ML20012H570

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Forwards Insp Rept 15000041/95-01 on 950828.One Violation Noted & Being Considered for Escalated Ea.Predecisional Enforcement Conference to Discuss Violation Scheduled for 950925
ML20012H570
Person / Time
Site: 15000041
Issue date: 09/11/1995
From: Mallett B
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To: Swindell D
External (Affiliation Not Assigned)
Shared Package
ML20012H571 List:
References
EA-95-187, NUDOCS 9509220169
Download: ML20012H570 (2)


See also: IR 015000041/1995001

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EA.95-187.

September 11, 1995

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Energy Technologies, Inc.

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= ATTN: Mr. David K. Swindell-

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President

P.O. Box-23860.-

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127 Perimeter Park Drive

Knoxville,: Tennessee _' 37933-1860-

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SUBJECT: NRC INSPECTION REPORT NO. 150-00041/95-01

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Dear Mr. Swindell:

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This refers to the inspection conducted on August 28, 1995 at your office in

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Knoxville, Tennessee. The purpose of the inspection was to determine whether

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activities conducted m ?reas of NRC jurisdiction were in accordance with NRC

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requirements. At the conclusion of the inspection, the findings were

discussed with you.

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Areas' examined during the inspection are identified in the report. Within

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these areas, the inspection consisted of selected examination of records,

interviews of personnel, and review of corrective. actions taken to date.

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Based on the results of this inspection, one apparent violation was identified

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and is being considered for escalated enforcement action in accordance with

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the " General Statement of Policy and Procedure for NRC Enforcement Actions"

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(Enforcement Policy), (60 FR 34381; June 30,1995/NUREG 1600) (Enclosure 2).

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The apparent violation being considered for escalated enforcement involves the

use of a byproduct material in areas under NRC jurisdiction without possessing

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an NRC general or specific license.

In addition, the apparent violation also

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appears' to involve an element of careless disregard for NRC regulations.

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Acccrdingly, no Notice of Violation is presently being issued for this

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inspection finding.

In addition, please be advised that the number and

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characterization of the apparent violations described in the enclosed

inspection report may change as a result of further NRC review.

A predecisional enforcement conference to discuss the apparent violation has

been scheduled for September 25, 1995 at 1:00 p.m. in the NRC Region II

office. The decision to hold a predecisional enforcement conference does not

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nean that the NRC has determined that a violation has occurred or that

enforcement action will be taken.

This conferance is being held to obtain

information to. enable the NRC to make an enforcement decision, such as a

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common understanding of the facts, root causes, missed opportunities to

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identify the apparent violation earlier, corrective actions, significance of

the issues and the need for lasting and effective corrective actions.

In

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particular, we expect you to address why you performed licensed activities

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within NRC jurisdiction, after you were informed that ETI was required to

submit NRC Form 241 to the Reaion 11 office. In addition, this is an

9509220169 9509119;

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Energy Technologies,-Inc.

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opportunity for you to point out any_ errors in our inspection report and for

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you to provide any information concerning your perspectives on 1) the severity

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_ of the violation, 2) the application of the factors the NRC considers when it

determines the amount of a civil penalty that may be assessed in accordance

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with Section VI.B.2 of the Enforcement Policy, and 3) any other application of

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the Enforcement Policy to this case, including the exercise of discretion in

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accordance with Section VII.

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You will be advised by separate correspondence of the results of our

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deliberations on this matter. No response regarding the apparent violation is

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required at this time.

In accordance with 10 CFR 2.790 of the NRC's " Rules of Prac'tice," a copy of

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this letter and its enclosures will be placed in the NRC Public Document Room.

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Sincerely,

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Original Signed By

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D. M. Collins for

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Bruce S. Mallett, Director

Division of Radiation Safety

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and Safeguards

Docket No.:

150-00041

License No.: General License

EA 95-187

Enclosures:

1.

NRC Inspection Report

150-00041/95-01

2.

NRC Enforcement Policy:

NUREG-1600

cc w/encls:

State of Tennessee

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Distribution w/encls:

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J. Lieberman, OE

Document Control Desk

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Ril Docket file, DRSS

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(SEE NEXT PAGE FOR ALL CONCURRENCES)

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ncerning your perspective on 1) the severity of the violation, 2) the

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ap ication of the factors that the'NRC considers when it determines the

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of a civil penalty that may be assessed in accordance with Section

VI.B.2 f the Enforcement Policy, and 3) any other application of the

Enforcem t Policy to this case, including the exercise of discretion in

accordance ith Section VII.

You will be ad sed by separate correspondence of the results of our-

deliberations on. his matter. No response regarding the apparent violation is

required at this t

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In accordance with 10

R 2.790 of the NRC's " Rules of Practice," a copy of

this letter and its enc

ures will be placed in the NRC Public Document' Room.

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Sincerely,

Bru

S. Mallett, Director

Divis' n of Radiation Safety

and

feguards

Docket No.:

150-00041

License No.: General License

EA 95-187

Enclosures:

1.

NRC Inspection Report

150-00041/95-01

2.

NRC Enforcement Policy

cc w/encls:

State of Tennessee

Distribution w/encls:

J. Lieberman, OE

Document Control Desk

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