ML19296D034
| ML19296D034 | |
| Person / Time | |
|---|---|
| Site: | 07000398 |
| Issue date: | 01/02/1980 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19296D024 | List: |
| References | |
| 70-0398-79-02, 70-398-79-2, NUDOCS 8002290279 | |
| Download: ML19296D034 (1) | |
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APPENDIX A NOTICE OF VIOLATION U. S. Department of Commerce Docket No.70-398 National Bureau of Standards Washington, D. C.
Based on the results of an NRC inspection conducted on November 14-16,1979, it appears that one of your activities was not conducted in full compliance with NRC regulations and the conditions of your NRC License th. SNM-362 as indicated below. This item is an infraction.
Condition 10 of your facility license dated July 12, 1979, incorporates the "NBS Radiation Safety Manual" of ycur approved license application which requires, in part, in Part III " Administrative Control of Radiation Sources outside NBS Reactor Biological Shield", " Introduction" that the initiation of a project involving ionizing radiation must have prior approval from the Health Physics Section.
This approval covers the initial procurement, installation, location and use of the source.
Any changes which might affect radiation safety considera-tions for a project already underway must also have prior approval.
" Initial Procedure" requires, in part, that Fonn NBS-364 " Proposal to Acquire Radiation Source" shall be completed and submitted to the Health Physics Section.
The Health Physics Section indicates approval by signing all copies of the form.
Paragraph C " Internal Procedures" states in part, that when it becomes necessary to utilize a source of ionizing radiation differently from the description given in Form NBS-364, the change must be approved by the Health Physics Section.
Any change in location, procedure, custodian, or user shall be preceded by submission of Form NBS-365 " Proposed Change in Utilization of Radiation Source" to the Health Physics Section.
Contrary to the above:
1.
Between July 25, 1979 and November 9,1979, NBS-364 forms were not completed and submitted to the Health Physics Section as required, in that, of 30 NBS-364 forms examined, 26 did not describe the use to be made of the source in the required detail (one did not describe the use at all); 9 did not have the proposal date filled in; 8 did not show the storage locations; 14 did not indicate the applicable license number; 7 did not identify the source users; 9 did not indicate that the users had been qualified by Health Physics and 5 did not show the date reviewed by Health Physics.
2.
On or about April 4,1978, an experimenter changed the location for flame sealing glass ampoules containing plutonium from a glove box to a hood and did not submit a Form NBS-365 " Change in Source Utilization" to Health Physics for approval prior to implementing the change.
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