ML19330B016
| ML19330B016 | |
| Person / Time | |
|---|---|
| Site: | 05000054, 07000687 |
| Issue date: | 07/11/1980 |
| From: | Stello V NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Bollinger R UNION CARBIDE CORP. |
| Shared Package | |
| ML19330B017 | List: |
| References | |
| EA-80-014, EA-80-14, NUDOCS 8007300038 | |
| Download: ML19330B016 (2) | |
Text
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Docket Nos.: 70-687 50-54 M 11 1980 EA-80-14 Union Carbide Corporation ATTN:
Mr. R. E. Bollinger Vice President Nuclear Products P. O. Box 324 Tuxedo, New York.10987 Gentlemen:
This is in reference to your letter of April 28, 1980, in response to the Notice of Violation and Notice of Proposed Imposition of Civil Penalties sent to you with our letter of April 7, 1980.
The April 7 letter concerned an item of noncompliance found during our investigation conducted on January 2-29, 1980, of events involving the transport and disposal of low specific activity radioactive waste from your facility, on or about December 10, 1979.
After careful consideration ef.your response, we have concluded that the proposed penalty for the item of noncompliance should be mitigated to One Thousand Dollars, and accordingly, we hereby serve the enclosed Order on Union Carbide Corporation imposing a civil penalty in that amount.
Appendix A to the Order discusses your request that the civil penalty for the item of noncom-pliance be reduced.
With regard to the corrective and preventive actions documented in your
" STATEMENT OF CORRECTIVE STEPS TAKEN (Pursuant to 10 CFR 2.201(a))", item B)
Corrective Steps Taken With Regard to the Preparation of Shipping Documents must' call for more explicit instructions to the carrier for maintenance of exclusive use shipment controls.
There have been other cases illustrating the need for explicit instructions.
For instance, in one case to satisfy a state weight requirement on loads over axles, a carrier broke the seal on a trailer, entered the trailer, and changed the loading pattern.
As a result, a box with a high radiation reading was located so that the limit of 49 CFR 173.393(j)(2) was exceeded.
In another case, the carrier changed tractors pulling a trailer.
The replacement tractor was of a different design than the original tractor, and the radiation level in the replacement tractor exceeded the 49 CFR 173.393(j)(4) limit.
Accordingly, you are required to provide additional information as to Item B of your statement of corrective steps taken.
CERTIFIED MAIL -
RETURN RECEIPT REOUESTED 800 7 agoo3g
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Union' Carbide' Corporation b I I I930 Your implementation of the corrective action to be addressed in your response to this letter will be considered in determining whether any further enforce-ment action, such as modification, suspension or revocation of your license is appropriate.
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 the enclosures will be placed in the NRC's Public Document Room.
Sincerely, i
/
Victor Ste o Director '
Office of Inspection and Enforcement
Enclosures:
Order Imposing Civil Monetary _ Penalty cc w/encis:
M. H. Voth, Manager, Nuclear Operations W. G. Ruzicka, Reactor Project Engineer C. Konnerth, Health Physicist R. Bollinger, Vice President, Medical Products Division 9
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