ML20248J124

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-0398/98-01 on 980422.Informs That Addl Info Still Needed & Requests Submittal of Old & Corrected Procedures for Review

ML20248J124
Person / Time
Site:	07000398
Issue date:	05/29/1998
From:	Kinneman J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Pevey L NATIONAL INSTITUTE OF STANDARDS & TECHNOLOGY (FORMERL
References
70-0398-98-01, 70-398-98-1, NUDOCS 9806080407
Download: ML20248J124 (3)

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i May 29,1998 Docket No. 070-00398 License No. SNM-362 Lyman E. Pevey L

Chief, Occupational Health & Safety Division U.S. Departrnent of Commerce National Institute of Standards and Technology Building 301, Room B124 Gaithersburg, MD 20899-0001

SUBJECT:

INSPECTION NO. 070-00398/98-001

Dear Mr. Pevey:

This letter refers to your May 20,1998 correspondence, in response to our April 22,1998 letter.

l Thank you for informing us of the corrective and preventive actions documented in your letter.

However, your letter has been reviewed and additional information is still needed.

Regarding your corrective actions to Violation D ($36.53(b)) please submit a copy of your old

~ and conected new emergency procedures for our review.

With regard to Violation E ($36.37(c) and $36.67) you propose to, install an additional rad'lon monitor inside the entry door that will generate a visible and an audible signal if the door is opened and the radiation level is above normal background. Since $36.37(c) requires that

during a power failure, entry may be only when using an operable and c,alibrated radiation survey meter, NRC believes you must either seek an exemption to $36.37(c) as part of your corrective action or comply with the regulation as stated. You also did not provide information for correction of $36.37(c) as to how the additional radiation monitor would function during a power failure. Further, $36.67 requires that upon first entering the radiation room, the operator must use a survey meter which has been checked for function with a radiation check source prior to entry. Please provide information on how the additional radiation monitor inside the entry door will be checked for function with a radiation check source prior to entry. Please submit your clarified corrective action for Violation E.

We understand you are seeking exemobons to the regulations as an amendment to your license as correchve actions for the sections of Part 36 citsd in Violations A, B, C and the citation of 36.67 in Violation E. Please send Region I a copy of this amendment request in order that we may review the attematives you propose as corrective actions to the regulations as stated.

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9906090407 990529 PDR ADOCK 07000398 (

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OFFICIAL RECORD COPY i

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L Pevey 2 U.S. Department of Commerce Please submit to this office within seven (7) days of receipt of this letter a written statement containing the requested information.

Your cooperation with us is appreciated.

Sincerely, Original signed by Pamela J. Henderson John D. Kinneman, Chief Nuclear Materials Safety Branch 2 Division of Nuclear Materials Safety cc:

Thomas G. Hobbs, Radiation Safety Officer State of Maryland

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DOCUMENT NAME: G:ONMSOOCWORK\lNSPLTR\LSNM362 16189962 To receive o copy of thle document, bidicate in the boa: *C' = Copy w/o attach /enci *E' = Copy w/ sttach/enct *N* = No copy OFFICE DNMS/Rl [\ ,lN DNMS/RW lF l NAME JJohansenM d,41KinnemaV  :

DATE 05/26 S8 U ) 05698 05/ /98 05/ /98 OFFICIAL RECORD COPY l

• • UNITED STATE] DEPARTMENT OF COMMERCE i National Institute of Standards and Technology  !

Gaithersburg, Maryland 208990001 May 20,1998 \'w o'/ l l

I U. S. Nuclear Regulatory Commission License No. SNM-362 ATTN: Document Control P:sk Docket No. 070-00398 Washington, D. C. 20555 Inspection No. 070-00398/98-001 U. S. Nuclear Regulatory Commission -

Regional Administrator Region 1 475 Allendale Road King of Prussia, Pennsylvania 19406-1415

Subject:

Reply to a Notice of Violation Gentlemen:

As required, we are submitting this response to the notice of violation in your letter of April 22,1998 resulting from Inspection No. 070-00398/98-00. The violation was caused by a misconception that 10CFR Part 36 did not apply to the vertical beam sources controlled under license number SNM-362.

l In this response to citations for 10 CFR 36.37(c) and 36.53(b), we are revising and reposting the emergency procedures. This will be in place by May 22,1998. Also, an additional radiation monitor is being installed inside the entry door that will generate a visible and an audible signal if the door is opened AND a mdiation level above normal background exists. That installation should be completed

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by September 30,1998. Until it is operational, a portable survey meter will be used for the first I personnel entry into the radiation room following an irradiation.

In the case of 10 CFR Part 36, section 23 paragraphs (a), (b), (c),' and (d); section 27, paragraphs (a) and (b); section 31, paragraph (a); section 51, paragraphs (d), (e), and (g); and section 67, paragraph (a), we are requesting exemption to the regulations. We anticipate that the exemption request will be filed concurrently with this letter, 1

i If you have further questions about this matter, please contact Mr. T. Hobbs at 301-975-5800, Room Cl25, Bldg. 245.

Sincerely, I L. E. Pevey, Ch Occupational He and Safety Division (Materials License Manager)

MAY 2 31998 NLST L +8mww+