ML20197E790
| ML20197E790 | |
| Person / Time | |
|---|---|
| Site: | 15000019 |
| Issue date: | 12/19/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20197E744 | List: |
| References | |
| 15000019-97-01, 15000019-97-1, NUDOCS 9712300078 | |
| Download: ML20197E790 (5) | |
See also: IR 015000019/1997001
Text
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U. S. NUCLEAR REGULATORY COMMISSION
REGION 11
Docket No.: 150-00019
License Nos.: General License (10 CFR 150.20)
Maryland License No. MD-27-014-02
Report No.: 150-00019/97-01
Licensee: Johns Hopkins Applied Physics Laboratory
Location: Laurel, Maryland
Date: November 19, 1997
Inspector: Bryan A. Parker, Radiation Specialist
Approved by: Thomas R. Decker. Chief
Materials Licensing / Inspection Branch 1
Division of Nuclear Materials Safety
Enclosure 2
9712300078 971219
PDR STPRO ESGMD
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EXECUTIVE SUMMARY
Johns Hopkins Applied Physics Laboratory
NRC Inspection Report 150-00019/97-01
This special. announced inspection was conducted to review the circumstances
surrounding a research project conducted by Johns Hopkins Applied Physics
Laboratory (JHAPL) for the U.S. Navy that involved a )rototype smoke detection
system onboard a Navy submarine. JHAPL installed smote detectors containing
americium-241 (Am-241) into switchboards onboard the USS Scranton for " sea
trails ~ of the detection system. After the installation. the Navy command
overseeing the project, Carderock, realized that they had not received
authorization from the Navy Radiation Safety Comv cee to receive and use the
Am-241 sources for this purpose. The Navy notif ' Region 11 of the issue.
Region 11 noted that the sources were installed onooard the USS Scranton in
Norfolk. Virginia, and no record was found of N APL filing for reciprocity.
The scope of the inspection was limited to a r. iew of the JHAPL's activities
in NRC jurisdiction.
- JHAPL maintains a State of Maryland broad scope license to possess and
use radioactive material, including up to 50 millicuries of Am-241,
incident to " general use in analytical or scientific research."
. The inspector identified a violation regarding JHAPL's failure to file
for reciprocity under 10 CFR 150.20 prior to installing the Am-241
sources onboard the USS Scranton on April 17-18, 1997.
. The inspector identified another issue pertaining to the transfer of
radioactive material to the Navy without first verifying that the Navy
(Carderock) was specifically authorized to receive the materi 1. This
issue has been forwarded to JHAPL's Agreement State regulatory agency,
the State of Maryland Department of the Environment, Radioactive
Materials Licensing. Compliance and Safeguards Division.
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REPORT DETAILS
01, Activities in NRC Jurisdiction (87100)
a. Scope
The inspector reviewed JHAPL's activities in areas of NRC
jursidiction to determine if the activities were conducted in
accordance with 10 CFR Part 150 reciprocity requirements,
b. Qbservations and Findinas
JHAPL's activities were inspected for compliance with the
following NRC requirements:
. 10 CFR 30.3 requi'es in part. that .a person shall possess
or use byproduct material exce)t as authorized by a specific
or general license issued by t1e NRC.
. 10 CFR 150.20;a) provides in .ct, that any person who holds
a specific license from an Agreement State is granted a
Nuclear Regulatory Commission (NRC) general license to
conduct the same activity in non-Agreement States and
offshere waters sut' ject to the provisions of
. 10 CFR 150.20(b)(1) requires, in part, that any person
engaging in activities in non-Agreement States or offshore
waters shall, at least three days before engaging in such
3ctivity, file four copies of NRC Form 241, " Report of
Proposed Activities in Non-Agreement States," with the
Recional Administrator of the appropriate NRC regional
office.
. 10 CFR 150.20(b)(2) requires, in part, thac any person
engaging in activities in non-Agreement States or offshore
waters shall not transfer or dispose of radioactive
materials possensed or used under the general license except
by transfer to a person specifically licensed by the NRC to
receive such it.aterial.
. Item 9 of State of Maryland License No. Mi)-27-014-02, issued
to JHAPL, in part, authorizes the possession and use of
licensed radioactive materials, including Am-241, incident
to general use in analytical or scientific research and as
calibration sources.
In 1996, JHAPL contracted with the U.S. Navy to develop a
prototype system for early detection of switchboard fires onboard
sea-going vessels. . The result was the Arc Fault Detector System
or AFDS. JHAPL began by purchasing standard smoke detectors from
a local retailer and removing the ionization chambers. The old
electronics, cover 3, etc., were discarded. As the project
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progressed. JHAPL obtained detectors directly from the
manufacturer (Amersham Type DSCA2 and DSCA3 ionization chambers). .
Eac5 of the ion chambers contain less than 1.0 microcurie of Am-
241. JHAPL connected the detectors to its own specially-designed
electronics to meet the Navy's specifications. JHAPL then
conducted bench tests and other quality assurance checks at its
facilities in Laurel. Maryland. On April 17-18. 1997 JHAPL
3ersonnel installed the )rototype AFDS onboard the Navy submarine
JSS Scranton, moored at iorfolk. Virginia. The purpose of the
iristalletion was to conduct " sea trials" of the AFDS. or, in other -
words, test the AFDS under actual field conditionr Seven of the
prototype detectors were installed into Scranton's switchboards,
and two additional detectors were left onboard for use as
replacements / spares while the Scranton was at sea for a total of
nine 1.0 microcurie Am-241 sources. JHAPL planned to remove the
detectors upon the Scranton's return from sea, and return them to ,
its Laurel. Maryland, facility to evaluate the performance of the
AFDS. JHAPL then planned to make any necessary changes and have
the system mass-produced for installation on other Navy
submarines.
On November 19, 1997, the inspector reviewed and discussed the
matter with JHAPL Radiation Safety staff personnel. The NRC's
reciprocity requirements were discussed and the inspector
explained that an Agreement State licensee was required to file
for reciprocity prior to conducting licensed activities in areas
where the NRC had jurisdiction for regulating the use of licensed
materials. The Radiation Safety Officer (RS0) indicated that he
was not aware of this requirement at the time of the AFDS
installation on the USS Scranton. The inspector clarified the
specific requirement to notify the NRC prior to onducting licensed
activity in NRC states. Based on these discussions with the RSO
and review of records, the inspector determined that JHAPL had not
filed for reciprocity to conduct licensed activities on a U. S.
Navy vessel in Norfolk. Virginia, which is an area of NRC
jurisdiction. Failure of JHAPL to file for reciprocity prior to
conducting licensed activities in areas of NRC jurisdiction was
identified as a violation with regard to the requirements of
The inspector also reviewed and discussed the issue regarding
transfer of the Am-241 sources to the Navy during the sea trail
period. When radioactive material is transferred from one
licensee to another, the transferor is required to verify that the
transferee is authorized to receive the material prior to the
actual transfer. In this case. JHAPL assumed that Carderock, the
Navy command with which it was interacting, was authorized to
receive the sources. No verification was made to ensure that
Carderock could accept the material. Although Carderock holds a
permit to )ossess and use certain ty)es of radioactive materials
under the iavy Master NRC Materials _icense, at the time of the
AFDS installation on the Scranton. Carderock was not specifically
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authorized to possess and use these ty)es of Am-241 sources.
Since the apparent failure to verify t7at the transferee's
authorization to receive occurred under JHAPL's Maryland
(Agreement State) license, this issue has been forwarded to that
regulatory agency. the State of Maryland Department of the
Environment. Radioactive Materials Licensing. Compliance and
Safeguards Division.
c. Conclusions
One violation of NRC requirements was identified for failure to
file reciprocity prior to conducting licensed activities in areas
of NRC jurisdiction. Another issue was identified regarding the
apparent failure to verify that the Navy was authorized to receive
radioactive material prior to transferring it. This issue was
forwarded to the State of Maryland.
EXIT MEETING SUMMARY
An exit meeting was held with JHAPL representatives on November 19. 1997. The
overall findings from the inspection, including the violation and other issues
were discussed. No dissenting comments were received from JHAPL
representatives. and they did not specify any information reviewed during the
inspection as proprietary in nature.
LIST OF PERSONS CONTACTED
Licensee
D. Ermer JHAPL RSO
K. Stoll, JHAPL Assistant RSO
INSPECTION PROCEDURES USED
IP 87100: Licensed Materials Program
ITEMS OPENED CLOSED, AND DISCUSSED
OPENED
97-001 VIO- FAILURE TO FILE FOR RECIPROCITY WITH NRC RII 0FFICE
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