ML20042A333
| ML20042A333 | |
| Person / Time | |
|---|---|
| Issue date: | 03/16/1982 |
| From: | Wiedeman D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20042A324 | List: |
| References | |
| NUDOCS 8203230334 | |
| Download: ML20042A333 (2) | |
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Appendix NOTICE OF VIOLATION Village of Oak Park License No. 12-18560-01 As a result of the inspection conducted on March 10, 1982, and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7, 1980), the following violations were identified:
1.
License Condition No. 13A requires that you test your sealed sources containing byproduct material for leakage and/or contamination at intervals not to exceed six months.
Contrary to this requirement, as of the date of the inspection, you had not tested your sealed source Nos. CAA-1683 and CC-2636 for con-tamination or leakage since March 19,1979,a period of more than six months.
This is a Severity Level V violation (Supplement VII).
2.
License Condition No. 17 requires that you conduct a physical inventory j
every six months to account for all sealed sources used or possessed, and that you maintain records of these inventories to include the quan-tities and kinds of byproduct material, location of sealed sources, and the date of the inventory.
Contrary to this requirement, as of the day of the inspection, inven-tories had not been conducted since the inception of this license.
This is a Severity Level V violation (Supplement VII).
3.
10 CFR 71.5, " Transportation of licensed material" states "no licensee shall transport any licensed material outside of the confines of his plant or other place of use, or deliver any licensed material to a carrier for transport, unless the licensee complies with the applicable requirements of the regulations appropriate to the mode of transport, of the Department of Transportation in 49 CFR Parts 170-189.
49 CFR 172.200 states in part, "each person who offers a hazardous material for transportation shall describe the hazardous material on the shipping paper in the manner required by this subpart."
Contrary to the above requirements, you transported byproduct material without proper shipping papers. Specifically, your shipping papers did not contain the following required information:
8203230334 820316 NMS LIC30 12-18560-01 PDR
e b
Appendix 2
a.
The proper shipping name, " Radioactive Material - NOS", 49 CFR 172.202(a)(1).
b.
The trar. sport index assigned to each package, 49 CFR 172.203(d)(v).
c.
The category of the label applied to each package in the shipment, 49 CFR 172.203(d)(iv).
d.
The level of radioactivity contained in each package of the shipment, 49 CFR 172.203(d)(iii).
This is a Severity Level V violation (Supplement VII.
4.
10 CFR 71.5, " Transportation of licensed material" states "n-licensee shall transport any licensed material outside of the confines of his plant or other place of use, or deliver any licensed material to a carrier for transport, unless the licensee complies with the applicable requirements of the regulations appropriate to the mode of transport, of the Department of Transportation in 49 CFR Parts 170-189.
49 CFR 173.394(a)(1) states in part, that each shipper of a Specifi-cation 7A packaging must maintain on file a complete certification and supporting safety analysis demonstrating that the construction methods, packaging design, and materials of construction are in com-pliance with the specification.
Contrary to this requirement, you transported byproduct material in a Troxler surface moisture density gauge (Serial No. 5561) a device that does not meet the packaging specifications for transport.
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 thirty days of the date of this Notice a written state-ment 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 compliance will be achieved. Under the authority of Section 182 of the Atomic Energy Act of 1954, as amended, this response shall be submitted under oath or affirmation. Consideration may be given to extending your response time for good cause shown.
3!S M Date D. G. Wiedeman,9 Acting Chief Materials Radiation Protection Section 1