ML20009A605
| ML20009A605 | |
| Person / Time | |
|---|---|
| Issue date: | 06/08/1981 |
| From: | Wiedeman D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20009A602 | List: |
| References | |
| NUDOCS 8107130363 | |
| Download: ML20009A605 (3) | |
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e Appendix A NOTICE OF VIOLATION Cherry Electrical Products Docket No. 12-15880-01 Corporation Docket No. 12-15880-02E As a result of the inspection conducted on May 21, 1981, and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7, 1980), the following violations were identified:
1.
10 CFR 20.201(b) requires that such surveys be conducted as may be necessary for the licensee to comply with all sections of Part 20.
Contrary to this requirement, it was learned through statements of licensee representatives you failed to perform surveys to ensure com-pliance with 10 CFR 20.105(b), a regulation which limits the radiatica levels in unrestricted areas.
Specifically, you failed to perfrom surveys in the unrestricted area around the krypton-85 storage container.
This is a Severity Level V violation (Supplement IV).
2.
10 CFR 20.105(b) requires that radiation levelt, in unrestricted areas be limited so that if an individual were continuously present in the area, he could not receive a dose in excess of 2 millirems in any hour or 100 millirems in any seven consecutive days.
Contrary to this requirement, it was learned from measarements by the inspector on May 21, 1981, that the radiation levels were in excess of 2 millirems in a hour in the unrestricted area around the krypton-85 storage container.
This is a Severity Level V violation (Supplement IV).
3.
License Condition No. 8 states you may not possess more than 5 curies of krypton-85 gas at any one time.
Contrary to this requirement, on May 21, 1981, your possession of krypton-85 gas exceeded the 5 curie limit.
Specifically, 6.5 curies of krypton-85 gas was in storage and 1.2 curies of krypton-85 gas was in the display tube filling area.
This is a Severity Level V violation (Supplement VII).
8107130363 810608 NMS LIC30 12-15880-01 PDR
e Appendix A 4.
License Condition No. 13 requires that licensed material be possessed and used in accordance with statements, representations, and procedures contained in application received November 12, 1978.
License application received November 22, 1978, states that the G-M survey meter shall be calibrated quarterly.
Contrary to this requirement, it was learned through statements of licensee representatives and a review of records that the EON model PSM 760 survey meter was last calibrated on April 21, 1980.
This is a Severity Level V violation (Supplement VII).
5.
10 CFR 20.203(f)(1) and (2), requires that t.ch container of licensed material bear a durable, clearly visible label bearing the radiation caution symbol and the words " Caution, Radioactive Material," and identify the radioactive contents.
Contrary to this requirement, a container used to store krypton-85 gas cylinders was not labeled as required.
This is a Severity Level VI violation (Supplement IV).
6.
10 CFR 71.5(a) requires that no licensee shall transport any licensed material outside of the confines of his plant or other place of use unless the licensee complies with the applicable regulations of the Department of Transportation in 49 CFR Parts 170-189.
A.
49 CFR 172.203(d)(V) requires that the shipping papers for shipping radioactive materials must include the transport index assigned to each package bearing Radioactive Yellow-II labels.
l 49 CFR 173.389(i)(1) defines transport index as the highest dose rate in millirem per hour at three feet from any accessible external surface of the package.
Contrary to these requirements it was learned through statements of licensee representatives and a review of records that the transport index was recorded on the shipping papers in units of microroentgens. The transport index dose rate recorded on the shipping papers was for full krypton-85 gas cylinders instead of empty krypton-85 gas cylinders.
B.
49 CFR 172.204(a) requires each person who offers a hazardous i
material for transportation shall certify that the material offered for transportation is in accordance with this subchapter by printing the following statement on the shipping paper contain-ing the shipping description:
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Appendix A
- This is to certify that the above-named materials are properly classified, described, packaged, marked, and labeled, and are in proper condition for transportation according to the applic-able regulations of the Department of Transportation.
Contrary to this requirement, it was learned through a review of records that the shipper's certification as described above was not printed on the shipping papers.
This is a Severity Level VI violation (Supplement V).
7.
License No. 12-15880-02E referencing letter dated February 4, 1981, states that daily monitoring of the radiation levels in the areas where krypton-85 is used shall be performed usic-g a G-M sur" y meter.
Contrary to this requirement, it was learned through statements of licensee representatives you failed to perform daily G-M surveys in the areas where krypton-85 is used.
This is a Severity Level V violation (Supplement VII).
Pursuant to the provisions of 10 CFR 2.201, you are required to submit to this office within twenty-five days of the date of this Notice a written statement or explanation in reply, including for each item of noncompliance:
(1) corrective action taken and the results achieved; (2) corrective action to be taken to avoid further noncompliance; and (3) the date when full com-pliance will be achieved. Under the authority of Section 182 of the Atomic Energe Act of 1954, as amended, this response shall be submitted under Oath or affirmation.
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Dated b ~S~N
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/ df D. G. Wiedeman, Acting Chief Materials Radiation Protection l
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