ML19325E694
| ML19325E694 | |
| Person / Time | |
|---|---|
| Site: | 07001334 |
| Issue date: | 09/15/1989 |
| From: | Kacher W AVCO EVERETT RESEARCH LABORATORY, INC. |
| To: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19325E683 | List: |
| References | |
| NUDOCS 8911080283 | |
| Download: ML19325E694 (2) | |
Text
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r Avco Research Laboratory e
Avco Mouerch Laboratory.inc./
2385 Revero Beach Parkway M:'r: f of TeatronInc.
Everett. Massachusetts 02 49 617/389 3000 9
Coptember 15, 1989 y
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.Nucloar Regulatory Commission
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Region I 475.Allendale Road King'of Prussia,. Pennsylvania 19406 RE:' August 28. 1989 Letter i
'Gentlemon:
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.Avco Rosenrch Laborntory Textron (ARL) did not knowingly intend to l
violato sny ttRC requirbment with rer,ards to its materials licenso SUM-1308
' issued on December 29, 1989.
The violations cited la your August 20, 198a I,
. letter More primarily the result of two factors:
(1) changint, personnel
? involved with the license and (2) confusion and misinformation in regards to j
-a disposal transaction.
In accord cco with the intent of the license, AEL disposed of the
' nuclear material specified in the license on October 27, 1987 to U.S. Ecolot;y,
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- Inc., which was opproximat.nly two montha prior to' the issuance of the most recent licenso. The transaction was rcported on an NRC Form 741 and ARL was t
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' told by U.S. Ecology t. hat the appropriato paporwork would be completed and t
submlLFad<to t.he NRC.
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'N kd thinifushn;can bh cttelbut:d to tio fcct th:t tha dicp:: cal k M a-i M3 transaction was initiated /and completed by.different employees. lThe disposal s
' f " transaction t'ok placo durin>, a' transitional period between Radiation Safety j
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Of ficers.!, The transaction was inillated by R. Sch11er, RSO, arid D. Olson,.
l l Safety'. Ent,i.1ocr and compl'oted by R. Fabrizio', RSO, shortly after being hlrod b,.D.-:
R. Fabelzio amended' the licenso in order to become Radiation Safet.y.
by ' ARL.~ -
h ' Officer shartly~after being hired, llowever, the disposed ~ transaction took t
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- place in the same time framo.
.-After our nucloac material was disposed of ARL-assumed.that the NRC was uv.
' fully aware'of'the transaction and that tbo materials license would becomo m,
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' & vrid.
Mr. C. Shroder was not instructed to. amend the materials license when n.
y; L h3 wasiinitially.hlred for the same reason.
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- AfLee the NRC's Safety Inspection on Junc 6, 1989 Mr. C. Shreder-
" notified me thatLthere were problems associated with the licenso and the-l 1'
transaction.
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The first correctivo. step taken by ARL was'to send Mr. C. T. Oberg fcP Leoples of tho transaction report:along.with other associated paperwork which
' documented the tranrneti,i. The second corrective step taken by AFL was to
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y ",'havo' Mr. Shreder send the NRC in amendment letter stating his qualifications.
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- The' HRC
- has sinco notified ARL (9/6/89 pt.ono conversation with John
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uJonson) that'it would be impractical to amend our materials licenso, sinco it y
b, f, d"wasn'" store to disposo"'lleense.
Therefore, Avco Research Laboratory, j
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.Textron has decided to properly terminate its materials license.
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'To provent'any additional problems ataociated with this licenso, y.
Mr. Shreder'and.myself'have reviswed the materials license requirements and wijl tchlew other pertinent FRC federal regulations to ensure that we properly J;
k5lN;terminatte:ourl'iconso.
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If you have any questions, plence fool frec ;.o contact me at t
(617),381-4346.
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. William Kacher C
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'V.P.' Industrial Resources a
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. fg UNITED STATES
. NUCLEAR REGULATORY COMMISSION II I ['
REQlON I f
476 ALLENDALE ROAD
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KING OF PRUSSIA. PENNSYL*/ANIA 19406
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AUG 281988 n
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. Docket Nn. 070 31334 License No. SNM-1308 i:
Avco Research' Laboratory, TEXTRON ATTN:
Mr. William Kacher, Vice President Quality and Industrial Resources 2385 Rever Beech Parkway i
Everett, Massachusetts 02149 Gentlemen:
subject:
RoutineInspectionNo.LO70-01334/89-001 On June 6,1989, C. T. Oberg of this office conducted e routine safety inspection at. the above address of activities authorized by the ai we itsted NRC license.
The inspection was an examination of your' licensed activities as they relate to 9adiation 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-a selective examination of represer.tative records.
T
'The f.indings of the inspection were discussed with Mr. Carl Shreder at the conclusion of the inspection.
This also refers to the telephone conversation on June 10 and 13,1989 between Mr. C. Shreder and Mr. C. T. Oberg.
Based on the results of this inspection, it appears that your a:tivities were l
not conducted in tull' compliance with NRC requirements.
A Notice of Violation is enclosed as Appendix A and categorizes each violation by severity level in accordatice with the " General Statement of Policy and Procedure for Nft Enforce-ment Actions," 10 CFR Part 2, Appendix C (Enforcement Policy).
You are required to respond to this letter and in preparing your response, you should follow the instructions in Appendix A.
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 your reply 3 will be placed,in the Public Document Room.
The responses directed by this letter and the accompanying Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
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'Avco Research Laboratory, TEXTRON 2
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Your cooperation with us is appreciated.
Sincerely, t
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ohn D. Kinneman, Chief p
Nuclear Materials Safety Section B Division of Radiation Safety and Safeguards
Enclosure:
. Appendix A, Hotice of Violation ec:
. Pub 11c' Document Reom (PDR)
Nuclear Safety Information Center (NSIC)
Commonwealth'of Massachusetts Mrl C. Shreder, Radiation' Safety Officer kW ' '
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I APPENDIX A l
f Avco Research Laboratory, TEXTRON Docket No. 070-01334 Everett, Massachusetts 02149 License No. SNM-1308 As a result of the inspection conducted on June 6,1989, and in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions,"
10 CFR Part 2, Appendix C (Enforcement Policy) (1988), the following violations were identified:-
3 A.
' License Condition 11.B. of License No. SNM-1308 requires a named-I individual'to be the Radiation Safety.0fficer (RS0) for this license.
Contrary to the above, on or about September 1,1988, the individuai identified as the RSO terminated i.is duties with the licensee.
The
. licensee failed to amend the license to include the identity and qualifications of the new individual appointed to the position of RSO.
This is a Severity Level IV violation.
(Supplement VI)
B.
License Condition 13 of License No. SNM-1308 requires that on March 1, 1987, and annually thereafter until the. license is amended or terrainated, the licensee file a report detailing the stctus of its plans and efforts to dispose of the Special Nuclear Material (SNM) authorized for storage by this licer.se.
l Contrary to the above, since February 1987, the licensee has not filed an annual SNM status report.
Thi.s is a Severity Level V violation.
(Supplement VI)
Pursuant to'the provisions of 10 CFR 2.201, Avco Research Laboratory. TEXTRON,
.is hereby required to submit to this office within thirty days of the date of
'the letter'which transmitted this Notice, a written statement or explanation in reply, including: (1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further violations; and (3) the date when full compliance will be achieved.
Where good cause is shown, consideration will be given to extending this response tig.a.
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NUCLEAR REGULATORY COMMISSION
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478 ALLEN 0 ALE ROAD l
KING OF PRUSSIA. PENNSYLVANIA 19408 AUB 281989 Docket No. 070-U 334 License No. SNM-1308 i
Avco Rescarch Laboratory, TEXTRON ATTN: Mr. William Kacher, Vice President Quality and Industrial Resources 2385 Rever Beach Parkway Everott, Massachusetts 02149 Ge ra lemen:
1
Subject:
. Routine' Inspection No. 070-02334/89-001 I
On~ June 6,'1989, C. T. Oberg of this office conducted a routine safety inspection at the above address of activities authorized by the above listed NRC license.
The inspection was an examination of your licensed activitics 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, l
interviews with personnel,'and a selective examination of representstive records..
The findings of-the inspection were' discussed with Mr. Carl Shreder at the conclusion of the inspection.
This also refers to the telephone conversation on June 10 and 13, 1989 between Mr. C. Shreder and Mr. C. T. Oberg.
Based on the results of this inspection, it appears-that your activities were l-
- not conducted in full compliance with NRC requirements. A Notice of Violation y
is enclosed as Appendix A and categorizes each violation by severity level in accordance with the " General Statement of Policy and Procedure for NRC Enforce-ment Actions," 10 CFR Part 2, Appendix C (Enforcement Policy). You are required to respond'to this letter and in preparing your response, you should follow the
. instructions in Appendix A.
tu In accordance with Secticn 2.790 of the NRC's " Rules of Practice," Part 2, u
Title 10, Code of Federal Regulations, a copy of this letter and your reply
-l will be placed in the Public Document Room.
.i The responses directed by this letter and the accompanying Notice are not l
L.
subject to the clearance procedures of the Office of Management and Budget av required by the Paperwork Reduction Act of 1980, PL 06-511.
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Avco Research Laboratory, TEXTRDN 2
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Your c'ooperation with us is appreciated.
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$1ncerely,
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/ohnD.Kinneman, Chief Nuclear Materials Safety Section 8 Division of Radiation Safety and Safeguards
Enclosure:
Appendix A, Notice of Violation
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Public Document Room (PDR) i Nuclear Safety Information Center (NSIC)
Commonwealth of Massachusetts Mr. C. Shreder, Radiation Safety Officer bec:
- RegionI'DocketRoom(w/ concurrences)
Management Assistant, DRMA C. T. Dberg,.RI
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s-L APPENDIX A NOTICE OF VIOLATION Avco Research Laboratory TEXTRON Docket No, 070-01334 Everett, Massachusetts 02149 License No. SNM-1308 As a result of the inspection conducted on June 6,1989, and in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions,"
10 CFR Part 2, Appendix C (Enforcement Policy) (1988), the following violations were identified:
A.
License Condition 11.B. of License No. SNM-1308 requires a named individua to be the Radiation Safety Officer (R$0) for this license.
Contrary to the abovo, on or about September 1,1988, the individual identified as the RSO terminated his duties with the licensee. The licensee failed to amend the license to include the identity and qualifications of the new individual appointed to the position of RSO.
This is a Severity Level IV violation.
(Supplement VI)
B.
License Condition 13 of License No. SNM-1308 requires that on March 1, 1987, and annua 11v thereafter until the license is amended or terminated, the licensee file a report detailing the status of its plans and efforts to dispose of the Special Nuclear Material (SNM) authorized for storage by this license.
Contrary to the above, since February 1987, the licensee has not filed an annual SNM status report.
This is a Severity Level V violation.
(Supplement VI)
Pursuant to the provisions of 10 CFR 2.201, Avco Research Laboratory, TEXTRON, is hereby required to submit to this office within thirty days of the date of the letter which transmitted this Notice, a written statement or explanation in reply, in:1uding: (1) the corrective steps which have been taken and the results i
l achieved; (2) corrective steps which will be taken to avoid further violations; and (3) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending this response time.
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