NRC CAL – NOV (SL 3)

On November 22, 2010, the NRC issued a Notice of Violation to Kansas State University for a severity level III violation involving 10 CFR 20.1101(a). Specifically, on or prior to September 22, 2010, the licensee did not implement a radiation protection program commensurate with the scope and extent of licensed activities that was sufficient to ensure compliance with the provisions of the regulations in Part 20. Examples include: (1) On or prior to September 22, 2010, the licensee did not make surveys as required by 10 CFR 20.1501 when the licensee failed to determine the magnitude and extent of radiation levels that would be caused by irradiating oil samples on September 21, 2010 that subsequently resulted, on September 22, 2010, in an unexpected high shallow-dose equivalent of 12.5 rem to the skin of the extremities (hands) of the operator handling the experiment and an unexpected change in the restricted area dose rates that exceeded 50 rem per hour on September 22, 2010; (2) On September 22, 2010, the licensee failed to supply and require the use of extremity monitoring devices to personnel who were likely to receive in 1 year, from sources external to the body, a dose in excess of 10 percent of the limits in 20.1201(a) in that, a person handling oil samples and a sample holder, which read in excess of 50 rem per hour, was not wearing, and had not been issued, extremity monitoring; (3) On or prior to September 22, 2010, the licensee did not have an adequate procedure as required by Technical Specification Section 6.3 to assure the safety of personnel within the Laboratory for conducting sample irradiations, in that, Experiment Procedure 1, "Isotope Production," did not require extremity dosimetry – finger rings – for those handling samples, it did not have a maximum sample withdrawal rate, and it did not specify threshold exposure/dose rates (hold points) to clearly indicate at what dose rate a sample should not be withdrawn from the pool.