united states nuclear regulatory commission region i - nrc.gov · name eullrich/exu kmodes/exu f/...

September 18, 2015 Docket No. 030-38471 License No. 19-31447-01 EA-14-218 Steven C. Hart Director, Directorate for Safety Department of the Army US Army Communications-Electronics Command ATTN: AMSEL-SF-R 3200 Raritan Avenue Aberdeen Proving Ground, MD 21005 SUBJECT: NRC INSPECTION REPORT NO. 030-38471/2014-001, DEPARTMENT OF THE

ARMY, US ARMY COMMUNICATIONS-ELECTRONICS COMMAND (CECOM), ABERDEEN PROVING GROUND, MARYLAND AND THE MULTIPLE ARMY NATIONAL GUARD LOCATIONS

Dear Mr. Hart: On November 18-19, 2014, Kathy Modes of this office conducted a safety inspection at the above address of activities authorized by the above listed Nuclear Regulatory Commission (NRC) license. During the period of December 2, 2014, through June 2, 2015, the NRC also conducted safety reviews at 19 Army National Guard facilities in ten States and territories as part of this inspection. The inspection was an examination of your licensed activities as they relate to radiation safety and to compliance with the Commission's regulations and the license conditions. The inspection consisted of observations by the inspector, interviews with personnel, and examination of records. Additional information provided in your correspondence dated November 25, 2014; January 22, 2015; April 22, 2015; and August 12, 2015; were also examined as part of the inspection. Betsy Ullrich, of this office, discussed the findings of the inspection with you and Craig Goldberg of your organization on August 25, 2015, at the conclusion of the inspection. The enclosed report presents the results of this inspection. Based on the results of this inspection and in accordance with the NRC Enforcement Policy, the NRC has determined that two non-cited violations of NRC requirements occurred. The non-cited violations involved: 1) the improper disposal of a device containing a 15-millicurie source of nickel-63 to a recycling facility; and 2) possession of a total quantity of americium-241 in sealed sources in excess of the quantity authorized by Amendment No. 3 of the license. These are considered non-cited violations because they were identified by your staff, corrective actions were taken within a reasonable amount of time, and they were not repetitive or willful. Therefore, you are not required to respond to this letter. One issue remains open because it is still under review by the NRC: the failure to notify the NRC within 60 days in accordance with 10 CFR 30.36(d)(4) when no principal activities occurred in a separate building in 24 months. Although the license application described the CECOM activities to include bulk storage, distribution and other material life cycle functions for the licensed commodities, only the use of the devices was listed on the license. Because

UNITED STATES NUCLEAR REGULATORY COMMISSION

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devices remained in separate buildings but were not used for more than 24 months, and no other principal activities were performed in the separate buildings, the presence of the devices would result in the buildings being unsuitable for release. Therefore, the Department of the Army was required to notify the NRC of this in accordance to 10 CFR 30.36(d)(4), but no such notification was provided prior to the inspection. Since the inspection, the license was amended to authorize use of all devices to include the Army-wide possession, use and storage for the conduct of military operations including contingency or emergency purposes; and for the management and performance of material life cycle functions and services. A separate letter will be issued when the NRC has completed our review of this issue. In accordance with 10 CFR 2.390 of the NRC’s "Rules of Practice," a copy of this letter, and its enclosure, will be made available electronically for public inspection in the NRC Public Document Room or from the NRC document system (ADAMS), accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html. Current NRC regulations and guidance are included on the NRC's website at www.nrc.gov; select Nuclear Materials; Med, Ind, & Academic Uses; then Regulations, Guidance and Communications. The current Enforcement Policy is included on the NRC's website at www.nrc.gov; select About NRC, Organizations & Functions; Office of Enforcement; Enforcement documents; then Enforcement Policy (Under 'Related Information'). You may also obtain these documents by contacting the Government Printing Office (GPO) toll-free at 1-866-512-1800. The GPO is open from 8:00 a.m. to 5:30 p.m. EST, Monday through Friday (except Federal holidays). Please contact Betsy Ullrich at (610) 337-5040 if you have any questions regarding this matter.

Sincerely, /RA/ Marc S. Ferdas, Chief Decommissioning and Technical Support Branch Division of Nuclear Materials Safety

Enclosure: Inspection Report No. 030-38471/2014-001 cc: Craig S. Goldberg, Radiation Safety Officer

State of Maryland

S. Hart 2 principal activities were performed in the separate buildings, the presence of the devices would result in the buildings being unsuitable for release. Therefore, the Department of the Army was required to notify the NRC of this in accordance to 10 CFR 30.36(d)(4), but no such notification was provided prior to the inspection. Since the inspection, the license was amended to authorize use of all devices to include the Army-wide possession, use and storage for the conduct of military operations including contingency or emergency purposes; and for the management and performance of material life cycle functions and services. A separate letter will be issued when the NRC has completed our review of this issue. In accordance with 10 CFR 2.390 of the NRC’s "Rules of Practice," a copy of this letter, and its enclosure, will be made available electronically for public inspection in the NRC Public Document Room or from the NRC document system (ADAMS), accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html. Current NRC regulations and guidance are included on the NRC's website at www.nrc.gov; select Nuclear Materials; Med, Ind, & Academic Uses; then Regulations, Guidance and Communications. The current Enforcement Policy is included on the NRC's website at www.nrc.gov; select About NRC, Organizations & Functions; Office of Enforcement; Enforcement documents; then Enforcement Policy (Under 'Related Information'). You may also obtain these documents by contacting the Government Printing Office (GPO) toll-free at 1-866-512-1800. The GPO is open from 8:00 a.m. to 5:30 p.m. EST, Monday through Friday (except Federal holidays). Please contact Betsy Ullrich at (610) 337-5040 if you have any questions regarding this matter.

Sincerely, /RA/ Marc S. Ferdas, Chief Decommissioning and Technical Support Branch Division of Nuclear Materials Safety

Enclosure: Inspection Report No. 030-38471/2014-001 cc: Craig S. Goldberg, Radiation Safety Officer

State of Maryland Distribution: B. Bickett, RI ML15266A171 DOCUMENT NAME: G:\WordDocs\Current\Insp Letter\L19-31447-01.2014001.doc SUNSI Review Complete: EUllrich After declaring this document “An Official Agency Record” it will be released to the Public. To receive a copy of this document, indicate in the box: AC@ = Copy w/o attach/encl AE@ = Copy w/ attach/encl AN@ = No copy OFFICE

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U.S. NUCLEAR REGULATORY COMMISSION REGION I

INSPECTION REPORT

Inspection No. 030-38471/2014-001 Docket No. 030-38471 License No. 19-31447-01 EA No. EA-14-218 Licensee: Department of the Army U.S. Army Communications-Electronics Command (CECOM) 3200 Raritan Avenue Aberdeen Proving Ground, Maryland 21005 Locations: Army – CECOM headquarters 3200 Raritan Avenue, Aberdeen Proving Ground, Maryland Army National Guard Facilities Counter Drug Task Force (CDTF), 1 First Regiment Road, Wilmington, Delaware

Combined Support Maintenance Shop (CSMS), 1197 River Road, New Castle, Delaware

CSMS, 2796 Mitscher Road, SW, Washington, DC

CSMS, Bethlehem Old Works, St. Croix CSMS, Camp Hartell, Building T1033, 580 North Street, Windsor Locks, Connecticut CSMS, Building 598, Camp Santiago, Salinas, Puerto Rico U.S. Property & Fiscal Office (USP&FO) Warehouse, Building 541, Fort Buchanan, Guaynabo, Puerto Rico USP&FO Warehouse, 7001 Range Road, Jefferson City, Missouri CSMS, 7000 Military Circle, Jefferson City, Missouri CSMS, 1500 E. Henrietta Road, Rochester, New York CDTF, 1 Air National Guard Road, Scotia, New York CTDF, 330 Old Niskayuna Road, Latham, New York CSMS, Camp Smith, Building 124, Cortland Manor, New York Civil Support Team, 6749 E. 16th Street, Fort Dix, New Jersey CSMS, 1 Pinehurst Road, Manchester, New Jersey Force Protection, 100 Military Drive, South Charleston, West Virginia CSMS, 110 Army Navy Drive, Red House, West Virginia

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CSMS, 100 Minuteman Parkway, Building 140, Frankfort, Kentucky USP&FO Warehouse, 100 Minuteman Parkway, Building 120, Frankfort, Kentucky Inspection Dates: November 18-19, 2014 (Aberdeen Proving Ground) December 2, 2014 (Delaware) February 23, 2015 (Virginia) February 24-25, 2015 (Puerto Rico) March 11, 2015 (District of Columbia) March 24, 2015 (Connecticut) March 31, 2015 (Missouri) April 20-23, 2015 (New York) April 30, 2015 (New Jersey) June 1, 2015 (West Virginia) June 2, 2015 (Kentucky) Date of Followup Information: November 25, 2014 (ML14335A484) January 22, 2015 (ML15040A423) April 22, 2015 (ML15126A244) August 12, 2015 (ML15243A411) Inspectors: Kathy Modes (Lead Inspector) Senior Health Physicist Decommissioning and Technical Support Branch Division of Nuclear Materials Safety, RI Robert G. Gattone, Jr. Senior Health Physicist Materials Inspection Branch Division of Nuclear Materials Safety, RIII Approved By: Marc S. Ferdas, Chief Decommissioning and Technical Support Branch Division of Nuclear Materials Safety, RI

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EXECUTIVE SUMMARY

Department of the Army NRC Inspection Report No. 030-38471/2014-001

A routine, unannounced inspection was conducted at the U.S. Army Communications-Electronics Command (CECOM) facility located in Aberdeen Proving Ground, Maryland on November 18 and 19, 2014. Additional announced inspections were performed at Army National Guard locations in ten States and territories from December 2, 2014, through June 2, 2015. Information contained in correspondence from CECOM dated November 25, 2014 (ML14335A484), January 22, 2015 (ML15040A423), April 22, 2015 (ML15126A244), and August 12, 2015, (ML15243A411) also was reviewed as part of this inspection. The inspection was performed in accordance with NRC Manual Chapter 2800, “Materials Inspection Program,” and Inspection Procedures 87124, “Fixed and Portable Gauge Programs,” and 87126, “Industrial/Academic/Research Programs.” The inspection included observations of all focus areas with emphasis on implementation of the 2013 license renewal, the improper disposal of radioactive material from the Hawaii Army National Guard, and the use of radioactive material at the Army National Guard locations. The inspectors conducted interviews with Army personnel, observed day-to-day operations, toured facilities, and reviewed documents and procedures. Based on the results of this inspection, two non-cited violations were identified:

(1) 10 Code of Federal Regulations (CFR) 20.2001(a) requires that the licensee dispose of

licensed material only as described in 10 CFR 20.2002 through 20.2006. CECOM improperly disposed of a device containing a 15 mCi Ni-63 source on March 10, 2011. Specifically, the licensee notified the NRC in a letter dated February 5, 2014, that they identified on January 10, 2014, that a 15 millicurie nickel-63 source in a device was improperly disposed of by transfer to a recycling facility on March 10, 2011.

(2) Condition 8.T of Amendment 3 of License No. 19-31447-01 authorized the possession of americium-241 (Am-241) as sealed sources in a device not to exceed 4 microcuries per source and 4 millicuries total. CECOM exceeded the authorized limit for an unknown period of time. Specifically, the licensee notified the NRC in a letter dated November 25, 2014, that they possessed a total of 30 millicuries Am-241 in the authorized sealed sources and devices for an unknown period of time. The letter also requested an expedited amendment of the license to increase the possession limit. Amendment No. 4 was issued on December 4, 2014.

One issue remains open because it is still under review by the NRC. 10 CFR 30.36(d)(4) requires, in part, that licensees provide notification to the NRC in writing within 60 days if no principal activities have been conducted for a period of 24 months in any separate building or outdoor area that contains residual radioactivity such that the building or outdoor area is unsuitable for release in accordance with NRC requirements. Although the license application described the CECOM activities to include bulk storage, distribution and other material life cycle functions for the licensed commodities, these activities were described in sections other than the proposed “authorized use” section and therefore not listed as principal activities in Item 9 of the license. As a result, the principal activities describe only use of the devices. Because devices remained in separate buildings but were not used for more than 24 months, and no

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other principal activities were performed in the separate buildings, the presence of the devices resulted in the buildings being unsuitable for release. Therefore, the licensee was required to notify the NRC of this in accordance to 10 CFR 30.36(d)(4), but no such notification was provided prior to the inspection. CECOM submitted a letter dated April 22, 2015, notifying the NRC that devices were in storage and not used for principal activities for more than 24 months. They also requested that the license be amended for storage of devices for contingency or emergency purposes, and as necessary to carry out the life-cycle management of the commodities. The license was amended on August 20, 2015, to authorize the devices listed on the CECOM license for the Army-wide possession, use and storage for the conduct of military operations including contingency or emergency purposes; and for the management and performance of material life cycle functions and services.

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REPORT DETAILS 1. Scope of the Program

a. Inspection Scope

Inspectors interviewed U.S. Army Communications-Electronics Command (CECOM) personnel and reviewed License No. 19-31447-01, its supporting documents and records of past inspections to determine the scope of the licensee’s activities performed at Aberdeen Proving Ground and other Department of Defense installations in the United States. Inspectors used information obtained during the routine, unannounced inspection of CECOM’s Aberdeen Proving Ground facilities on November 18 and 19, 2014, to perform additional announced inspections at Army National Guard (ARNG) locations. NRC inspectors visited 20 ARNG locations in ten States and territories from December 2, 2014, through June 2, 2015, as part of this inspection. A separate inspection of an ARNG location was performed in Mitchell, South Dakota (Inspection No. 2015-001) on March 17, 2015. The inspection was performed in accordance with the NRC Inspection Manual Chapter 2800. Inspectors used Inspection Procedures 87124 and 87126, to review the use of radioactive material at the CECOM and ARNG locations. The inspectors interviewed Army personnel, observed day-to-day operations, visited storage and use facilities, and reviewed documents and procedures to determine the scope of the licensed program.

b. Observations and Findings

CECOM supports the Army military communications readiness worldwide. CECOM’s mission is to develop, provide, integrate, and sustain the logistics and readiness of certain military systems and mission command capabilities for joint, interagency, and multi-national forces worldwide. In support of the mission, an NRC license is required to authorize the variety of radioactive sealed sources in Army commodities such as calibrators; compasses; intrusion detection systems; detectors for narcotic, explosives, chemical agents and other contraband; rangefinders; thermal imaging devices; x-ray fluorescence devices; ion mobility spectrometers; and others. The license authorizes CECOM to use these devices at Department of Defense installations anywhere in the United States and at temporary job sites anywhere in the United States. Most of these other locations are facilities under the Army’s 54 National Guard States and territories. Prior to 2011, most of the ARNG devices were possessed under a general license. Since then, the devices are authorized on the CECOM specific license so they can be moved to new locations as needed during mobilization and deployment operations. Although the CECOM license renewal application and Condition 9 of the license describes the use of the devices for detection, calibration, and other activities, Supplements F and G of the application describe the CECOM activities to include bulk storage, surveillance and issue of calibrators and commodities, and for the control of radioactive items of supply distributed Army-wide. The application describes the


CECOM mission to be the management and performance of all material life cycle functions and services. CECOM staff stated that radioactive commodities may be needed for deployment and military readiness when the ARNG is activated. Most licensed commodities remain in storage in the event that they may be needed on a moment’s notice, and they may be in storage for more than 24 months without actually using the devices. Commodities that are awaiting disposition also are stored until CECOM and the Army Joint Munitions Command can arrange to properly dispose of these radioactive materials. Because the mission of CECOM and ARNG was not described under the “authorized use” of materials in the application, Condition 9 does not include these as principal activities. As a result, the principal activities describe only use of the devices. Because devices remained in the buildings but were not used, and no other principal activities were performed in the separate buildings, the presence of the devices resulted in the buildings being unsuitable for release. Inspectors noted that leak tests and radiation surveys were performed of devices in storage, and that the devices also were included in inventory. The inspectors identified the following locations where devices were stored for more than 24 months without being used, in separate buildings where no other licensed activities were performed, and the licensee did not make a report and begin decommissioning as required by 10 CFR 30.36(d)(4): - The Civil Support Team (CST) in Fort Dix, New Jersey, possessed three Smiths

Detection Model APD2000 devices which had not been used in over 48 months because they were replaced with a non-radioactive device. These devices each contained a 15 millicurie nickel-63 (Ni-63) sealed source.

- The New York ARNG Force Protection in Latham, New York possessed one GE

Homeland Protection Model Itemizer and two GE Homeland Protection Model Vapor Tracer 2 devices in storage for over 24 months with no use of the devices. Each contained a 10 mCi Ni-63 sealed source.

- The West Virginia ARNG Force Protection in South Charleston, West Virginia

possessed two GE Homeland Protection Model Itemizers and three GE Homeland Protection Model Vapor Tracer 2 devices for over 24 months with no use of the licensed devices. These devices each contained a 10 mCi Ni-63 source.

- The Missouri ARNG possessed and stored a Smiths Detection Model No. APD

2000 spectrometer containing approximately 9100 microcuries of Ni-63 and a Viewer Thermal imaging device containing approximately 0.1 microcurie of thorium-232. No principal activities were conducted with these items since August 23, 2011.

- The USP&FO warehouse in Frankfort, KY, stored a non-serviceable sight unit for

over 24 months. The sight unit contained not more than 0.330 microcuries of thorium.


Specifically, 10 CFR 30.36(d)(4) requires, in part, that licensees provide notification to the NRC in writing within 60 days if no principal activities have been conducted for a period of 24 months in any separate building or outdoor area that contains residual radioactivity such that the building or outdoor area is unsuitable for release in accordance with NRC requirements. Contrary to that, multiple CECOM stored multiple devices without use for periods longer than 24 months at multiple ARNG facilities. This is an open item which is still under review by the NRC. The licensee submitted a letter dated April 22, 2015, notifying the NRC that devices were in storage and not used for principal activities for more than 24 months at the USP&FO in Missouri. In the letter, the licensee also requested an extension of the 24 months in accordance with 10 CFR 30.36(h), and requested that the license be amended to add storage of material as a principal activity. Additional information was provided in a letter dated August 15, 2015, describing the need for storage of devices for contingency or emergency purposes, and as necessary to carry out the life-cycle management of the commodities. As a result, the license was amended on August 20, 2015, to authorize the devices listed on the CECOM license for the Army-wide possession, use and storage for the conduct of military operations including contingency or emergency purposes; and for the management and performance of material life cycle functions and services.

c. Conclusions

The failure to notify the NRC within 60 days that no principal activities were conducted for a period of 24 months, in a separate building that contains residual radioactivity such that it is unsuitable for release in accordance with NRC requirements, is an apparent violation of 10 CFR 30.36(d)(4). This is an open item which is still under review by the NRC.

2. Organization and Management Oversight of the Licensee’s Program

a. Inspection Scope

Inspectors interviewed personnel and reviewed documents and procedures to determine the organization and management oversight of licensed activities, and the program organization and management oversight, as it related to activities at the ARNG facilities.

b. Observations and Findings The CECOM licensed activities are managed by the Directorate for Safety at their facilities in Aberdeen Proving Ground, Maryland. Radiation safety staff includes the Director, the Radiation Safety Officer (RSO), and seven health physicists. The Radiation Safety Committee provides additional oversight of the licensed program, although a Radiation Safety Committee is not required for this license. Primary responsibilities of the safety staff include inventory, calibration, and leak-testing of the sealed sources and devices; training of users; inspection of facilities where licensed materials are used or stored; managing incidents/accidents; disposal of radioactive waste; and management of NRC licenses and Army Radiation Authorizations.


The ARNG States and territories operate with a State RSO, local RSOs, local alternate RSOs, AN/UDM-2 operators, and other personnel as assigned. There are approximately 400 ARNG State and local RSOs. The radioactive commodities are used by ARNG in the Combined Support Maintenance Shop (CSMS); the U.S. Property and Fiscal Office (USP&FO) warehouse; the Civil Support Team (CST); the Counter Drug Task Force (CDTF); and Force Protection (FP). CECOM radiation safety personnel conduct on-site inspections every two years (27 locations per year) of ARNG locations where materials are used under the license. The State RSOs are required to perform a self-evaluation of their radiation safety program during the off year. These inspections are required by Army regulations and are performed to ensure compliance to Army, NRC, and U.S. Department of Transportation (DOT) regulations.

c. Conclusions

The organization and management of the program is as described in license commitments. No violations were identified.

3. Facilities and Equipment

a. Inspection Scope

Inspectors interviewed personnel, inspected facilities, observed personnel, and reviewed records at 19 ARNG locations in ten States and territories to determine if facilities and equipment were as required by with the conditions of the license and NRC regulations.


CECOM facilities for analysis of wipe test and leak test samples, and for calibration of survey meters, are located at Aberdeen Proving Ground, MD. The inspectors observed the use of operable and calibrated equipment for analysis of leak test and wipe samples. Inspectors also observed the facilities and equipment used for calibration of survey instruments. CECOM records were available online and easily accessible. Inspectors visited ten locations of the ARNG CSMS. The ARNG CSMS personnel use the AN/UDM-2 calibrator to confirm that the Army pocket direct reading dosimeters, alarming rate meters, and RADIAC probes are operable. The inspectors observed the availability of calibrated survey instruments, appropriate dosimetry, and equipment for taking leak-test samples. Inspectors confirmed that materials in the facilities were secured when not in use. Inspectors visited three ARNG CDTF locations, one CST site, and one FP site. ARNG personnel from the CDTF, CST and FP use and/or store vapor tracers, itemizers, and other chemical agent and explosive detectors as part of their mission. Inspectors verified that, in accordance with the August 2011 amendment to include these formerly “generally licensed” devices on the CECOM license, the labels on the devices were


replaced. Inspectors also observed additional labels affixed to the devices which provided transfer and disposal guidance. Inspectors visited three warehouses under the ARNG USP&FO, which is responsible for the storage of serviceable radioactive commodities and excess radioactive commodities awaiting disposal. USP&FO also performs commercial shipment and receipt of radioactive material for the ARNG. Inspectors observed a variety of licensed devices maintained in the warehouses. USP&FO stores the radioactive commodities until needed and then ships them to military bases. Inspectors noted that the warehouses also contained radioactive commodities authorized under the Department of the Army, Tank-automotive and Armaments Life Cycle Management Command (TACOM), License No. 21-32838-01. Warehouse personnel treat all radioactive material the same. CECOM personnel are able to distinguish which commodities are associated with their license.

c. Conclusions

The facilities and equipment were as described in license commitments. No violations were identified.

4. Material Inventory

a. Inspection Scope

Inspectors interviewed personnel, observed equipment, and reviewed records at facilities where licensed devices were used or stored to understand how CECOM accounts for the inventory of devices authorized under the license, and to verify that material is accounted for in accordance with the conditions of the license and NRC regulations. At ARNG locations, the inspectors observed items stored in the radioactive materials storage rooms within warehouses, and confirmed that ARNG personnel performed leak tests, inventories, radiation surveys of the storage areas.


CECOM personnel maintain an inventory of thousands of radioactive commodities possessed under the license. Most of the devices are used or stored at ARNG locations. As approved in CECOM’s license renewal application, CECOM performs a physical inventory of most of the devices at ARNG locations on an annual basis. There are some devices for which a 6-month physical inventory is required. This also meets the Army mandate for a 12-month accounting of all radioactive commodities. The following issues related to inventory occurred since the last inspection. - (Materials Licensee Event Report MLER-2014-006) In a letter dated February 5,

2014, CECOM notified the NRC of the improper disposal of a 15 millicurie nickel-63 (Ni-63) source in a Smiths Detection Ion Mobility Spectrometer Model 400B by the Hawaii Army National Guard which occurred on March 10, 2011. Although the device manufacturer is currently authorized to distribute these devices to persons


who are exempt from licensing, and was formerly authorized to distribute them to persons who possess them under a general license, the Army chose to possess such devices under the CECOM specific license. CECOM identified the improper disposal on January 10, 2014, as part of a review of inventory that began in December 2013. Upon investigation, CECOM learned that the Hawaii ARNG transferred the device to the Defense Logistics Agency (DLA) for reutilization or disposal on March 10, 2011, and removed it from their inventory. Subsequently, the device was sent to a recycling company in Nevada and the source and device were unable to be recovered by the time CECOM learned of the loss. CECOM also determined that the assigned DEMIL codes for these items were incorrect because they indicated that either no radioactive material present or no DEMIL was required. Corrective actions included:

a) Retraining of personnel at Hawaii ARNG; b) Notifying all ARNG Station RSOs of the problem; c) Adding adhesive labels to the devices at all ARNG locations, which state that

users must notify CECOM prior to any transfer or disposal; and that DLA disposition services are not authorized to accept radioactive materials;

d) Ensuring that inventory of all former generally licensed assets to includes confirming that proper methods are used for all turn-in and disposal actions;

e) Issuing an article about proper disposition of such devices in CECOM’s RADCO REGISTER newsletter June 2014;

f) Revising their inspection process to review the complete list of radioactive material, including that in disposal records;

g) Updating the FED-LOG database to correct DEMIL codes for these assets; h) Providing guidance to DLA that, if they should come across an ion spectrometer

being turned in, they must immediately recognize that it contains radioactive material and contact CECOM; and

i) Discussed this matter during training sessions with personnel from the ARNG States and territories.

The inspectors noted that the licensee was cited on September 7, 2012, (NRC Inspection No. 2012-001) for the loss of three itemizers, each containing 10 mCi Ni-63, from the Puerto Rico ARNG in August 2010. The loss was identified by the licensee and reported to the NRC in February 2012. Inspectors verified that devices observed during NRC Inspection No. 2014-001 were labeled as described in the corrective actions for the NRC Inspection No. 2012-001. The improper disposal from the Hawaii ARNG occurred prior to the implementation of corrective actions from Inspection No. 2012-001 so labels that might have prevented the improper disposal were not yet added to the devices. CECOM achieved full implementation of their corrective actions as a result of the improper disposal from the Hawaii ARNG on June 10, 2014.

10 CFR 20.2001(a) requires that the licensee dispose of licensed material only as described in 10 CFR 20.2002 through 20.2006. The disposal of a device containing a 15 mCi Ni-63 source on March 10, 2011, is a violation of 10 CFR 20.2001, which requires that a licensee dispose of licensed material only as described in 10 CFR 20.2002 through 20.2006.


- In a letter dated November 25, 2014, CECOM notified the NRC that they possessed

30 millicuries total of americium-241 (Am-241) in lightweight laser designator rangefinders (LLDR) for an unknown period of time, an amount that was greater than the Amendment 3 possession limit for Am-241 in the LLDR of 0.004 millicuries per source, and 4 millicuries total. The November 25 letter also requested an expedited amendment of the license to increase the possession limit. Amendment No. 4 was issued on December 4, 2014. CECOM determined the cause of this violation to be a breakdown in communication and oversight of the acquisition of assets. Specifically, a project manager misinterpreted the license conditions, safety engineers did not inform health physicists of the additional acquisition of assets, and CECOM did not verify the inventory of the project manager’s work group. Corrective actions by CECOM included: a) a full accounting of the inventory of LLDRs; a review of other similar projects to confirm that no similar problems occurred in other areas with other devices; health physics access to the database in which LLDR are tracked; and improvements in communication such as quarterly meetings with the project manager to review the status of the program. Inspectors verified that CECOM did not exceed any other possession limit listed on License No. 19-31447-01. The possession of Am-241 in an amount greater than that authorized by Amendment No. 13 of the license is a violation of Condition 8.T of Amendment 3 of License No. 19-31447-01.

c. Conclusions

Two non-cited violations related to the licensed material inventory occurred: (1) the improper disposal of a 15 mCi Ni-63 source in a device on March 10, 2011, is a violation of 10 CFR 20.2001; and (2) the licensee exceeded the possession limit for Am-241 as listed on Amendment No. 3 of the license. Both violations are “non-cited violations” in accordance with NRC Enforcement Policy because each is a Severity Level IV violation that was identified by the licensee, corrected within a reasonable period of time, not repetitive, and not willful.

5. Training of Workers a. Inspection Scope

Inspectors interviewed personnel, observed personnel perform activities with licensed materials, and reviewed records at 19 ARNG locations in ten States and territories to determine if workers are trained in accordance with the conditions of the license and NRC regulations.



The inspectors observed ARNG personnel perform a daily quality assurance check of their PDR-77 survey meter and perform a calibration using the AN/UDM-2. They observed ARNG staff demonstrate taking of a leak test, wearing whole body and either ring or wrist dosimetry, and performing surveys. Inspectors also observed ARNG personnel use a variety of the detectors at different locations, one of which was the set-up and use of the Rapiscan device on the Stratton Air National Guard Base. The inspectors confirmed that personnel were trained in the operating and emergency procedures. Workers appeared knowledgeable of the use of the devices and the radiation protection requirements for use and for storage. The inspectors reviewed training records as well as the operating and emergency procedures developed by ARNG USP&FO warehouse personnel based on CECOM templates. USP&FO also performed commercial shipment and receipt of radioactive material for the ARNG. CECOM personnel were able to distinguish which commodities were associated with their license, and which were radioactive commodities authorized under the Department of the Army, TACOM License No. 21-32838-01. Inspectors confirmed that ARNG warehouse personnel were trained to identify a radioactive commodity and to secure, inventory, survey, package, transport and ship these commodities.

CECOM personnel provided the following training courses at least annually:

- 24-hour RSO course, which qualifies personnel to be appointed as Local RSOs for

locations that possess NRC-licensed, and Army authorized, radioactive commodities;

- 40-hour RSO course, which qualifies personnel to be appointed as State, Alternate

State, and Local RSOs; - 24-hour Radioactive Commodity Identification and Transportation course, which

qualifies personnel to be appointed to receive, package and ship for transport radioactive material packages; and

- 8-hour AN/UDM-2 operator course, which qualifies personnel to be appointed to

properly use, calibrate, and source check portable survey instrumentation. c. Conclusions CECOM and ARNG workers were trained in accordance with the conditions of the

license and NRC regulations. No violations were identified. 6. Radiation Protection

a. Inspection Scope

Inspectors interviewed personnel and reviewed records to determine if the licensee’s radiation protection program was implemented in accordance with the conditions of the license and NRC regulations.



Inspectors observed that licensed materials were secured when not in use. The inspectors reviewed dosimetry records, inventory and leak tests records, monthly and quarterly survey records, operating and emergency procedures, and the last CECOM inspection findings. Inspectors noted that radiation protection activities were performed as required by the license conditions and the regulations. The ARNG CDTF in Scotia, New York, possessed a Rapiscan mobile device for scanning of cargo, vehicles, trailers, etc. Licensee representatives stated that the Rapiscan Team used this device in the State of New York to assist local law enforcement at locations not NRC jurisdiction, under a State of New York license. The Rapiscan device is serviced by the device manufacturer and was one month over due on a leak test. Once identified, the ARNG personnel quickly communicated with the device manufacturer to send a service engineer out to conduct a leak test as soon as possible. Since there has been no use in NRC jurisdiction, the leak test would need to be completed before the next use of the device.

Independent surveys were performed by the inspectors. The highest contact exposure rate on the UDM-2 calibrator was approximately 7.0 milliroentgen per hour (mRem/hour), and the maximum exposure rate on the exterior surface of the safe/cabinet was approximately 0.2 mRem/hr.

c. Conclusions The licensee’s radiation protection program is implemented as required by the conditions

of the license and NRC regulations. No violations were identified. 7. Exit Meeting

At the conclusion of the inspection, the results were discussed with CECOM’s senior management on August 25, 2015. CECOM acknowledged the inspectors’ findings and provided a status update of the corrective actions.

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Attachment

PARTIAL LIST OF PERSONS CONTACTED

Licensee - CECOM *Steven C. Hart, Director, Directorate for Safety *+Craig S. Goldberg, RSO +Barry J. Silber, Health Physicist +Michael S. Gray, Health Physicist +Hugo Bianchi, Health Physicist Gary R. Ziola, Health Physicist Paul H. Feeser, Health Physicist +Burton C. Cummings, Health Physicist +Marcos S. Vincente, Health Physicist State Radiation Safety Officers (SRSOs) LTC Tim Seery, Connecticut Denise Matthews, Delaware CPT Joshua Witt, Kentucky SSG Luis Cruz, Alternate SRSO for New Jersey SFC Chuck Austin, New York MAJ Angel Camacho, Puerto Rico CW3 Mervin Mills, Virgin Islands LTC Stacy Hess, West Virginia And various Army National Guard personnel +Present at entrance meeting *Present at exit meeting ITEMS OPEN, CLOSED, AND DISCUSSED OPEN: The failure to notify the NRC within 60 days in accordance with 10 CFR 30.36(d)(4) that no principal activities have been performed in a separate building for more than 24 months. CLOSED: The improper disposal of a device containing a Ni-63 sealed source. CLOSED: Exceeding the possession limit for Am-241 sealed sources listed in Amendment No. 3 of the license.

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LIST OF DOCUMENTS REVIEWED Annual Program Reviews for 2013 and 2014 Radiation Safety Committee meeting minutes for 2013 and 2014 Dosimetry Reports for 2013 and 2014 Leak test records for 2013 and 2014 Inventory records for 2014 Incident Log for 2012, 2013 and 2014 Survey Meter Calibration records for 2014 Training records for 2012, 2013, and 2014 Radiological Surveys for 2013 and 2014 License Amendment No. 3 issued February 24, 2014 Materials Licensee Event Report dated February 5, 2014 ML14295A461 Licensee letter dated November 25, 2014 ML14335A484 Licensee letter dated January 22, 2015 ML15040A423 Licensee letter dated April 22, 2015 ML15126A244 Licensee letter dated August 12, 2015 ML15243A411 Licensee letter and renewal application dated December 11, 2013 LIST OF ACRONYMS USED ARNG Army National Guard CDTF Counter Drug Task Force CECOM U.S. Army Communications-Electronics Command CFR Code of Federal Regulations CSMS Combined Support Maintenance Shop CST Civil Support Team DLA Defense Logistics Agency FP Force Protection LLDR lightweight laser designator rangefinders NRC U.S. Nuclear Regulatory Commission RSO Radiation Safety Officer TACOM Tank-automotive and Armaments Life Cycle Management Command USP&FO U.S. Property & Fiscal Office

united states nuclear regulatory commission region i - nrc.gov · name eullrich/exu kmodes/exu f/...

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