ML20005B650
| ML20005B650 | |
| Person / Time | |
|---|---|
| Issue date: | 06/26/1981 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Sturm J Sturm, J.L. MD |
| Shared Package | |
| ML20005B651 | List: |
| References | |
| NUDOCS 8107080489 | |
| Download: ML20005B650 (2) | |
Text
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REGION 111 799 ROOSEVELT ROAD 1
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JUN 2 61981 aq )s.
Joseph L. Sturm, M.D.,
Inc.
License No. 13-1 86 01 2
P O. Box 592 Hartford City, IN 47348 Gentlemen:
This is to acknowledge your letters dated July 8, July 16, August 5, and December 29, 1980, and January 16, 1981, informing us of the steps you have taken to correct the noncompliance identified in our carrespondence dated June 26, August 5, and October 17, 1980.
This letter also references the telephone conversations between Mr. W. P. Reichhold of this office and Mr. Wayne Mertes of your staff on January 22, and May 12 and 13, 1981, concerning your corrective actions mentioned above.
It is our understanding that the following additional actions will be taken:
1.
Personnel will be provided with a whole body film badge and a finger badge before they elute generators or administer patient doses.
2.
In the absence of film badge results, you will make an evaluation of the radiation exposures to ensure they are within Part 20 limits.
A record of the results of these evaluations will be kept for review by the Commission.
3.
A semiannual review of the daily and quarterly constancy checks of the dose calibrator will be performed by you or your consultant to ensure that the dose calibrator checks have been performed.
4.
A semiannual inspection of the hot laboratory area will be performed by you or your consultant to ensure the posting requirements in Part 19 have been met.
5.
You will use a properly calibrated replacement G-M survey meter until your Eberline E-520 and Ludlum 3 survey meters are calibrated and returned from the manufacturer.
If our understanding of the above is incorrect, please contact William P. Reichhold or Donald J. Sreniawski at 312-932-2500.
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IO1070BO489 010626
NMS LIC30 U13-17296-01 PDR
.e Joseph L. Sturm, M.D.,
Inc. M26 W Item 7 of your letter dated December 29, 1980, states that film badge reports for a technclogist were not available for the period October 1977 to December 1978 because this technologist was not employed by you during this period. Accordingly, we will delete this item of noncompliance from our records.
We'are concerned that fcM using our initial notice of violation and subsequent enforcement conference, multiple letters and telephone con-Tersations have been required to obtain an underseding of your corrective actions. This raises questions :n to the degree of control you have exercised in assuring that regulatory requirements are being met.
We plan to conduct a reinspection of your licensed operations to review these corrective actions. Continuing violations resulting from ineffective corrective actions will result in consideration of the issuance of civil penalties.
Sincerely, James G. Keppler Director cc: Wayne Mertes, R.T.
cc w/ltrs dtd 7/8, 7/16, 8/5/80 & 1/16/81:
DMB/ Document Control Desk (RIDS)
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Sirs; In res. se t: yttr IE 521etin 79-19, (au;rst '.7, 2???),e dc n:t shi, ar, Icv-level radicactive vaste for burial. Cur low-level rsdioactive we.ste in stcred in a le:1 shi-ided sres u P.12 it has decc.yed devn te back;round level. This is c:nfinM +y.cnit:rir; the vsste with a s'.m ey : eter. The vaste is then dit-esed f by eblit rmtia.; t'e radiatior s,rM2 and thr:vn in vitt the no:-$.1 tras :.
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1 F.t. :xa 592 Frrtferd City, Ind'ana J k s July 2i, 1990 Jees G. Fe pier, Jirect r t'.
- 5. Nuclear Re;f aterr Co.:-issien P.e;ier III
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Dear Mr. Ee-rler,
Ir are:: dar.ae vitr the c:rvisiens of 3< ctien 2.pra of tre,rix n:;,;cs ef tractice", ?=.rt 2, Title ;r', C:de of Federal.:.e ulatiens. I Pr hareby s&.dtt'.n; a vri; ten stater. ant er erlanatien ir reoly te each ite- :f n:nce rlience f:vnd drin; the ins,eetier :f -- '.icense n.rter 13-27:46/1 c nducted b:
.'. I.eich':2d er June 3 and 4, 1930 and dea:ribed in Appendix A t: ycur letter of J re 2e,19E te *:.: are aware, T the, the irs-action findin;s and our cerractive actirn* vere d'seussed with rerrasentatives fr-- the ' T Cffice c' Ir.spectier ard trf:rre ent :r J *, 2 9 'O.
Infractien I.
C:ntra'y te the license a.9 licatien, t he UJ-99/Te-?t renerater 5.a* beer rece'~ed =rd st red at :'ackf:rd C:un*- Wsrita.' fr:- Suniry :rnin; *:
--day - rninc ener vem since 1:a:, 2 0"'
t: J ;-e, 19 20.
(1) Cer-eetive e eti:r taken and tr e res f t e ael ' e"-d :
"ne st:n i-crier fr
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A.n m d. t -e-ce:t wa: - 1, c.t eu :n July 7,1980 to indentify the 2143 West Wahington Street, Hartforti City, Indiana 47348 address as an authorized location of use. Mallincrokt will not ship the generator to this address until the license as been amended.
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l Infraction III.
Licensed :saterial is used at 216 Washington Street, Hartford City, Indiana, a location not authorized by the license.
(1) Corrective action taken and the results achieved:
The correct address of the hot lab is 2143 West Wahington Street, Hartford City, Indtann 47348. On July 7,1980 an a:nendment request was sent requesting that this address be added as an authorized location of use. Until the license is amended there is no licenseed material being delivered to this address.
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(2) Corrective action taken to avoid further non-cogliance.
( see above)
(3) Se date when full m14mnee will be achieved.
m enever the license amentment is received.
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Infraction III.
Contrary to lo CFR 20.201 (b) one individaul who works l
in controlled areas, slutes generators, and administers l
patient doses did not have a whole body badge or a finger i
badge for a two month period starting 12-79 thru l-80 nor was evaluattde of the whole body made for a two month period starting 12-79 thru l-80.
(1) Corrective action taken and the results achieved.
l An average mnthly exposure based on badge reports already recieved for Feburary, March, April, and May,1980, will be computed and includei in the l
pernament record. Se average monthly exposure was determined to be 10 =1111reas whole body and 7 millirems fingers These exposuree will be taken as estimated I
exposures for 12-79 ami 1-80.
(2) Corrective action to be taken to avoid further nonopspliance.
The above estimated exposures for 12-79 ani 1-80 will to forwarded to IAndauer to be added to the individual's lifetime exposure.
(3) Date when full ecg liance will be achieved.
The radiation dose for 12-79 an! 1-80 where estimated on July 16, 1980.
Full ccepliance will be achieved when these estimated are forwarded to TaMauer.
Infraction IV.
Contrary to the license application the last calibration of the Eberline, model E-520, serial amber 895 survey I
meter was on December 21, 1976. The Ludla, model 3 l
survey meter has not been calibrated since date of license issuance.
1 (1) Corrective action taken and results achievai.
The Eberline, mdel 3-520 has been return.1 to the manufactureer for repair l
and onlibration. Also the frv11'= 3 has been returned to the manufacturer for repair ami calibration.
(2) Corrective action taken to avoid further non-ocupliance.
Een the survey meters are returned frce the manufacturer the nuclear medicine technologist will make a note of the due date for subsequent calibration ani will subsequently have the survey meters calibratai at the appropriate time.
(3) Date when full compliance is achieve 1.
M en survey meters are returned from the manufacturer.
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' Intranion V.
Contrary to t'.ne license applf aation daily measurements of the dese calibrator were not per-formed using Cs U7 aM Co 60 standards, nor was a Co 60 source avaible. Quarterly checks of a variety of settings on the does calibrator using a Co60 or a Ce U7 staMard ':%r a not performed in March 1980 nor were records kept of the previous quarterly checks kept.
(1) Corrective action taken and the results achieveds m en the M 9%aton street address is added to the license as as cuthorized place of use the necessary Cs U7 and Co 60 does calibrator standards will be ordered. Upon receipt of these sources they will be used for daily measurements of the dose calibrator. Se Ce U7 etwnd will be measured on colected dose calibrator settings, gpon receipt and subsequently at quarterly fatervals.
(2) Corrective action to be taken to avoid further non-cosylinwe.
( see above)
(3) S e date when full etapliance will be achieved.
l M en the license is amended to include the Washington street address as an authorized place of use and the sources are rec Mved.
Contrary th the license application a graph of Infraction VI.
the results of the linearity tests of tJ e dose calibrator were not kept from date of. newe issuance.
(1) Correttive action taken and the results achieved.
Linearity cheeks were pesformed on Janurary, March, and June of 1980, but the results were not graphed. Rese data have subsequently been plotted on semilng graph paper.
(2) Corrective action to be taken to adtd further noncompliance.
Se results of future linearity tests will be graphed.
(3) Date when full compliance will be achieved.
July 17, 1980 Contrary to 10 CFR Section 20.401 (a) theie Deficiency VII.
were no exposure records for an individual from October 1977 to Feburary 1978.
(1) Corrective action taken and the results achieved.
Badiation Detection Company was contacted on July 8,1980 at which time we requested that they forward the required exposure records. Rese have not yet been received.
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(2) Corrective action to be taken to avoid further noncompliance If the required esposure records are not avaible from Radiation Detection Compaq, an estimate of the individual's exposure will be made.
(3) Date when full compliance will be achievoi.
Idhen the required recoMs are received from Radiation Detection Compag.
De2iciency VIII.
Contrary to 10 CFR Section 20.407 the statistical esman y report of menitoring information for 1978 and 1979 was not sutaitted within the first quarter of the calender years 1979 and 1980.
(1) Corrective action taken and the results achieved:
Statistical summary reports of monitoring information for 1978 ami 1979 will be submitted on July 20, 1980.
(2) Corrective acvion taken to avoid further noncompliance:
k ne required.
(3) Date when full ocepliance win be achieved:
July 20, 1960 Deficiency VIIII.
Contrary to 10 CFR 19.11 required doctments and notices were not posted &n the hot lab.
l (1) Corrective action takes and the results achieveds A form I?BC 3 has been posted in the hot lab. Also, a notice has been posted describing Part 19, Part 20, license conditions, documents incorporated into the license, license amendments and operating procedures and where they may be s-amined.
(2) Corrective action to be taken to avoid further noncompliance.
See above.
(3) The date when full compliance will be achieved:
June 25, 1990 If there are av further questions feel free to contact me at the Blackford County Hospital ( 317-349-0300)
Sincerely, k
k(b WP Jonest Sturm, M.D.
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