response time.
If you contest this enforcement action, you should also provide a copy of your response to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001. Under the authority of Section 182 of the Act,42 U.S.C. 2232, any response contesting a violation shall be submitted under oath or affirmation.
Your response will be placed in the NRC Public Document Room (PDR); therefore, to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. However, if you find it necessary to include such information, you should clearly indicate the specific information that you desire not to be placed in the PDR, and provide the legal basis to support your request for withholding the information from the public.
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