ML20004C095

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IE Safety Insp Rept 30-08744/81-01 on 810318.Noncompliance Noted:Individuals Working in Loading Dock/Filter Storage Area Not Instructed in Health Protection Problems
ML20004C095
Person / Time
Issue date: 05/21/1981
From: Adam W, Matson E, Sreniawski D
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20004C090 List:
References
30-08744-81-01, 30-8744-81-1, NUDOCS 8106010507
Download: ML20004C095 (19)
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Text

{{#Wiki_filter:l l 9 U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION III . Report No. 03008744/81-01 Docket No. 030-08744 License No. 34-15216-01 Licensee: Nuclear Consulting Services, Inc. 6800 Huntley Road Worthington, OH 43085 Inspection At: Nuclear Consulting Services, Inc., Worthington, OH Inspection Conducted: March 18, 1981 La.h. A f l Inspectors: W. J. Adam, Ph.D. 6 / 1' / f/ / l 4 Gth E. R. Matson Of7ag %l, t 9 Er/ k' h Approved By: . J. Sreniaws i, Chief / / Materials Radiation Protection Section 2 Inspection Summary Inspection on March 18, 1981 (Report No. 03008744/81-01) Areas Inspected: Special, unannounced inspection of activities condccted under License No. 34-15216-01 including an investigation of allegations relayed to Region III by the Ohio Disaster Services Agency on March 3,1981. The allegations were: 1. Personnel who work with or near radioactive material including those involved with receipt of carbon filters have not received training or warnings concerning radioactivity. This allegation was partially substantiated. See Section 5. 2. Personnel working in the radiochemistry laboratory may not be trained in safe handling of radioactive material and emergency procedures. This allegation was not substantiated. See Section 5. THIS DOCUMENT CONTAlH3 POOR QUAL.lTY PAGES 81060109Y

3. In December 1980, a shipment was received from Arkansas Power and Light. It contained a crate reading 12 rem /hr. The crate was stored at NCS, Inc. until NRC inspectors visited NCS, Inc., at which time the crate was returned to Arkansas Power and Light. Employees may have been exposed to radiation. The allegation was not substantiated. See Section 17. 4. I-131 from carbon filter testing is discharged two or three feet from open windows. I-131 used in a high pressure test chamber is vented inside the plant. I-131 may be recirculated into occupied areas. The allegation was not substantiated. See Section 13.B. 5. Equipment and procedures for safe use and disposal of I-131 may not be adequate. The allegation was not substantiated. See Sections 7 and 16. 6. Radioactivity is used in a test chamber, an area accessible and frequented by employees. No regulatory requirement was violated. 7. Radioactive syringes, gloves, and bottles are left laying around the hot lab. The allegation was not substantiated. See Section 8. 8. Posting of " Caution Radioactive Material" signs is not adequate. Specifically, there are no signs at the loading dock. The allegation was not substantiated. See Section 9. 9. Radioactive carbon filters received from nuclear power plants are not separated or stored in an area away from employees. No regulatory requirement was violated. See Section 10. 10. Radioactive carbon filters are not surveyed immediately upon receipt to determine their safety. The allegation was not substantiated. See Section 10. 11. Contaminated carbon may be ground and recycled for use in nerve gas protective clothing. Contaminated filters are recharged and reused. l l The allegation was not substantiated. See Section 10. Also reviewed were: Inspection History; Organization; Training, Retrain-ing and Instruction to Workers; Facilites, Instrumentation; Security of Materials; Posting and Labeling; Receip.t and Transfer of Material; g w-

Personnel Radiation Protection-External; Personnel Radiation Protection-Internal; Surveys; Leak Tests; Radioactive Effluent Control and Waste Disposal and Shipping Incidents. Results: Of the 15 areas inspected, two items of noncompliance were identified in two areas: Of the 11 allegations, one was partially substantiated: Allegation one - inadequate training, Section 5. 10 CFR 19.12 - failure to train radiation workers; Section 5; License Condition 20 - failure to perform area surveys, Section 13. l . ~.

DETAILS 1. Persons Contacted

  • Mr. Louis J. Kovach, President
  • Mr. Jack Jacox, Vice President
  • Mr. John Grimm, Laboratory Supervisor
  • Ms. Christine Pollard, Radiation Safety Officer Mr. Timothy Walker, Radioisotope Laboratory Technician Mr. Mark King, Laboratory Technician i

Mr. Bruce Robert, Laboratory Technican Mr. Troy King, Fabrication Technician Mr. Thomas Knight, Fabrication Technician

  • Attended exit interview on March 18, 1981.

2. General NRC Byproduct Material License No. 34-15216-01, issued July 17, 1972, authorizes the use of any byproduct material with atomic numbers three through 83 for the purpose of evaluation of adsorbents. The licensee is also authorized to possess and use several sealed sources as cali-bration sources and as ionization sources in detectors. The bulk of licensed activities consist of: a. refilling of activated carbon filters received from nuclear power plants, and b. testing of activated carbon samples for iodine adsorption efficiency (samples are selected from activated carbon filters used at nuclear power plants). 3. Inspectior. History The previous NRC inspection of this license was conducted on l September 16, 1976. No items of noncompliance were identified. i This facility has been recently inspected by the U.S. Department of Labor. The Citation and Notification of Civil Penalty issued as a result of this inspection is included as Attachment A. I 4. Organization Nuclear Consulting Services, Inc. is part of NUCON, Inc., Inter-l national of Delaware. Nuclear Connulting Services cwns 50% of 1 U.S. Activated Carbon Company (U.S.A.C.C.). Winfield Manufacturing l owns the remaining p'rtion o^ ') 3.A.C.C. Mr. Kovach is president of both Nuclear Consulting Services, Inc. and U.S.A.C.C. and is the only employee involved with both firms. No items of noncompliance were identified. l i

5. Training, Retraining and Instruction to Workers 10 CFR 19.12 requires training of all personnel who work in or frequent a restricted area. This training is to include, but is not limited to: health protection problems associated with exposure to radio-a. active materials, and b. the appropriate response to warnings made in the event of any ur. usual occurrence or malfunction that may involve exposure to radiation or radioactive material. No additional training requirements are included by license condition. The licensee has focused current training efforts on two areas: a. field engineers, and b. workers as described in 10 CFR 19.12. Field engineer training is conducted to satisfy requirements of ANSI Standard 45.2.6-78 and is documented. Current in-house training is conducted by the RSO and the Laboratory Supervisor. This program was initiated during December 1980 and consists'of a weekly open class. Basic math is currently being reviewed with the intent of providing the employees with enough background information to proceed to radiation safety training. Individuals working in the hot lab appeared to have adequate training in operating and emergency procedures. Individuals working on the loading dock / filter storage area as well as within the chemistry lab were not instructed in the health protection problems associated with exposure to radioactive materials. Moreover, an employee responsible for receipt of I-131 packages was not instructed in the appropriate response to warnings made in the event of any unusual occurrence, specifically, she was not instructed in appropriate emergency pro-cedures for the receipt of a damaged byproduct material package. This is in noncompliance with 10 CFR 19.12. One item 6f noncompliance was identified. 6. Facilities The facilities were as specified in the license application and referenced correspondence. Included are; a counting and analysis chamber, four I-131 carbon penetration test chambers in the hot lab, and a high pressure test chamber outside of the hot lab. No items of noncompliance were identified. 1 l

7. Instrumentation The instrumentation specified in the license application dated June 13, 1977, or the equivalent, was available and appears sdequate. Survey instruments available in the isotope laboratory include two baird Atomic 443 area monitors and a Digirate G-M ratemeter. Analytical instruments include a 4 x 4 NaI well counter and an intrinsic germanium detector. Calibrations of instruments are performed. No items of noncompliance were identified. 8. Security of Materials In the areas inspected, all licensed material was secured against unauthorized removal. All isotopes are used and stored in the isotope laboratory, with the exception of a high pressure cell just outside the hot lab door. This lab is locked with a padlock when unattended. All sealed sources including:

.15 mci Co-60 source, a 57.5 mci Kr-85 source, a 7.5 mci Ni-63 source and a number of low activity calibration sources are kept in a locked cabinet in the hot lab.

Carbon filters received from nuclear power plants are determined by alpha, beta, and gamma analysis to be below NRC exempt concentrations listed in 10 CFR 30.70 Schedule A, and therefore, no security is required. No licensed material was observed to be in an unrestricted area. No items of noncompliance were identified. 9. Posting and Labeling Posting of radioactive caution and warning signs in all of the isotope use areas including the counting chambers, high pressure l chamber, and isotope laboratory appear to be adequate. The receiving dock is not required to be posted because no high radiation area, radiation area or amounts of radioactive material exceeding ten times the quantities specific in 10 CFR Part 20, Appendix C were present. l Radioactive labeling of equipment such as vials, cylinders and sealed sources appeared to be adequate. Posting of notices as required by 10 CFR 19.11 appeared to be adequate. No items of noncompliance were identified. 10. Receipt and Transfer Byproduct material is received as contamination on activated carbon filters at the rear loading dock and as packages of I-131 at tLe front reception desk. r 1

Iodine-131 is received from International Chemical Nuclear, Inc. (ICN) in shipmenen of about 5 mci each. These packages are delivered by courier to the front reception desk. The secretary notifies the laboratory supervisor who picks up the package and takes it to the hot lab where he performs a G-M survey and wipe test. The inspectors reviewed the receipt and survey records and they appeared adequate. Used activated carbon filters from nuclear power plants are received at the rear loading dock. The shipment is surveyed on the truck or shortly after it is unloaded. These filters do not sit on the loading dock any longer than 1.0 to 1.5 hours. Before these filters are moved or processed, 5 percent are analyzed for gross alpha, beta, and gamma contamination with a germanium detector. If the analysis shows no contamination above the exempt concentrations as defined in 10 CFR 30.70, Schedule A, the carbon is considered non-radioactive and is processed as such. The inspectors reviewed the receipt and contamination analysis records. It was determined from interviews with licensee employees that used carbon is not recycled and reground for use in the manufacture of protective clothing. They stated there would be no economic advantage in recycling the carbon. No items of noncompliance were identified. 11. Personnel Monitoring - External Evaluations of whole body and extremity exposures are performed using film badges and TLD ring dostneters supplied on a monthly basis by Eberline. The following individuals are supplied with whole body dosiaeters: all field test personnel, isotope and chemistry lab personnel, a welder, an employee who performs cali-brations of equipment, an electronics technician and any other employee who requests one. In addition, ring dosimeters have been issued to individuals working in the isotope lab. The inspectors reviewed personnel monitoring reports for 1976 through March 1981. Maximum yearly totals are listed below in millirem. 1981 1980 1979 1978 1977 lo76 Whole body 164 433 117 240 165 147 Extremity 228 889+ + Ring dosimeters were not issued until the last quarter of 1980.

  • Ring dosimeters were not issued during this year.

No items of noncompliance were identified.

12. Personnel Monitoring - Internal The licensee is committed by license condition to perform urinalysis on laboratory personnel working with liquid forms of Hydrogen-3. Tritium has not been used in liquid form since 1973. The licensee initiated the current iodine-131 bioassay program in February 1981. Personnel who work in the radioisotope lab are monitored every two weeks. Employees from the chemistry lab, the front office, field test personnel, fabrication technicians and quality assurance personnel are monitored on a monthly basis. The counting system consists of a four inch by four inch NaI crystal calibrated with a mock-iodine source (Cs-137/Ba-133). Personnel are counted by leaning over the crystal and positioning their throats in close proximity to the crystal. The results of the monitoring are recorded in percent maximum permissible body burden. From a review of monitoring data, it was determined that the highest recorded iodine uptake was 0.2 percent of the maximum permissible body burden (MPBB). Chemistry lab and front offica personnel usually measured approximately 0.05 percent of MPBB. Prior to February 1981, thyroid counts were performed on a monthly basis on personnel working in the isotope lab. Results of these counts were recorded in curies. From a review of monitoring records, it was determined that the highest recorded uptake of iodine prior to February 1981 occured on June 8, 1979, and was 5.6 E-9 Ci. No items of noncompliance were identified. 13. Surveys An August 2,1977 application specifies laboratcry surveys and wipes for beta gamma contamination be performed and the results recorded once each week. a. Laboratory Surveys Weekly wipe tests and area surveys of the radioisotope lab were being performed in areas where contamigation was likely to occur. An action level of 1100 dpm per 100 cm is used for decontamina-i tion. Survey records indicated isolated cases of contanination I within the radioisotope lab. Corrective actions were noted in the survey records. From an examination of survey records it appeared that no area or swipe surveys were performed between August 5 and 22, 1980, August 22 and September 8, 1980, and September 19 and December 23, 1980. This is in noncompliance with License Condition 20. b. Air Monitoring The licensee is required by 10 CFR 20.201(b) and License Condi-tion 20 to evaluate airborne concentrations of radionuclides in both restricted areas and eff,luents. At this facility, the only i nuclide which presents a possible airborne hazard is iodine-131. Charcoal collection capsules designed for for a maximum flow rate of 4 CFM at 95 percent relative humidity are run for a maximum of five hours at less than 1 CFM on a weekly basis at 1 l different locations within the radioisotope lab. These samples are generally taken while charcoal filter evaluations are being i conducted. The Part 20 Appendix B maximum concentration in air for iodine-131 for a restricted area is 9.0 E-9 microcuries/ milliliter. The licensee's sample results for the restricted area ranged from 5.0 E-10 to 1.0 E-11 microcuries/ milliliter. l Point of release (effluent) monitoring is conducted at the same ( frequency as the restricted area monitoring. The same charcoal I collection capsules are used. The Part 20 Appendix B maximum concentration for I-131 in air for an unrestricted area is i 1.0 E-10 microcuries/ milliliter. A typical point of release sampling result for January 1981, indicated 1.66 E-11 micro-curies / milliliter. Sampling results for several monitoring periods during the first three months of 1981 were recorded in units other than microcuries per milliliter. c. Package Surveys Byproduct material is received in two forms: (1) elemental or methylated iodine-131 and (2) charcoal filters with trace contaminants from nuclear power plants. Iodine packages are surveyed immediately upon receipt by the radioisoptope lab supervisor and the results recorded. Surveys of incoming filters are performed either on the delivery vehicle or on the loading dock, within 1.0 to 1.5 hours after receipt. Survey results typically indicated less than 0.01 mR/hr. One item of noncompliance was identified. 14. Leak Tests One sealed source requires leak testing. A 15 mci Co-60 source is leak tested as required. The inspectors reviewed the records. No items of noncompliance were identified. 15. Radioactive Effluent Control No liquid radioactive wastes are generated for disposal through the sanitary sewer system. Venting of iadine to the atmosphere is discussed in Section 13, " Surveys." No items of noncompliance were identified. _9_

1,6. Waste Disposal Radioactive contaminated waste is generated from the iodine-131 testing in the hot lab. Contaminated articles include vials, gloves, absorbant paper, test carbon, counting samples, etc. All of this waste is disposed of in a specified hot waste drum in the hot lab. The waste is stored for a minimum of ten weeks. After the storage period, each item is removed, one at a time, and surveyed with a G-M survey meter. If the survey indicates backgrcund radiation levels, it is discarded into the normal trash system. If the article is found to be above background it is held for decay. Licensee representatives stated survey results are not recorded and have not been recorded since the date of license issuance on August 29, 1977. License conditions do not require survey results to be recorded. No radioactive material is discarded into the sanitary sewerage system. No items of noncompliance were identified. 17. Shipping Incident On December 18, 1980, NCS, Inc., received a shipment of filters from Arkansas Power and Light which included a crate of contaminated waste. A survey of this shipment performed on the loading dock revealed higher exposure rates than expected. A further examination showed one of the crates contained material other than filters. Arkansas Power and Light, the driver of the delivery truck and the NRC, Region III were notified. Region III instructed the licensee to open the crate and determine its contents, repack it and return it to its originator. Arkansas Power and Light sent two men on December 22, 1980, to repack and send the entire shipment back. The NRC did not send any inspectors to NCS, Inc. but did have inspectors at the Arkansas Power and Light facility. See Attachment B for licensee's evaluation of the event. No items of noncompliance were identified. 18. Exit Interview On March 18, 1981, an exit interview was held at the conclusion of the inspection with the licensee representatives identified in Section 1. The apparent items of noncompiiance, possible corrective actions and the allegations were reviewed. Attachments: As stated.

+ e U.S. DEPA':TMENT OF LARCR oCCUPAT1oNAL SAF E TV ANo HEALTH /.DMINISTuftoN 4 i ~. CITATION and NOTIFICATION OF PENALTY ' essoasca pate e osaa auvasa _)/L/81 c6657r.104 Federal Office Building - Roon 634 ' atsas . asta easa 200 North High Street 5 1800 1 *F 2

PENat Tits Colt = bus, Ohio h3215 h69-5582

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  1. NSPECTIOrJ DATE:

RECTIPT g 2/12/81

OF THl3 Serious 1

l INSPECTION SITE: 6600 Huntley g iCONTEsito Nuclear Consulting Sewices, Inc. Vorthington, Ohio h3085

tsse encloses To:

P. O. Box 29151 THe Lavv REau MES that a e py or mi. ! 8"M Colunbus, Ohio L3229 ci== t poneow-mew, in e pro,.+ : lat.on'W sited besow.'ac* " or "ar ** 'ac8* *f *"'* i 7" "as The Citatson must. se Desched rema,n posted unas me v esat no cited be. : seeere Poes, Cmuu.a 86108367 few he.e been corrected, or for 3 wormane : d'v$ 4'ac8"d'at ***ad'sa8 Fa$erel he'i 8 This estanon cescribes v osamens of me Occupedonal Setevy and Heeish Act of 1970. deve whichever.sioneer. m you must correct the violanens referred to in shee estanon by the detes listed below and pey the penaltese prop lencluding sweekende and Federal holidays) from your receipt of ttus estation and penalty you mail a notice of contest evs Labor Aree Oftace et the address shoven above. (See me enetooed boomet vehich ovemos your responsitulities and co'e read 14 congunction peqft thes formj e M ITEM NUM8ER e DATERTvv>stCH ; STAND ARD. R EOULATION 01 SECTIoN OF THE ACT VtoLATED: VIOLA f ton uuST.'* DESCRIPTION PENALTY BE COR n E(.TE D The violations descuibed in this citation are alleged to hrve occurred on or about the day the inspection was nade unless otherwise indicated within the description given below. i* 1a h/6/81 I $200.00 29CFR1910.23(a)(7): Te=porary noor opening (s) were not guarded by standard railires or constantly attended by senecnes a) Mezzanines noor ooenings in floor grating were not guarded. 1b h/6/81 29CFR1910.23(a)(B): Floor hole (s), into which persons could accidentally walk, were not guarded by staMard railings with standard toeboards on all exposed sides or by floor hole covers of staMard i strength and construction: a) Mezzanine; floor holes not guarded. 1e h/6/81 29 CFR 1?'O.23(o)(1): Open aided flocr(s) or platfom(s) h feet or nore aoove the adjacent floor or ground level ::re not guarded by standard railings or the equivalent, on all open sides: a) Carbon inpregnation area; no staMard railing around open sided platforn (no nid rail). 2a h/6/81

$200.00 29CIR1910.2h(f):

Fixed stairs did not have uniL.,In rir height l and tread width throughout the flight of stairs: i a) Southeast part of buildir.g; nissing stair on fixed industrial stairs. ,{ 2b h/6/81 i 29CFR1910.2h(e): Fixed stairs were installed at an angle to the horizontal greater than 50 degrees a) Southeast part of building; fixed stairs were installed at anagle to the horizontal greater than 50 degrees.

  • l

'* AREA DtRECT s ~ Se NOTICE TO EMPLOYE ES - Tde law gives an emp'oyee or his EMPLOYER OfSCRIMINATION UNLAWFUL - The law pro. :10TAL PE NA repreentative trie oc,pertunity to object to any abatement date habits descrimmation by an employer agaenst an emp?ovee for ' O HS set for a veolation of he bel. eves the date to be unruonable, filing a cott plaint or for exercismg any nghts under this Act. gg .The contest must be mailed to the U S. Department of Labor An ernployee who believes that be has been disenmmated

o.a., p.v.aos Area Off ce at the address shown above with;n 15 workmq days gemst may file a complamt no later than 30 days after the :
  1. DOL OSHs lancludmg weekends and Federal holidays) of the receipt by descrtmmation with the U.S. Department of Labor Area Of fice l'"d',' osha the employer of thes citation and penalty.

at the address shown above. EMPLOYER RESPONSIBILITIES AND COURSES OF ACTION - The enclosed booklet outimes employer responsetulaties end courses of ection and s'iould be read in coniunction with th.s notification. rev a finas a uen gnTIsar & 7tnra na essen t TV Ch h ."..d i ,t

-p--,-- i U.S. DEPA2TMENT OF LABOR ^ QC.CUPATioN.*.L SAFETY AND HEALTH LDMINISTRATION _W- = *. i CITATION and NOTIFICATION OF PENALTY _3/h/81 C665710h ( Federal Office Pu11 ding - Root 63h

  • nasma 200 North Hign Street f ma
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_5 l1800 2082 l PENALT!ES Colu:sbus, Ohio h3215 h69-5582 ME itil 'o7y"3 E 'rm-- d a 'hi 1 INSPfCTION DATE: AECElPT Serious 1 2/12/61 0F THis 1NspEcTion site: " *N 6800 Huntley f0" 70: miolear Consulting Services, Inc. VortMmrton, Ohio 143085 STED gsee,e,,4 Pe O. Box 29151 THE law nEcuanES that a copy of eis ' seekrei) Columbus, Ohio h3229 cirwon t. poseed in-ediedy in e pron + aeat otace a or nw ee tocation of ee vi. me section ua 1 tiento died bdow. The citation must se oeta hed remain posted un D the violations deed be-low have been corrected, or for 3 voorkleg, Sofoes Ptseing days (excluding weekends and Federal holk This citation describes violations of the occupadonal Safety and Heenth Act of 1970. days) whichever is longer.

(

3-(enduding vveetenda and Federal holidays) from your rseipt of this citados ent' enalty you , ons within 15 vuorking days Labor Ares Office at the address shown soove. (See the endosed booklet which oudines ye,or responnoitities and read in coniunction wwith this form.) on and mould be ITEM NUMBER STANDAR6 **CULATloN oR SECTioN OF TME ACT VIOLATED: ' DAff. lV WMICH l '* DESCRIPTION k#NE g PEfeALTy 3 29 CFR 1910.27(d)(3): The side rails of through or side ate h/6/81 $2h0.00 fixed ladder extensions did not extend 3 i feet above parapet (p or landing (s): s) a) Bucket elevator area; no side rails of fixed ladder were provided to offer safe access to platform. l l l l l i l l ' ^"'^ "'**'%g" ~ $6ho.00 NOTICE TO EMPLOYEES -T/e law gives an employee or his representative the opportunery to object to any abatement date EMPLOYER DISCRIMINATION UNLAWFUL - The law pro. OTA set for a violation of he befseves the date to be unreasonable. hibits discrimination by an employer against m employee for t FDR 15 The contest must be mailed to the U.S. Department of Labor filing a complamt or for exercising any rights under this Act. CITAT10'4 Area Of rice at the address shown above within 15 working days An employee who believes that he has been discrimmated aae%g order Paveble T (excluding weekends and Federal holidays) of the receipt by agaif'st may ide a complaint no later than 30 days after the 1 M * *' the employer of this citation and penalty, discrimination with the U.S. Department of Labor Area Office l7,' "M at the address shown above. j, courses of action anJ shound be read in con unction with this notification. EMPLOYER RESPO F-t _.,. _ b

l 7 U.S. DEPARTMENT OF LABOR l WCUPATloNJ.L SAFETY AND HEALTH ADMIN 157;ATION CITATION and NOTIFICATION OF PENALTY 3/h/81 C66c;710h Federal Office Building - Rocn 634

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  • anna..rasa 200 North Eigh Street 5

1800 1er 1 HNALTIES Columbuss Ohio h3215 m Ou h69-5582 DAYS OF lmmo o r...r_ : c. .u mr i 1 4 INSPECT 10N DATE: RECElPT p 2/12/81 0F THl3 Other l 2 INSPECTION SITE: g 6600 Huntley conigs7go Vorthington, Ohio h3085 m (S endesad Nuolear Consulting Services, Inc* P. O. Box 29151 THE law nEoUints met e ece, of eis anklet) Cimica be pomed i==edi=#y in a prond. Columbus, Ohio h3229

    • at akut o' a* ** 'ocation of mo vio-mi ser %n sas lationis) cited below. The Citation must se Detached remain posted until me v6olations cited be-severe Poenne low heve been corrected, or for 3 working days (excluding weekends and Federal hoe days) whichever la longer.

This citation describes vicistions of me occupations 4 Safety and Health Act of 1970. The penalty (ies) listed below are based on these slotetlant You must correct the violations referred to in this citation by the dates Heted below and pay the penalties proposed.untees vneln 15 working days l (excluding weekends and Federal holidays) from your receipt of this citation and penalty you mail a notice of contest to the U1 ospartment of Labor Arne Offica et the address mown above. (See me enclosed booklet which outilries your responshilitlee and crurses of action and mould be read in conjunction with this formJ o

  • DATA avWMICH t NsCg g'*

PENALTY R.RECULATION oR 9ECTIL oF THE ACT VloLATED: DESCRIPT1oM The violations described in this oitation are alleged to have occurred on or about the day the inspection was nade unless otherwise indicated within the description given below. 1 h/6/81 0 29CFR190h.2(a): A log of alJ recordable occupational injuries and illnesses, (CSHA Fom No. 200 or equivalent), was not naintained at the eatablisb=ents a) No OSHA 200 kept at the establishnent. l l l l l l l l l l l l

    • AREA DIRECTOR j

NOTICE TO EMPLOYEES - The la'w gives an employee or his EMPLOYER DISCRIMINATION UNLAWFUL - Tm ;aw pro. OA L representative trie opportunity to object to any abatement date hibits discrirnination by an employer against an employee for 1 CIT ATION set for a violation if l$e believes the date to be unreasonable. faling a complaint or fer exercising any trfts under this Act. %,w,,u, The contest must be mailed to the U.S. Department of Labor An employee whn beliewes that he has beei discriminated j O'eer Pavao8e ' Area 0ffice at the address shown above within 15 working days against may file a complaint no later than 30 days after the I ~00 N "" (excluding weekends and Federal holidays) of the receipt by discrimination with the U.S. Department of Labor Area 0ffice l'**'**,'* U8*^' the employer of this estatiori and penalty, at the address shown above. s EMPLOYER RESPONSIBILITIES AND COURSES OF ACTION - The enclosed booklet outlines ernployer responsibilities and l courses of action and should be read in conjunction with this notibcation. I p.

.l.. s,me wew. v i4 'De c. 80 deleae. denstdlinp Gesces .Gdco Etrrl% Gblumbus,0 ~Receival of I?adoadoe. Sv.fment-fem hchansas Wedeae One.. (~R.A.In.,LS.R.3 M.D. S. %bIe. (lases, t\\alogens,and metal O)(ths on charcoas) 2:co p.m. dohn &lrmm be an reu.k.a rec 5Do.A su.rdet of rem 0.rkaatsas. -Th' e, dly o.ra.tts reci.tced 3 ara. tis bad been uAloacled and 6+acked -two high, Gree deep in 4he deck. a.rea at klucen. jollatoing rzeoain3s: dehn got %e V60 ~lbl .5.tf mt/Ar r w s .I #6.c 4 hat 4he crafes appeared a:15 dold rne. l 'abood hace. 7a.dohn shipp n,reacho higher 4ha.n -lhezy were. S4cded o?t. l fo g sapers. t0e. Lotu-t d.t and -bolc det boyes and lces l 4he. 2 4he lower 3 4he Ed ed 0 arcand 1. 8

  • n t l jtt r bc e sreadbec from c(ake, 70- 16 ( bacb Y

~ 091 a. erale. Y aedicitt bacicgr}ettnd.Ta e o w cj' x s had no p k -6,e d6p[ pd toflom Se also ca.lled bac obooe fratler. Gacl Paperidle 3:30cp.m. Oa.lled Nfde. : Mr. 31a - 93a - 46 il Ne adbised tts 40 opGn 4he crale idatq 4te. Kghesl reading and ~dneigze, -{he carzbon prconterrP 3 oC radionaclided. Rf 4his 4ime Lareg

Kern, h

taalker, and Ort.rt

markouned 4he e'forh %e arokes were roped u ? G ra.aes i ed a ractiah arca. %e 4 dock worke6 and durocogd bg me and bnd to hooe no corrfam-were inahir,v on othem. The eraPes were moded and

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yj y ARKANSAS POWER & LIGHT COMPANY ng

Arkansas Nuclear One mranL.

<rm mrece r Tc r r, enTppTnn pdMP NO. n nm, e arr 1603.03A SHIP TO Abt eu b m /h'.S w h Le,, RSR NUMBER 4[8-3n ~ J /,,d0d Mu R h j

f., License Number. of Organization

' Receiving Radioactive Material _ 2 1 dolu,Jous, og 432 z_t .w.. ..-. n.-.. .n ,.-.,..-,....:....>....s.. w. w u.., ..s w 3$-46~2-w \\ ^ DescriptionofMata.rialfbio fe; Mcdecil. LSA _ d. 0.S. D a) Alanse z/ JZioO EL:eL_ t .d.--..' i. Chemical Form, if Applicable ... m. 7, f.. )'2#T 7-/33 g g13fM g b) Radionuclides i c) Quantity . ((, Millicuries Iransport Group Kdf n d) Type Shipment LsA e) Type Container la.3tr-om '[~.'qhY lx)eodem 3 axe 5 f) Sole Use Vehicle Required (/e; f7 S$p v ,J 1 g) DOT Labels on all Containers es,. Mor S a /A, e,,,- 04 ,y p y. .y h) Maximum Vehicle Radiation. Levels: External Surface of Vehicle 4 0.! mrem /hr j 1 6 ft. from External Surface 4.0.1 mrem /hr Reading in Cab 4@ mrem /hr .i) Maximum Loose Surface Cost'mination: Alpha 46D DPM/100cm2 a 2 Beta-Gamma X2CD DPM/100cm n.[O Surveyor's Sign. _ I. Title H9 Date 6 j) Required Placards on Venicle (d.s k) RSR and Applicable Forms Completed: LleA i / l This is to-certify that the above-named materials are properly classified, described, packaged, marked and labeled and are in proper condition for trans-portation according to the applicable regulations of the Department of Trans-portation. 1) Reviewed By 6 f~t. Date / 7 / Radioactive Waste Coordinator l 1 l l

o ARKANSAS POWER & LIGHT COMPANY j 7 y yg g ' Arkansas Nuclear One f-R.iDIOf CTn'" S"TP'"'"' mm r Te s wTunTm pad [F NO 1603.03 A. SHIP TO Mudeg [mgJi-L. Sese,Lc. RSR NuMuza 2/g gn d i /d0d N,nR Eoa 3 T,Lic. case Number of Organization ~ - n: Receiving Radioactive Material ' ~ < i dol d us,Oh N32. 8 ..n........,_,.., -.~a.... : n c.. ... +,.m... u.a.,..,.k

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bina.c_, fe_, Medectcj. LSA _ d,0.S.,D k a) Description of Material e. h oN asei )%,h5E <1.n$//Isl l An1les m. G$ cu,.ee. l .d.-_.'__. J. Chemical Form, if Applicable t %) Radionuclides 7,. )L N, Z~ 7-MM !d<#$ b \\[c) Quantity

7. ^[d Millicuries Transport Group Kd' TIC g

f\\ W-d) Type Shipment LSA e) Type Centainer la.3fr-o(4Wed1.)oodem30Xe5 O J p f) Sole Use Vehicle Required des . -f71 M l 0 g) DOT Labels on all Containers c4,. Ao 4 /e er s j% .f V y ' g-lef ~ h) Maximum Vehicle Radiation Levels: / External Surface 'of Vehicle _ C O.lmRem/hr 6 ft. from External Surface 4.0.! mrem /hr Reading in Cab _f Q mrem /hr i) Maximum Loose Surface Contamination: Alpha DD DPM/100cm2 2 Bet::-Garra X2Do DPM/100cm Surveyor's Sign. j). Title H9 Dateit[I j) Required Placards on Vehicle des j k) RSR and Applicable Forms Completed: LdA / This is to certify that the above-named materials are properly classified, described, packaged, marked and labeled and are in proper condition for trans-portation according to the applicable regulations of the Department of Trans-portation. 1) Reviewed By Date / 7/ / Radioactive Waste Coordinator [ .+

._. A.

  • J 25 AT17CINCtr '10 SilIPPI!X; PAPERS For " Exclusive Use" shipnents of Radioactive Materials.

Instructions to Shipper. 1. Shipnent is to be delivered to Consignee without reloading. 2._. Exclusive Use means this vehicle is to transport only those matenals loaded by AP&L. 3. Material is to be unloaded by consignee. 4. Trailer must be cleared by consignee to ensure radiaticxs and contaminaticsn levels are within specification prior to releasing trailer for other use. 4 ~ 5. In the event of accidents, leaks or unusual delays,.nake required report to Departrent of Transportation and notify AP&L as soon j ', as possible. Make notifi.ution to AP&L by calling 501- % 8-7410 day or night. , f n ..J j ' 6. Keep these instructicns with the shipping papers.

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