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{{Adams | |||
| number = ML061570264 | |||
| issue date = 05/24/2006 | |||
| title = Texas Engineering Experiment Station, Reply to Notice of Violation EA-06-113, NRC Special Inspection Report 50-128-06-203 | |||
| author name = Reece W | |||
| author affiliation = Texas A&M Univ | |||
| addressee name = | |||
| addressee affiliation = NRC/Document Control Desk, NRC/RGN-IV | |||
| docket = 05000128 | |||
| license number = R-083 | |||
| contact person = | |||
| case reference number = 2006-0036, EA-06-113, IR-06-203 | |||
| document type = Letter, Licensee Response to Notice of Violation | |||
| page count = 3 | |||
}} | |||
See also: [[see also::IR 05000128/2006203]] | |||
=Text= | |||
{{#Wiki_filter:TEXAS ENGINEERING | |||
EXPERIMENT | |||
STATION TEXAS A&M UNIVERSITY | |||
3575 TAMU COLLEGE STATION, TEXAS 77843-3575 | |||
NUCLEAR SCIENCE CENTER 979/845-7551 | |||
FAX 979/862-2667 | |||
May 24, 2006 2006-0036 U. S. Nuclear Regulatory | |||
Commission | |||
ATFrNPDb-cumentfrntiolVDek | |||
i Washington | |||
D.C 20555-0001 | |||
SUBJECT: Reply to a Notice of Violation; | |||
EA-06-113 NRC Special Inspection | |||
Report # 50-128/2006-203, Facility License R-83.This letter is the required response to the violation | |||
cited during the Special Nuclear Regulatory | |||
Commission (NRC) inspection | |||
on March 27-29, 2006 at the Texas A&M University | |||
Nuclear Science Center Research Reactor facility. | |||
We appreciate | |||
the detailed report and hope that our prompt corrective | |||
actions with respect to the cited violation | |||
are acceptable. | |||
Each item addressed | |||
in the Commission's | |||
report is addressed | |||
below including: | |||
1) reason for the violation, or if contested, the basis for disputing | |||
the violation | |||
or severity level, 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.1. Violation- | |||
Severity Level IV a. Licensee failed to make reasonable | |||
surveys to evaluate the magnitude and extent of shallow dose equivalent | |||
radiation | |||
levels following | |||
the initial trial runs 'of vials containing | |||
plastic disks and following | |||
the first indication | |||
of a possible overexposure | |||
of February 24, 06.SIa. Reason: Trial-runso | |||
of vials containing | |||
plastic disks were performed | |||
on several occasionsirath'e | |||
year 2005. lThe experimental | |||
protocol was correctly | |||
followed and the employee's | |||
m6nthly Shallow Dose Equivalent (SDE) was carefully monitored. | |||
The experiments | |||
were performed | |||
by another employee in the year 2005. The SDE noted for this type of work by NSC employees | |||
was minimal.Another employee performed | |||
the above type of work in the year 2006 following RESEARCH AND DEVELOPMENT | |||
FOR MANKIND http://nsc.tamu.edu | |||
Thci | |||
#1 the training from the previous employee. | |||
This employee's | |||
handling practices | |||
must have differed from previous workers.We do not contest the violation. | |||
lb. Corrective | |||
step that have been taken: Nuclear Science Center (NSC) has taken various corrective | |||
actions to improve the radiation | |||
protection | |||
program.o The employee is restricted | |||
from all radiation | |||
duties and classified | |||
as "non-radiation" worker during calendar year 2006 and his dosimetry | |||
was cancelled. | |||
o The employee has undergone | |||
a medical examination | |||
and a follow up check with laboratory | |||
work and the results indicate "no abnormalities". | |||
o We have built holders and manipulators | |||
that will eliminate | |||
beta dose for this type of Neutron Activation | |||
Analysis (NAA) work.o We--haveaconducteNSCPne--uniati--cifiAed | |||
personnel with emphasis on handling beta sources with the use of tools, tongs and beta shields.o We have conducted | |||
general training for all radiation | |||
workers on safe handling of compact sources.o We have developed | |||
step by step handling procedures | |||
for pneumatics (NAA) work. This is incorporated | |||
in the Pneumatics | |||
training module and also posted on the pneumatics | |||
hood.o NSC Radiation | |||
Work Permit is revised and notes the use of handling tools and shielding | |||
during pneumatics | |||
work.o We have implemented | |||
two extremity | |||
badges for NAA workers. The badge processing | |||
period is still monthly (as per Texas A&M contract). | |||
o NSC has evaluated | |||
the current NAA worker's dose report for the month of April following | |||
the implementation | |||
of new handling procedures, handling tools, etc, and noted that the SDE was "M".o Based on the above consideration, NSC believes that monthly dose reporting | |||
is adequate for the purposes of compliance. | |||
o We have ordered a radiation | |||
detector (indicating | |||
both beta and gamma)that will be permanently | |||
mounted inside the pneumatic | |||
hood so that NAA workers will be able to note any unusually | |||
high radiation | |||
levels.o NSC has purchased | |||
a dedicated | |||
potable beta sliding window ion chamber for the purposes of noting contact beta doses.o The dosimetry | |||
vendor was requested | |||
to include two NSC contact points in case the first person on the list cannot be notified to minimize any time delay in overexposure | |||
notification. | |||
Fax and e-mail notification | |||
was also requested. | |||
ic. Corrective | |||
steps that will be taken to avoid further violations: | |||
Event notification | |||
to the NRC was carefully | |||
reviewed and a copy of the SOP detailing | |||
reporting | |||
was posted in NSC RSO office and on the NSC bulletin board. | |||
NSC has already started observing | |||
work practices | |||
and talking to individuals | |||
on the safety aspects and correcting | |||
deficiencies. | |||
NSC has reemphasized | |||
on the restrictions | |||
on material storage cabinet in the pneumatics | |||
laboratory | |||
by locking all cabinets.Id. Date when full compliance | |||
is achieved: | |||
Based on the above considerations | |||
on all the corrective | |||
actions performed, we believe that this type of event will not happen in future and the Nuclear Science Center facility is in full compliance. | |||
We will permanently | |||
install the new beta-gamma | |||
detector in the pneumatics | |||
hood upon receipt.In conclusion, except for the Severity Level IV violation | |||
identified | |||
in the NOV on procedure | |||
violation, the radiation | |||
safety program satisfied | |||
the regulatory | |||
requirements | |||
and all the applicable | |||
features of the program were adequately | |||
implemented. | |||
The NSC management | |||
will provide increased | |||
attention | |||
and oversight | |||
of all licensed activities. | |||
If you require additional | |||
information, please contact me or Latha Vasudevan | |||
at (979) 845-7551.Sincerely, Dr. W. D. Reece, Director Nuclear Science Center LV/jg Xc: 211/ Central File NRC Inspection | |||
File Craig Bassett/ NRC Inspector Brian Thomas, Chief, Research and Test Reactors Branch Theresa Maldonado/Deputy | |||
Director, TEES | |||
}} |
Revision as of 17:51, 13 July 2019
ML061570264 | |
Person / Time | |
---|---|
Site: | 05000128 |
Issue date: | 05/24/2006 |
From: | Reece W Texas A&M Univ |
To: | Document Control Desk, NRC Region 4 |
References | |
2006-0036, EA-06-113, IR-06-203 | |
Download: ML061570264 (3) | |
See also: IR 05000128/2006203
Text
TEXAS ENGINEERING
EXPERIMENT
STATION TEXAS A&M UNIVERSITY
3575 TAMU COLLEGE STATION, TEXAS 77843-3575
NUCLEAR SCIENCE CENTER 979/845-7551
FAX 979/862-2667
May 24, 2006 2006-0036 U. S. Nuclear Regulatory
Commission
ATFrNPDb-cumentfrntiolVDek
D.C 20555-0001
SUBJECT: Reply to a Notice of Violation;
EA-06-113 NRC Special Inspection
Report # 50-128/2006-203, Facility License R-83.This letter is the required response to the violation
cited during the Special Nuclear Regulatory
Commission (NRC) inspection
on March 27-29, 2006 at the Texas A&M University
Nuclear Science Center Research Reactor facility.
We appreciate
the detailed report and hope that our prompt corrective
actions with respect to the cited violation
are acceptable.
Each item addressed
in the Commission's
report is addressed
below including:
1) reason for the violation, or if contested, the basis for disputing
the violation
or severity level, 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.1. Violation-
Severity Level IV a. Licensee failed to make reasonable
surveys to evaluate the magnitude and extent of shallow dose equivalent
radiation
levels following
the initial trial runs 'of vials containing
plastic disks and following
the first indication
of a possible overexposure
of February 24, 06.SIa. Reason: Trial-runso
of vials containing
plastic disks were performed
on several occasionsirath'e
year 2005. lThe experimental
protocol was correctly
followed and the employee's
m6nthly Shallow Dose Equivalent (SDE) was carefully monitored.
The experiments
were performed
by another employee in the year 2005. The SDE noted for this type of work by NSC employees
was minimal.Another employee performed
the above type of work in the year 2006 following RESEARCH AND DEVELOPMENT
FOR MANKIND http://nsc.tamu.edu
Thci
- 1 the training from the previous employee.
This employee's
handling practices
must have differed from previous workers.We do not contest the violation.
lb. Corrective
step that have been taken: Nuclear Science Center (NSC) has taken various corrective
actions to improve the radiation
protection
program.o The employee is restricted
from all radiation
duties and classified
as "non-radiation" worker during calendar year 2006 and his dosimetry
was cancelled.
o The employee has undergone
a medical examination
and a follow up check with laboratory
work and the results indicate "no abnormalities".
o We have built holders and manipulators
that will eliminate
beta dose for this type of Neutron Activation
Analysis (NAA) work.o We--haveaconducteNSCPne--uniati--cifiAed
personnel with emphasis on handling beta sources with the use of tools, tongs and beta shields.o We have conducted
general training for all radiation
workers on safe handling of compact sources.o We have developed
step by step handling procedures
for pneumatics (NAA) work. This is incorporated
in the Pneumatics
training module and also posted on the pneumatics
hood.o NSC Radiation
Work Permit is revised and notes the use of handling tools and shielding
during pneumatics
work.o We have implemented
two extremity
badges for NAA workers. The badge processing
period is still monthly (as per Texas A&M contract).
o NSC has evaluated
the current NAA worker's dose report for the month of April following
the implementation
of new handling procedures, handling tools, etc, and noted that the SDE was "M".o Based on the above consideration, NSC believes that monthly dose reporting
is adequate for the purposes of compliance.
o We have ordered a radiation
detector (indicating
both beta and gamma)that will be permanently
mounted inside the pneumatic
hood so that NAA workers will be able to note any unusually
high radiation
levels.o NSC has purchased
a dedicated
potable beta sliding window ion chamber for the purposes of noting contact beta doses.o The dosimetry
vendor was requested
to include two NSC contact points in case the first person on the list cannot be notified to minimize any time delay in overexposure
notification.
Fax and e-mail notification
was also requested.
ic. Corrective
steps that will be taken to avoid further violations:
Event notification
to the NRC was carefully
reviewed and a copy of the SOP detailing
reporting
was posted in NSC RSO office and on the NSC bulletin board.
NSC has already started observing
work practices
and talking to individuals
on the safety aspects and correcting
deficiencies.
NSC has reemphasized
on the restrictions
on material storage cabinet in the pneumatics
laboratory
by locking all cabinets.Id. Date when full compliance
is achieved:
Based on the above considerations
on all the corrective
actions performed, we believe that this type of event will not happen in future and the Nuclear Science Center facility is in full compliance.
We will permanently
install the new beta-gamma
detector in the pneumatics
hood upon receipt.In conclusion, except for the Severity Level IV violation
identified
in the NOV on procedure
violation, the radiation
safety program satisfied
the regulatory
requirements
and all the applicable
features of the program were adequately
implemented.
The NSC management
will provide increased
attention
and oversight
of all licensed activities.
If you require additional
information, please contact me or Latha Vasudevan
at (979) 845-7551.Sincerely, Dr. W. D. Reece, Director Nuclear Science Center LV/jg Xc: 211/ Central File NRC Inspection
File Craig Bassett/ NRC Inspector Brian Thomas, Chief, Research and Test Reactors Branch Theresa Maldonado/Deputy
Director, TEES