ML20011F237
| ML20011F237 | |
| Person / Time | |
|---|---|
| Issue date: | 02/12/1990 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20011F236 | List: |
| References | |
| 1500042-90-01, 1500042-90-1, NUDOCS 9003020188 | |
| Download: ML20011F237 (2) | |
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g APPENDIX pf NOTICE OF VIOLATION sa +
Raba-Kistner Consultants, Inc.
Docket:
15000042/90-01
During=an NRC inspection conducted on January 22, 1990, violations of NRC
- requirements were identified.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C-(1989)L(Enforcement Policy), the violations are listed below:
IL ' 10: CFR 150.-20(b) provides, in part, that persons who hold a specific
- license _.from an Agreement State are granted an NRC general license to conduct the same activity-in a non-Agreement State provided the general.
licensee complies with 10 CFR Part 71.
l 10'CFR. 71.5(a) requires that no licensee deliver any licensed material;to i
a carrier for transport without complying with the applicable requirements i
of'the regulations appropriate to the mode of transport of the Department i
of Transportation (DOT) in-49 CFR Parts 170-189.
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.49 CFR 172.200. requires, in part, that each person who offers a hazardous mat'erial for transportation describe the' hazardous material on a shipping paper.
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' Contrary to the above, when interviewed, the licensee's operators and 1
RSO stated that shipoing papers were not prepared when licensed i
material was transported by them when they did work on federal installations, i
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'49 CFR-172.300 requires, in part, that each person who offers a p~
hazardous material for transportation mark each package containing j
the hazardous material. in the manner required by 49 CFR 172.301:
-j and 172.310' j
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' Contrary.to the above, during 1989 and 1990, the licensee transported moisture / density gauges containing. licensed material in wooden boxes i
that'had.the appropriate labels, but did not contain the proper l
shipping name, the identification number, or the appropriate j
specificatior number, all of which are required by 49 CFR 172.301 and
-l 172.310.
j This Is' a Severity Level IV violation.
(Supplement V)
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2, 10 CFR-150.20(b)(3) requires, in part, that a licensee may not possess or use licensed materials for more than -180 days in any. calendar year under the. General License provided in 10 CFR 150.20.
. Contrary to the above, during calendar year 1989, the licensee used lictr.s ef material in portable gauging devices for approximately 214 days on federal: installations under the General License.
This is a Severity Level IV violation.
(Supplement VI) i Pursuant to the provisions of 10 CFR 2.201, Raba-Kistner Consultants, Inc., is
.hereby required to submit.to this office, within 30 days of the date of the letter transmitting.this Notice, a written statement or explanation in-reply, i
including for each violation:
(1) the reason for the violation if admitted, (2) the corrective steps-which have been taken and the results achieved, (3) the corrective steps which will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending the response tina.
'I Dated at Arlington, Texas,.
this 12th day of February 1990 i
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