ML061570264

Texas Engineering Experiment Station, Reply to Notice of Violation EA-06-113, NRC Special Inspection Report 50-128-06-203

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

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. 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