IR 05000186/1986003

Discusses Safety Insp Rept 50-186/86-03 on 860826-1003 & Forwards Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $4,000

ML20212H006
Person / Time
Site:	University of Missouri-Columbia
Issue date:	01/15/1987
From:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Brugger R MISSOURI, UNIV. OF, COLUMBIA, MO
Shared Package
ML20212H008	List: IR 05000186/1986003 ML20212H043
References
EA-86-191, NUDOCS 8701210257
Download: ML20212H006 (3)

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'JAN 151987 Docket No. 50-186 License No. R-103 EA 86-191 University of Missouri ATTN: Dr. Robert M. Brugger Director, Research Reactor Facility Research Park Columbia, MO 65201 Gentlemen:

Subject: NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY (NRC INSPECTION REPORT NO. 50-186/86003(DRSS))

This refers to the NRC safety inspection conducted from August 26 through October 3, 1986 at the University of Missouri Research Reactor Facility in Cola.3ia, Missouri. The inspection was in response to an overexposure reported to the NRC by the licensee in a letter dated August 20, 198 The results of the inspection were discussed with you during an enforcement conference in the Region III office on October 3, 198 The extremity overexposure and inadequate radiation hazard evaluation constitute violations of NRC requirements as described in Section I of the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice). Our review of the overexposure event shows that on July 29, 1986 you were informed by the dosimetry vendor (R. S. Landauer Jr. and Co.) that a TLD finger dosimeter for the month of June 1986 had recorded approximately 23 rem. The dosimeter had been worn by an employee on June 9, 1986 while handling thulium-170 wafer The extremity dose was subsequently revised to approximately 115 rem by the dosimetry vendor after considering the calibration adjustment factors necessary for measuring thulium beta exposures. After carefully considering your arguments regarding the validity of the dosimetry, we have determined that the thulium-170 pellet handling operation could easily have produced the exposure reported by the dosimetry vendor. We are concerned that you did not realize the actual beta dose rates associated with the thulium pellets either by calculation or measurement and did not adequately preplan the operation. These inadequate evaluations may have contributed to the overexposure even To emphasize the necessity of exercising effective control over licensed activities and employee radiation exposures, I have been authorized, after consultation with the Director, Office of Inspection and Enforcement, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty in the amount of Four Thousand Dollars ($4,000) for the violatiuns described in Section I of the enclosed Notice. In accordance with the

" General Statement of Policy and Procedure for NRC Enforcement Actions,"

10 CFR Part 2, Appendix C (1986) (Enforcement Policy), the violations CERTIFIED MAIL RETURN RECEIPT REQUESTED 8701210257 870115 PDR ADOCK 05000186 G PDR-

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University of Missouri 2 JAN 151987 r

described in Section I of the enclosed Notice have been categorized as a i Severity Level II problem. The base civil penalty for this type of violation or problem is $4,000, and although the escalation and mitigation factors in the Enforcement Policy were' considered, no adjustment has been deemed appropriat The inspection also identified other violations of NRC requirements which are described in Section II of the enclosed Notice. The violations included the failures to (1) maintain records of surveys; (2) provide information in a report, and (3) accurately reflect on a shipping paper the activity level of thulium pellets being transported to another location. Because these violations

are less significant than the overexposure event, they have been characterized as three Severity Level IV violations. However, they demonstrate that management awareness needs to be strengthened in these areas to achieve full compliance with NRC requirements.

You are required to respond to this letter and should follow the instructions i specified in the enclosed Notice when preparing your response. In your

- response, you should document the specific actions taken and any additional actions you plan to prevent recurrence. After reviewing your response to this Notice, including any proposed actions, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory

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In accordance with'Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosure ,

will be placed in the NRC Public Document Roo l The responses directed by this letter and the enclosed Notice are not subject

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to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-51 _

Sincerely,

Crig ant egg,qg g d'4 3 G. Kapp;er i

James G. Keppler Regional Administrator

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! Enclosure: Notice of Violation i and Proposed Imposition of Civil Penalty i

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JAN 151987

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Distribution POR SECY CA JMTaylor, IE RStarostecki, IE JGKeppler, RIII BStapleton, RIII JGrobe, RIII ABeach, IE EFlack, IE JLieberman, OGC Enforcement Coordinators-RI, RII, RIV, RV FIngram, PA JCrooks, AE00 BHayes, 01 SConnelly, OIA VMiller, NMSS DNussbaumer, OSP '

GSjoblom, IE ES File EA File OCS DCS/RSB (RIDS)

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