ML20028F167
| ML20028F167 | |
| Person / Time | |
|---|---|
| Site: | 07000734 |
| Issue date: | 01/07/1983 |
| From: | Mowry W GENERAL ATOMICS (FORMERLY GA TECHNOLOGIES, INC./GENER |
| To: | Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20028F163 | List: |
| References | |
| 696-4034, NUDOCS 8301310199 | |
| Download: ML20028F167 (4) | |
Text
- '
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r av p,,i g s In T8pi?
b9@-g4 Refer To:
GA Technologies Inc.
7 January 1983 gDc[Ojg,,/, ;
P o BOX 81608 SAN DtEGO. CAUFORNIA 92138 (619)4 %-3000 Mr. R. H. Engelken Office of Inspection & Enforcement U.S. Nuclear Regulatory Commission Region V 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596-5368
Subject:
Docket 70-734 SNM-696: Notice of Violation Required Response.
Reference:
(a) NRC ltr Docket 70-734 dated 12/8/82.
Dear Mr. Engelken:
This is in response to your letter, ref. (a), which includes a notice of violation relating to the Department of Transportation requirements of 49 CFR 170-189 incorporated by reference in NRC's regulation 10 CFR 71.5.
Your notice follows an inspection by your staff into a matter where two of several boxes containing contaminated equipment arrived at the Barnwell, S.C. waste disposal site with holes in them.
Appendix A of reference (a) requires a written statement which includes certain responses. Our statement is as follows:
Your letter, ref. (a), Appendix A, states: " Contrary to the above, one container in the shipment (Crate No. 28675) had con-taminated scrap sticking out of three of eight holes in the con-tainer." This is not consistent with our understanding.
Based on information made available to us we are not aware of any con-taminated scrap items which were sticking out of the boxes.
In-formation given to us indicates that there were eight holes which exposed the scrap but that no significant radioactivity was found in the immediate area surrounding the holes. There was also no evidence of any noticeable contamination in the truck bed. We concluded from this that the holes were caused by abrasion from the vibrations and small impacts generated during the long travel across the country to South Carolina. The boxes were disposed of at the Barnwell site after wood patches were placed over the holes.
To avoid further non-compliance our NMM staff has reviewed the appropriateness of the package designs to meet the strong tight packages requirements for LSA material. Further, the incident and its probable cause was brought to the attention of all em-ployees involved in either package selection or material pack-aging. These employees have been cautioned to be alert to 8301310199 830125 PDR ADOCK 07000734 C
./
R.H. Engelken 1/7/63 future possibilities of any heavy compact object that might, during travel damage a container which was strong and tight when loaded. We paid South Carolina their prescribed penalty, re-viewed our packaging, and instructed the appropriate employees by October 15, 1982 and we believe we were in compliance from that date.
We are hopeful that our corrective actions are adequate for this incident and that our response clarifies our position in the matter. Should you have information which has not been made available to us but significant-ly alters the appropriateness of our actions or response, please provide a copy of it.
Should you have any additional questions or comments, please don't hesitate to contact me at (619) 455-2823 or this address.
Please note the new postal zip code for GA Technologies Inc. is 85608.
Very truly yours, William R. Mowry Licensing Administrator WRM:he 4
I
rollfit carol.INA DEPARTftE?rr OF IIEAtr!! AND ENVIR0m!ErffAL C0tifROL _
/
iDn eau of Radiological lie alt h Division (f inactivo Material Licanainr, an.
ompliance 2
Fadilict ive Shipment Itu;pection Report--
'..Gyncral Inf ore atien:
nen.rt No.
82-09-03
- 1. Name of Shipper:-San liiego, TalifoF6Ta ~ Tvre Package / Cask Model:
General Atomic Company
/ d.f rt r. s :
Flat Bed
.'. t arrier:7 hem-t[iTc~ lear S'js tems
__,, M containing: M arge crates
~ ~
s Tractor >>
12
,_, f r a i le r l# 009 type _ flat bed
- 4. Shipping Documentation:
. ESR'l 33852 vot. Allor.!! 0932-120-A Pe rm t t ri 0118-04-82-X
- 2. Shippinc :!ame and Claaa:..Raiingti3e_slerial. LS A h0S ItM rd.p tItiT9T2 (172.202(aT' u
T. Toa.a1 Volume:,,199_1R (172.202(c)) retal curies: 0.0024686, (172.203(d) re
. HadIonaclides:. U-235 U.238..iuld Th-232 Labels NA (172.203(d)
- 5. Cescriation(chen/phy/ media):50 lid _QX}.dgs on metal, air filters, wood, plasMcs,(172.203(d)
- 6. Shippers Certificaticn: State (48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />)
N DOT N (172.204)
- 7. T.:o:1usive "uha_ Instruct ion h(173.392(c))(173.393(j))or Total T.1.
NA (177.842(a)
- 3. Check for:(a) Radiation Survev c(173. 393(i)(j)) Contamination leveD N (173.397)
". Cc.c.pa ro : Radienuclides w/resta aaalysisNA Radiation / Contamination levels w/CNSI/BRH %.,_
Fhiprent.faspectir,n Check List: _ _. -. _ _
>.ckagina: Ltd. Qty / devices 7'I.391,1.SA 173.392,Ceneral 173.393,Special form,173.394,
- formal form 173.395,Fianile 173.396
,fjA ecurity Seals (173.393(b))
1 Lids (Drum, box, cask) secure (173.393(n)(6))
7 hip. tent T, raced /Bi cck ed (173. 392 (c ) /177. 842 (d)) XJi s ib le Daciage (173. 393 (d ) )
.J_? t sible Leakage (173.392(e)/173.393(d))
rg,, Cask Defects / Missing parts (173.398)
..jpckaro tabelinn/Wh_ I. Ye1 II,III (172.403) v3adiation Survey (173.393(j))
6'SadicmM e LSd (173.392(c))
Cab / sleeper, trailer / track
.sr NAircss Licight mrked(17,3!O)$.SA E.<.uae Exempt)MContamination Levels (171. 397) hA#ype A/ Tyre B packa.:e marked (172.310)
,t, vehicle Placarde (173.392(c))/172.512) a_ Trailer /~ractor Defects N !iedowns secure / adequate
?ackageujanded} reinforec(,[palleti::ch
_0ffloading Discrepancies
,3
.:-- :- :: = r.: =- - - - -_.. __ := :: _- e.:.,. _ __. -
._.._=:-
'. Radiat.ic./ Conte.minat ion Survey:* ;t ransport vehicle or package)
"R/h 1 Furface:
2,Q_
2 metera:
Eurface:
Cub / steeper Surface:
~
m t e rs :
2 meters:
Surface:
?.0 2 netern:
QJ,L Highest Cont.mination Detected: Arrival 0_
.dem/100cm2 Release adpm/100cm 16 ttydpm/100cm2 Bydpm/100cm 8.. Results of Inspection f tc.tmary of vic 1ations anc. di.;cce sancles Jtate_!28&r had_ca11tatillated scrao stieking a..
Ont.nl.threa <p01.5. and_0CQ10 tllt0U9b t.lle PIMitgd in._the fourth soot 1_.lb.erefore. this cnntaier was _ nnt a strong tight _cantainer.
This is in violation of DOT 49 CFR 171.393 (lll(ll..ani.113.392(Q{D
~
{Use Suppl?>mentary Sheet if necessary)
Date: September 13, 198?
Inspector's Signature s / Richard S. Sanoington DHEC S10 (11/81)
[
pum I
Ra.i tonc t f.
Shipment In::p.?ction Heport Suppleacnt Information Repqrt No.: 82-09-03 ssR# 308i2 Permit #
0118-04.-82-X 7.
Outline any addition 21 information, facts, circumstances, etc., which nas bearing on the inspection:
Additional facts found on offloading this 5 crate shipment:
As the tarp was being rolled back, four (4) additional holes were found in crate #28675; the total holes in this crate are eight (8).
The largest h"le was big enough to get your hand into. See attached ~ photo.
- Also, o
crate #28676 had tnree (3) holes in it. The total holes in the two boxes are eleven (11). Smears were taken around the holes and are attached.
P' Sep.e:nber 15, 1982 Date:,
Inspector' ::Ignature.J/ Richard S. SaDDin0 ton Cllt:C ElO (11/81)
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