ML20044G195
| ML20044G195 | |
| Person / Time | |
|---|---|
| Issue date: | 05/21/1993 |
| From: | Barry M, Caniano R, Holt B, Wagner S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20044G191 | List: |
| References | |
| REF-QA-99990003-930521 99990003-93-05, 99990003-93-5, NUDOCS 9306020156 | |
| Download: ML20044G195 (28) | |
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U.S. NUCLEAR REGULATORY COMMISSION i
REGION III i
Report No. 99990003/93005(DRSS)
Docket No. 99990003 General License (10 CFR 31.5)
Licensee:
Steel Warehouse Company, Inc.
2722 West Tucker Drive t
South Bend, IN 46624 Inspection Conducted: April 22 - 30, 1993 Inspection At: Steel Warehouse Company, Inc.
South Bend, Indiana Inspector:
, (/
A6hs 5
S vWagner
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Date RadiationSpebia) list d -/L I%//9d Inspector:
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/M.~ Barfy
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Date'
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Radip{ ion Specialist Reviewed By:
7 M
S~~/a//f8
'B. J. l%1t, Chief Date/
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Nucleaf Materials Safety Section 1 Approved By:
w,gd.
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J Caniano, Chief Date N
r Materials Safety Branch Inspection Summary Inspection on April 22. 1993 (Report No. 99990003/93005(DRSS))
Areas Insoected: This special, announced safety inspection was conducted to review an incident involving the unauthorized removal and improper transport of a damaged fixed gauging device containing a' one curie Am-241 sealed source.
The inspection included interviews of personnel, a tour of the licensee's facilities, independent measurements, and discussions with the manufacturer of the gauging device.
Results: Three apparent violations were identified and ' consist of: (1) removal of a fixed gauging device containing licensed material by unauthorized t
persons (10 CFR 31.5(c)(3)); (2) failure to comply with the requirements for transporting radioactive material (10 CFR 71.5(a)); and (3) failure to submit 1
a timely report to the NRC. regarding damage to the gauging device l
s 020156 930gy3 99990j p EEC*
DETAILS i
1.
Persons Contacted Steel Warehouse Company. Inc.
- Mr. David Dopp, Engineering & Maintenance Manager
- Mr. Jerry Czajkowski, Maintenance Superintendent
.*Mr. Ron Duerksen, Electrical Supervisor Mr. Rod Cochran, Electrician Mr. Kent Fuchs, Foreman Mr. George Paige, Gauge Operator Mr. John Uvalles, Gauge Operator Mr. Dave Ingle, Assistant Roller
- Denotes attendance at exit meeting held on April 22, 1993.
Contacted via telephone April 23 - 30, 1993.
Data Measurement Corporation
- Mr. Chris Burnett, Radiation Safety Officer
- Mr. Dino Jardina, Assistant Radiation Safety Officer
- Mr. Glenn Schultz, Field Service Representative
- Contacted via telephone on February 19, 1993.
- Contacted via telephone April 23 - 28, 1993.
- Contacted via telephone on April 30, 1993.
2.
Summary of Licensed Proaram and Inspection History Steel Warehouse Company, Inc., located in South Bend, Indiana,- is generally licensed to use byproduct material contained in thickness measurement devices. The licensee has three Data Measurement Corporation fixed gauging devices, each containing one curie of Am-241.
Two of the devices are located on large C-frames, and one device is fixed in the base of a temper mill. The licensee also has four x-ray devices manufactured by Data Measurement' Corporation.
t Steel Warehouse Company has not previously been inspected by the NRC.
I 3.
Discussion of Incident On the morning of November 29, 1992, the first-shift foreman observed that a fixed gauging device containing one curie of Am-241 was damaged.
t The device, manufactured by Data Measurement Corporation, Model l
Number AM-5A and Serial Number BS954804, was used for thickness; measurement. The damage occurred during the third shift while operators were processing a roll of steel. The end of the steel roll was bent, so 2
a pry bar was used to straighten it. The pry bar was caught by the t
steel, dragged down the process line and subsequently hit the fixed gauging device and broke its indicator window.
Upon noticing the damage, the foreman informed the electrical supervisor of the situation. At this time, power to the fixed gauging device was turned off at the operator control panel. The electrical supervisor, with the assistance of an electrician, removed the gauge from the temper mill during lunch break that same day. The removal took approximately 15 minutes during which time the electrical supervisor's body was about I foot from the source and the electrician's body was about 3 feet from l
the source. The decision to remove the gauge was made by the electrical supervisor, who had received basic radiation safety training from Data Measurement Corporation in late 1989. He estimated that approximately one day of this training was devoted to learning about isotope gauging devices. As a result, he knew that this device contained radioactive material, and that it had two shutters that needed to be closed. The electrician had not received any radiation safety training.
The electrical supervisor did not contact Data Measurement Corporation prior to the removal because he thought the gauge was initially installed by L'
workers at Steel Warehouse and could, therefore, be removed by the same.
The fact that Steel Warehouse installed this device was confirmed by Data Measurement Corporation on April 27, 1993. The device radiation safety manual, provided to the licensee by the manufacturer, states that installation by the licensee is permitted (Attachment 1).
Neither the licensee nor Data Measurement Corporation recalls if a label, prohibiting removal of the gauge by the licensee, was affixed to the l
device at the time of the incident.
During the milling process, water is sprayed over the steel.
Water
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entered through the broken indicator window of the gauging device and J
caused condensation to form on the window. As a result, the indicator i
could not be read to determine if the shutter was in the closed position.
This device has two shutters, one electronic and one pneumatic, both of which return to the closed position when power is lost.
By disconnecting the power prior to removing the device, the electrical supervisor was reasonably certain that the shutters were i
closed. As soon as the removal was complete, the electrical supervisor
{
took the device to a work area, removed a steel plate on its surface, and verified visually that the shutters were in the closed position.
}
The electrical supervisor instructed the electrician to call Data Measurement Corporation to obtain a return materials authorization for i
the damaged gauge. However, instead of stating that an isotope gauge l
would be returned, the electrician informed the device manufacturer that the device was an x-ray source. As a result, Data Measurement Corporation gave the electrician instructions for shipping an x-ray source. The electrician wrapped the device in bubble-wrap and placed it in a cardboard box filled with foam pellets.
It took the electrician i
approximately 15 minutes to complete the packaging.
He labeled the package with Data Measurement Corporation's address and placed it overnight in the shipping area. There was no labeling or marking to i
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indicate that the package contained radioactive material. The device radiation safety manual, provided to the licensee by the manufacturer, states that DOT requirements must be followed, but it does not explain i
specific marking, labeling, and packaging requirements (Attachment 2).
United Parcel Service picked up the package on November 30, 1992, shipped it via second day ground service, and delivered it to Data Measurement Corporation on December 2, 1992. No leak test was performed prior to shipment.
When the package was received and unpacked by Data Measurement Corporation, workers realized that the device contained a sealed source.
Because the indicator window was cracked, the device was disassembled within a plexiglass isotope handling box for added precaution.
It was noted that there was corrosion on the sealed source caused by the condensation which had formed on the interior of the broken indicator window. At this time a wipe test was performed, with results indicating no leakage of Am-241.
Data Measurement telephoned Steel Warehouse to inform them of the incident. Data Measurement Corporation confirmed that the device shutter was locked in the closed position when they received it from Steel Warehouse. No dose calculations were made because the exposure rate with the shutter in the closed position is less than 1 milliroentgen /hr on the surface.
The licensee notified the NRC Region III office of the incident in a letter dated Febru+ry 4, 1993 (Attachment 3). Upon receipt of the letter, NRC staff cantacted the licensee and Data Measurement Corporation to (1) ensure that there was no contamination or significant radiation exposure to personnel involved, and (2) verify the status of the device.
By letter dated February 19, 1993, Data Measurement Corporation provided the NRC specific information on the incident (Attachment 4).
4.
Evaluation of Incident The root cause of the incident appears to be a lack of. knowledge of the requirements of a general license. Also, the electrician did not understand the difference between isotope and x-ray gauges which lead to the miscommunication between the licensee and Data Measurement Corporation.
In general, the inspectors observed that Steel Warehouse workers referred to all gauges at the facility as x-ray gauges.
General licensees are not required to have formal training with respect to radiation safety. However, general licensees are required pursuant to 10 CFR 31.5(c)(1) to maintain all labels affixed to the device at the time of receipt which contain a statement that removal of the label is prohibited. General licensees are also required pursuant to 10 CFR 31.5(c)(1) to comply with all instructions and precautions provided by such labels. According to Data Measurement Corporation, a label similar to that contained in Attachment 4 should have been affixed to the damaged gauge. As previously stated, during the inspection, it could not be determined if the required labeling was affixed to the I
device in question at the time of the incident.
Representatives from Data Measurement Corporation could not recall if labels were affixed 4
i upon its receipt at their facility. Other general licensed gauges observed during the inspection were labeled properly pursuant to 10 CFR 31.5(c)(1).
10 CFR 31.5(c)(3) requires, in part, that installation and removal from installation involving radioactive materials be performed in accordance with the instructions provided on the label or by a person holding a 3
specific license. According to Data Measurement Corporation, the label affixed to a generally licensed gauge, similar to the one which was l
damaged, states that installation, relocation, and servicing of the device be performed only by Agreement State or USNRC specific licensees.
If the label is not present, these activities per 10 CFR 31.5(c)(3) must i
be performed by persons holding a specific license pursuant to NRC or Agreement State regulations.
In January 1990 the licensee installed one Data Measurement Corporation fixed gauging device, Model Number AM-5A and Serial Number BS954804, containing a one curie americium-241 sealed source. On November 29, 1992, they removed this device from installation. The licensee was not specifically licensed to perform 7
these services. The unauthorized installation and removal from installation of a fixed cauaina device containina radioactive material i
is an apparent violation of 10 CFR 31.5(c)(3).
10 CFR 71.5(a) requires each licensee who transports licensed material outside of the confines of its plant or other place of use, or who delivers licensed material to a carrier for transport, to comply with the regulations appropriate to the mode of transport of DOT in 49 CFR Parts 170 through 189.
Pursuant to 49 CFR 172.101, radioactive material is classified as hazardous material.
t 4
49 CFR 172.817(a) requires that a carrier not transport a hazardous material unless it is accompanied by a shipping paper prepared in accordance with 49 CFR 172.200 through 172.203.
49 CFR 173.465(a) requires, in part, that Type A packaging be capable of withstanding the tests described in Section 173.465.
49 CFR 173.461 requires, in part, that compliance with the test requirements in Section 173.465 be shown by methods prescribed in i
Section 173.461(a).
l 49 CFR 172.300(a) requires, in part, that each person who offers a hazardous material for transport mark each package containing the hazardous material in the manner required.
49 CFR 172.400(a) requires, in part, that each person who offers a package containing a hazardous material for transportation label it, when required, with labels prescribed for the material as specified in 172.101 and in accordance with 172.400.
5 r
On November 30, 1992, a generally licensed fixed gauging device, Data Measurement Model Number AM-5A and Serial Number BS954804, containing one curie of Am-241, was delivered to a carrier for transport outside the confines of the licensee's plant. The package was not (1) accompanied by a shipping paper; (2) a Type A package capable of showing compliance with test requirements; (3) properly marked; and (4) properly l abeled.
Failure to comply with reaulations appropriate to the mode of transport of DOT in 49 CFR Parts 170 throuch 189 is an apparent violation of 10 CFR 71.5Lal.
10 CFR 31.5(c)(5) require., in part, that upon any indication of a possible failure of, or dahage to, the on-off mechanism or indicator, the licensee shall, within 30 days, furnish to the Director of the-appr oriate Nuclear Regulatory Commission Inspection and Enforcement Regional Office, a report containing a brief description of the event and the remedial action taken. A fixed gauging device, Data Measurement Model Number AM-5A and Serial Number BS954804, containing one curie of Am-241, was found to be damaged on November 29, 1992, and the report describing this incident was sent to NRC Region III dated February 4, 1993.
Failure to notify the acoropriate NRC reaional office within 30 days of the indication of possible damaae to the on-off mechanism or indicator on a fixed cauaina device is an apparent violation of 10 CFR 31.5(c)(5). The reason for_not reporting within the required time frame was due to the fact that the licensee was not aware of the requirement.
This incident and the related apparent violations are significant from a health and safety perspective primarily due to the potential for wide-spread contamination of radioactive material both at the licensee's facility and off-site during transport. The damage sustained by the device's indicator window caused the sealed source to be partially corroded. No leak test was performed prior to shipment to verify source i
integrity. Also, the carrier had no indication that the package contained radioactive material.
i Three apparent violations of NRC requirements were identified.
5.
Other Areas Inspected Organizational structure, leak tests, on-off mechanism tests, installation surveys, receipt procedures, and corresponding records were reviewed during this inspection.
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No violations of NRC requirements were identified.
6.
Exit Interview On April 22, 1993, the inspectors conducted an exit interview with the persons indicated in Section 1.
The inspectors summarized the i
inspection findings, incident review,.and apparent violations. The
-licensee's corrective actions were discussed as described below.
6
To prevent further incidents such as this, the licensee has discontinued use of a pry bar to process the steel roll. On January 28 and 29, 1993, a representative from Data Measurement Corporation visited the l
licensee's facility to review procedures for proper use of x-ray and l
isotope gauging devices with the warehouse safety committee.
The licensee also stated that they will not be attempting to ship isotope gauging devices in the future. All shipments will be handled through the manufacturer. Additional preliminary corrective actions were discussed at this time (Attachment 5).
Corrective actions were i
implemented and documented shortly thereafter (Attachment 6).
On March 17 and 18, 1993, all Steel Warehouse employees, approximately 300 people, were trained by Data Measurement Corporation's Radiation Safety i
Officer in radiation safety with respect to isotope gauging devices.
During this training, the differences between isotope devices and x-ray devices were emphasized. This training was videotaped and will be shown to new employees.
In addition, there are monthly safety meetings and a l
daily five-minute safety meeting at the beginning of each shift which will include pertinent radiation safety matters.
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Attachments:
1.
Device radiation safety manual information on installation i
2.
Device radiation safety manual information on transportation 3.
Licensee report of incident 4.
Data Measurement Corporation report of incident l
S.
Initial report from January 28 and 29,1993 meetings 6.
Followup report from January 28 and 29,1993 meetings j
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.IMPORTANT Compliance with Government hafety Regulationn p.
I ownership of a radioisotope by your company entails certain i
r.wsponsibilitica on your part and on the part of IGCI.
iour company is a ' general licensee' which means it can operate the sealed source for the purpose for which it is
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1atended in the thickness gauge manufactured by IGCI and checked out at your site by an IGCI engineer.
IGcI has a ' specific license' to distribute the gaugen with the sealed cource to ' general licensecs'.
You do not need to apply for a ' general license'.
The regdations require that you file a ' cc r t i f i'c a te ' with your state if it is an ' agreement state' or with the Nuclear Regulatory Council (NRC).-
(IGCI will assist with thic tequirement.)
The laipor tan t rESponsibilitleS of your Conpany and IGC] are as follows; 1.
IGcI will provide you with a copy of the appropriate e
Jta*.e or NRC regulations covering your general licence.
2 Installation of the gauge as shipped to you may be done by our personnel as la customary.
The ganga should not j
t --
bc turned on by you et this point.
3.
Chect out and start-up will be done by an IGCI service d
e ng i r. e c t sent by IGCI.
The engineer will perform a radiation survey, and after determining the gauge is operating sa'tisfactorily, turn its operatinn over to your personnel.
f 4.
You must have ' wipe tests' performed by an individual who is licensed to do so (obtain list from IGCI) at least once every six months.
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5.
Your c upany must be aware of the label on the source holder and of the fact that removal of this label is i
prohibited, ti.
11 0 m ec c a tilc al changes to the C-frame involving the source and the detector may be made by you.
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6-B ATTM tIMGar # \\
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7.
_ Relocation of gauge'to another line - The user must close the nephanical shutiter, check that it is in effect
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closed (green marker) the electrical shutter will be.
closed automatically - before removing the gauge from the line and reinstalling it' on another, B.
Radiation Survey and Shutter Mechanism check _1_no - These must be performed at intervals of no nore than 6 months either by an individual licensed to perform the wipe test or by an IGCI service engineer.
9.
Malfunction of source holder shutter Close shutter manually and call IGCI service engineer, 10, _ Accident on the line - If source bolder can be located, close~ nechanical shutter.
If source holder cannot'be
- located, prevent personnel from entering the suspect area, call IGCI or specific licensee performing wipe test.
In the following pages you will find copies of the pertinent pages of the applicable regulations.
Licenses and Regulations, E.
Sec. c. 20 Types of Licenses.
Licenses for radioactive i
materials are of two types: ~ general and specific.
a.
General licenses provided in this part are effective without the filing of applications with the Agency or the issuance of licensing documents to the particular persons, although the filing of a certificate with the Agenc be required by the particular general license.y mayThe~ general licensee is subject to all other applicable portions of these regulations and any limitations of the general license, b,
Specific licenses require the submission of an applictation to the Agency and the issuance of a
licensing document by the Agency, The licensee is subject to all applicable portions of these regulations as well as any lim.itations specified in the Ifeensing
- document, a
M 8l 6-9 1
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1 c-3 sec. C.90 (lit)
Such person chall escure that any labels required to be affixed to the device under regulations' of the authority which licensed manufacture of the device beir a statement that ' Removal of this label is prohibited":
e and s
(iv)
Thg holder of the specific license shall furnish to each general licensee to whom he transfers such device or on whose premises he installa such device a copy of the general license contained in C.22(d).
i e
3)
The Agency may withdraw, limit, or qualify its acceptance of any opecific license or equivalent licensing document 7
issued by another agency, or any product distributed pursuant to such licensing document, upon determining that such action is necessary in order to prevent undue hazard to public 3
health rind cafety or property, j
e Transportation Sec.100 _ Preparation of Radioactive Material for Transport.
A)
No licensee shall deliver any radioactive material to a r-carrice _1_{/ for trposport, unless; 7'
1)
The licensee compiles with the applicable I
i requirements of the regulations, appropriate to the mode 3
of trcnsport, of the U.S.
Department of Transportation l
in so far as such regulations relate to the packaging of l
radioactive material, and to the monitoring, marking and labeling of thosc packages; l
> r) 2)
The licensee has established procedures for opening and closing packages in which radioactive material is
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t r an spor ted to provide safety and to assure that, prior to the delivery to a
carrier for transport, each
- 3 package is properly closed for transport; and 7
3)
Prfor to delivery of a package to a carrier for transport, the licen.See shall assure that any special instructions needed to saf ely open the package are sent 1
to or have been available to tne consignee.
i n) c.10 0 ( s)
Shall hot apply to the transportation of y
licensed material, or to the delilvery of licensed material to a carrier for transport, where such transportation is subject to the regulations of the U.S.
Department of Trancportation or the U.S.
Postal Service.
f
, l_4/
For the purpose of.this regulation, a licensee who 1
transports his own licensed material as a private carrier is considered to have delivered such material to a carrier for
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transport, 6 - 23
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Ar TT M H M E A/T ff 7 i
E)
Additional Requirements.
t 1)
Each arca or room in which any radioactive material, other than natural uranium or thorium, is used or stored in an amount exceeding,10 times the quantity of radioactive material specified in Appendix B of this
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part shall be conspicuously posted with a sign or signs bearing the radiation caution symbol and the words:
CAUTION 10/
RADIOACTIVE MATERIAL 2)
Each area or room in which natural uranium 'or thorium is used or stored in an amount exceeding one hundred times the quantity specified in Appendix B of this part shall be conspicuously posted with a sign or signs bearing the radiation caution symbol and the Words; CAUTION 10/
RADIOACTIVE MATERIAL i
F)
Containers.
1)
Except as provided in D.203(f)(3), each container of radioactlye material phall bear a
- durable, clearly visable label identifying the radioactive contents.
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2)
A label required pursuant to D.203 ( f) (1) shall bear the radiation caution symbol and the words:
[
CAUTION 10/
RADIOACTIVE MATERIAL It shallindividuals handling or using the containirs/
also provide sufficient information 11 to l
permit
, or working in the vicinity thereof, to take precautions to avoid or minimize exposures.
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3)
Notwithstanding the provisions of D.203 ( f) (1),
labeling is not required:
i (i) for containers that do not contain radioactive l
material in quantities greater than the applicable quantities listed in Appendix B of this part; we 6 - 27 m@
(ii) for containera containing only natural uranium or thorium in quantities no greater than 1,0 times the applicable quantities listed in Appendix B of this part; (iii) for containers that do not contain radioactlye natetial in concentrations greater than the applicable concentrations listed in Column 2,
Table 1, Appendia A of this part; (iv)'
for containcre when they are attended by an individual who takes the precaution necessary to prevent the exposure of any individual to radiation or radioactive material in excess of the limits established by the regylations in this parti (v) for containers when they are in transport and packaged and labeled in accordance with regulations published by the U.S. Department of Transportation; (vi) for containers which are accessible only to individuals authorized to handle or use them 12/ or to work in the vicinity thereof, provided thaE the contents are -identified to such individuals by a readily available written recordt and (vii) for manuf acturing and process equipment such as piping and tanks.
G)
All radiation machines shall be labelad in a manner which cautions individuals that radiation is produced when the nachine is being operated.
10/ or " Danger'.
TI/ As appropriate, the information will include radiation
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IcVels, kinds of material, estimate of activity, date for which activity la estimated, etc.
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steel warehouse -oc.
2722 w.si 1. a., a...e
.... to. i377 219 236-5100 south Lend, indiono 46624 8'00-348 2529 t
February 4, 1993 tw= no. 810-299 2519 steel wkse ska Inspection and Enforcement Offic,e United States Nuclear Regulatory' Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 Ref:
Incident Involving Generally Licensed AM-5A-Device
Dear Sir or Madam,
As required by 10 CFR 31.5 paragraph (c) (5), I am writing to inform you of an incident involving 1 Curie (37 GBq) of Amer icium-241 radioactive material contained within a generally licensed AM-5A device manufactured by Data-Measurement Corporation (DMC).
The Incident occurred at Steel Warehouse
- Company, Inc.,
2722 West Tucker Drive, South Bend, Indiana, 46624.
The Americium-241 was in the Special Form AMC.19 model sealed source manuf actured by Amersham Corporation.
The Registratitsn Number for the Sealed Source and Devices Safety Evaluation of Device for the AM-5A is MD-381-D-101G.
It should be noted that this incident involved no contamination and the AM-5A device shielded radiation levels to less than 1 mrem /hr on the surface and well below the regulated limits for the general public, 0.024 mrem /hr, at 10 cm (4 inches) from any surface of the device.
Details of the incident:
I n late November 1992, the tail steel strip on a production line struck the DMC thickness gauge.
Both the source holder and the detector were damaged.
On November 30 1992, a_ Steel Warehouse employee packed and returned to DMC one damaged AM-5A Isotope Source Holder.
The extent of the damage was limited to the indicator window, which was cracted.
This crack allowed water / coolant to enter the source holder and come in contact with the sealed source.
The coolant caused significant corrosion to occur on the sealed source itself.
When DMC was contacted to provide a Return Materials Authorization (RMA N1),
a Steel Warehouse Employee requested f or the r eturn and repair of one "X-ray Sou::e" and one "X-ray Detector".
The DMC employee handling the call processed the RMA as if the source was an X-ray generator not an isotope source.
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~..- -.
a F
i The device was wrapped in " bubble-wrap" and placed in a cardboard box approximately 24" x 14" x 10".
Foam fill pellets were added to cushion'the device during transportation.
The device was shipped via UPS second day-l ground service and arrived at DMC on December 2, 1992.
l The. package was unpacked by DMC wher,e it was r ealized the device contained a sealed source and the cardboard box was an inappropriate shipping container i
for radioactive materials.
An individual trained in handling radioactive materials was called to examine ~
the package and perform a leak test (Standard procedure for receipt of radioactive materials).
Because of the cracked window, extra precautions were taken.
The device was disassembled in DMC's Plexiglass Isotope handling box, where the true extent of the corrosion was observed.
An extensive wipe to test for leakage of radioactive material was performed.
The results of the wipe test indicated there was no leakage of the Americium-241 radioactive material.
Violations:
At the time of the st ip break,.and observed damage to the source holder, Steel Warehouse was correct by immediately suspending ' operation of that device.
However, the manufacturer, DMC, should have been contacted to test the device for leakage, remove the device from installation and make any of the necessary arrangements for transportation and repair of the device.
d The transportaticr. of the device was not in accordance with USA DOT class 7 shipping r egulations The packaging used was not certified TYPE A, and there 4
were no labels or stencils to indicate this was a Radioactive Materials Shipment.
Also, according to 10 CFR part 31.5 paragraph (c) (5) report of this incident should have been furnished to the USNRC within thirty days.
Remedial Actions taken:
After inspection of the corroded sealed source, the DMC RSO classified the capsule as "non-conforming" material, and cannot be used again.
Both the device and the "X-ray Detector" were beyond repair and had to be replaced.
DMC telephoned _Mr. Ron Duerksen, Head of Electronic Maintenance for Steel-Warehouse, and explained the shipment of the de/ ice was in violation of Nuclear Regulatory Commission and Department of Transportation Regulations.
DMC also explained the condition of the device was poor and a DMC employee should have been called for an on-site visit.
Mr. Duerksen apologized and indicated that an A raintM nician handled the repair and if he had been aware of the technician's actions ne wou1 N ve not allowed the shipment.
j j
1
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t DMC reminded Steel Warehouse of their responsibilities as a General Licensee.
Mr. Duerksen reassured the RSO that this-was understood by himself and he l
would not permit this to happen again, j
A on-site training session by DMC took place on January 28, 1993.
-At the request of the Steel Warehouse Union Safety. Board Chairman, Tim Oliver, an j
additional copy of Chapter 10 Part'31 of the Code of FederaT~ Regulations, l
" general domestic Licenses for Byproduct Material," and a copy of " Working i
Saf ely with 14uclear Gauges" were provided for' training purposes.
It should be noted that the dif f erence between the x-ray gauges and the Isotope gauges F
was made clear, thus avoiding the mistake that lead to the violations
[
associated with the shipment of this device.
Actions to be Taken:
Steel Warehouse is in the process of obtaining a radiation survey meter to monitor radiation levels around the nuclear gauges.
Additional warning signs.are being ordered to raise the general level of I
awareness around the gauges.
Additional saf ety training is scheduled f or all Steel warehouse employees f or
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mid-February.
The training will cover the responsibilities and restrictions j
of the General License.
Steel Warehouse deeply regrets the errors made during this incident, and believes the remedial actions caken (and to be taken) will avoid violations i
in the future l
?
Sincerely, j
A9
~7 th
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S eel Warehouse Safety Supervisor 2
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X DATA MEASUREMENT CORPORATION i
P.O. Box 490 15884 Gaither Drive GaitherstPJrg. Maryland 20884 U.S.A.
Phone: (301) 948-2450 Fax: (301) 6704506 Telex: 898332 19 February 1993 Ms. Sharon Wagner Radiation Specialist Materials Inspection United States Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Ill 60137
Reference:
Steel Warehouse Incident
Dear Ms. Wagner,
i As indicated in our phone conversation today, I have included with this note the following:
1)
My letter to Steel Warehouse dated 1 February 1993.
2)
Two three view drawings of the AM-5A source holder.
l 3)
A sample label indicating General Licensee responsibilities.
On item number 2,
I have indicated the location of the etched
" Caution Radioactive Material Retainer" and of the smaller labels on the front side of the holder.
The small labels were still in place when the source was received at DMC.
On all AM-5A source holders distributed under our MD-31-088-02 Radioactive Materials license, we are required to attach Item 3.
Item 3 is placed on the top of the AM-5A as indicated in Item 2.
When the source holder was received from Steel Warehouse it was considerable dirty and DMC is not sure the label was in place.
The source holder has since been cleaned up and re-tested.
If you have any additional questions please give me a call at (301) 948-2450 extension 341.
Sincerely,
- t-Bs Christopher Burnett mag g y b3 Radiation Safety Officer
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Enclosures DMC France SARL DMC Mess & RegelrechnA GmbH DMC (U K.) Ltd ATTAU4rH&MT # M 3
D M C DATA' MEASUREMENT CORPORATION P.O. Box 490 15864 Gaither Drive Gaithersburg, Maryland 20884 U.S.A.
Phone: (331) 948-2450 Fax: (301) 67CLO506 Telex: 898332 1 February 1993 Mr. David Lerman President Steel Warehouse Company, Inc.
2722 West Tucker Drive South Bend, Indiana, 46624 Ref:
Return of Damaged Generally Licensed AM-5A Device
Dear Mr. Lerman,
I am writing to inform you of an incident involving your generally licensed AM-5A device containing 1 Curie (37 GBq) of Americium-241 radioactive material.
The Americium-241 was in the Special Form AMC.19 model sealed source manufactured by Amersham Corporation.
The Registration Number for the Sealed Source and Devices Safety Evaluation of Device for the AM-5A is MD-381-D-101G.
It should be noted that t;his incident involved no contamination and the AM-5A device shielded radiation levels to less than 1 mrem /hr on the surface and well below the regulated limits for the general public, 0.25 mrem /hr, at 10 cm (4 inches) from any surface of the device.
Detqils of the Incident:
t on 30 November 1992, a Steel Warehouse employee packed and returned to Data Measurement Corporation (DMC) one damaged AM-5A Isotope Source Holder.
The date the damage and the conditions under which the damaged occurred are not known to DMC.
However, the extent of the damage was limited to the indicator window, which was cracked.
This crack allowed water / coolant to enter the source holder and come in contact with the sealed source.
The coolant caused significant corrosion to occur on the sealed source itself.
When DMC was contacted to provide a Return Materials Authorization (RMA f), a Steel Warehouse Employee requested for the return and repair of one "X-ray Source" and one "X-ray Detector".
The DMC employee handling the call processed the RMA as if the source was an X-ray generator not an isotope source.
The device was wrapped in " bubble-wrap" and placed in a cardboard box approximately 24" x 14" x 10".
Foam fill pellets were added to cushion the device during transportation.
The device was shipped via UPS second day ground service and arrived at DMC on 2 December 1992.
3 DMC France SARL '
DMC Mess & Regel!cchnA GmbH DMC (U K ) Ltcl
The package was opened and delivered to the repair department.
At the repair department the technician monitored the radiation levels (less than 1 mrem /hr) and realized the device contained a' sealed source and the cardboard box was an inappropriate shipping container for radioactive materials.
An individual trained to handle radioactive materials was called to examine the package and perform a leak test (Standard procedure for receipt of radioactive materials).
Because of the cracked window, extra precautions were taken. The device was disassembled in DMC's Plexiglass Isotope handling box, where the true extent of the corrosion was observed.
An extensive wipe to test for leakage of radioactive material was performed.
The results of the wipe test indicated there was no leakage of the Americium-241 radioactive material.
Actions taken:
DMC's Radiation Safety Officer returned from a business trip on 4 December 1992 and was informed of the incident.
After inspection of the corroded sealed source, the RSO classified the capsule as "non-conforming" material, and cannot be used again.
Both the device and the "X-ray Detector" were beyond repair and had to be replaced.
A phone call was made to Mr. Ron Duerksen, Head of Electronic I
Maintenance for Steel Warehouse, explaining the shipment of the device was in violation of Nuclear Regulatory Commission and Department of Transportation Regulations.
The condition of the device was poor and a DMC employee should have been called for an on-site visit Mr. Duerksen apologized and indicated that an untrained technician handled the repair and if he had been aware of the technician's actions he would have not allowed the shipment.
The RSO at DMC reminded Mr. Duerksen of the responsibilities of Steel Warehouse's General License, as included in the gauge Operators Manual.
Mr. Duerksen reassured the RSO that this was understood by himself and he would not permit this to happen again.
Based on the consistent level of attention to radiation safety, with respect to timeliness for leak tests and other issues, Mr.
Duerksen's assurance for increased training on this issue was accepted as an appropriate corrective measure.
A on-site training session with DMC field service engineer Glenn Sch z took place on 28 January 1993.
At the request of the Steel Warehouse Union Safety Board Chairman, Tim Oliver, a copy of Chapter 10 Part 31 of the Code of Federal Regulations, " General Domestic Licenses for Byproduct Material," and a copy of " Working Safely with Nuclear Gauges" are being provided for training purposes.
Mr. Schultz reports shielding was added to reduce levels of scattered radiation around the thickness gauges.
i
Mr. Oliver was concerned about possible exposures that could have resulted from this incident.
During a phone conversation with Mr.
Oliver on 27 January 1993, the RSO at DMC described a hypothetical scenario of the corrosion on the sealed source breaching the stainless steel capsule, the active ceramic material cracking and small quantities of the Americium-241 mixing with the coolant.
l Under this remote scenario, all those who came in physical contact with the device may have been contaminated including any UPS employees.
This scenario described the seriousness required when handling radioisotopes.
During the conversation, Mr. Oliver became concerned about the water now being contaminated. Understanding that the leak test indicated no leakage of radioactive material, Mr. Oliver was still concerned that the water had touched the source. The RSO reassured Mr. Oliver that the AMC.19 Scaled Source emits a beam of gamma rays that do not make substances radioactive when they are placed in the beam.
This concern on the part of Mr. Oliver indicates the need for training with respect to radiation interaction with matter.
Actions to be Taken:
After several conversations with Steel Warehouse, and reviewing the Regulations concerning General Licensee Responsibilities.
DMC recommends:
- 1) Steel Warehouse implement a procedure regarding the extent to which in house technicians can work on the gauges containing radioactive material, and when a DMC technician is required to perform the work.
- 2) Steel Warehouse should obtain a survey meter (and the proper operational training) to monitor levels of radiation around gauges to " map" safe areas.
- 3) Steel Warehouse train maintenance and line operators in the responsibilities and restrictions associated with the possession and use of Nuclear Gauges.
- 4) Under 10 CFR 31.5 paragraph (c) (5), Steel Warehouse should notify the appropriate Nuclear Regulatory Commission Inspection and Enforcement Regional office of the event as it took place at Steel Warehouse.
(See Attached letter as an example)
+
s,-
i In the' future,-please contact DMC if you-have any questions about'
~
your isotope'and-X-ray thickness gauges.. We will provide whatever' assistance neces'sary to insure.the safe and' legal use of' nuclear j
gauges by Steel Warehouse'and its employees.
1 i
Sincerely, j
?
V Christopher Burnett Radiation Safety Officer Enclosures cc:
Edward Berebitsky, Steel Warehouse, Vice President Gerry Czajkowski, Steel Warehouse, Maintenance Supervisor ~
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Tim Oliver, Steel Warehouse, Union' Safety Boardmember Dominique Gignoux, DMC, President
.j Okey Deraimo, DMC, Customer Service Manager Charles Flynn, State of Maryland, MDEREP
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CAUTION - CONTAINS RADIOACTIVE MATERIAL DATA MEASUREMENT CORPORATION GAITHERSB'JRG, MD USA ~
ISOTOPE:
ACTIVITY:
SERIAL #:
MODEL *:
, -RECEIPT, POSSESSION, USE, AND TRANSFER ARE SUBJECT TO 4
' GENERAL LICENSE OR EQUIVALENT AND REGULATIONS OF AN AGREEMENT STATE OR THE U. S. NRC.
-ABANDONMENT / DISPOSAL PROHIBITED UNLESS TRANSFERREO
,TO AGREEMENT STATE OR U.S. NRC SPECIFIC LICENSEES.
- OPERATION PROHIBITED IF ANY INDICAT!ON OF FAlLURE/ DAMAGE TO SHIELDING, SOURCE CONTAINMENT OR ON-0FF MECHANISM.
-lNST ALLATION, DISMANTLING, RELOCATION, MAINTENANCE,
- REPAIR, TESTING, TO BE PERFORMED BY AGREEMENT STATE'
' OR U.S. NRC SPECIFIC LICENSEES.
-DEVICE TO BE TESTED FOR RADIDACTIVE LEAKAGE AND PRO-PER FUNCTIONING OF SHUTTER MECHANISM AT INSTALLATION
! AND EVERY SIX MONTHS THEREAFTER.
1-LOSS, THEFT, OR TRANSFER SHALL BE REPORTED TO AN l
- AGREEMENT STATE OR THE U.S. NRC.
-00 NOT PLACE HANDS OR FINGERS IN AIR GAP.
f REMOVAL OF THIS LABEL IS PROHIBITED a_--
I
5 To: Ron Dneiksen Steel W:nehouse South Bend,IN i
i F:om: Glenn Shultz Data M casurement Corp.
Valpm aiso,IN Re: Meeting Sunnumy January 28 and 29.1993 Attendees: Je:Ty Czajkowski Ron Dneiksen Bob Mack Ot ec, Kline l
Kent Fuchs Glenn Simitz r
Meetings were held nt Steel War ehouse on Januaiy 28 and 291993. 'Ihe meetings were requested by S: eel Warehouse for the purpose ofreviewing proper procethtres relating to their X-Ray and Isotope thickness gauges. *Ihe need for a review became apparent alles Steel Warehouse shipped an Americium 241 radioisotope source / source holder assembly to DMC for repairs without following established shipping procedures. 'Ihe imrnediate causes of this occurrence were the lack ofunderstmiding of the differences between X-Ray and Radioisotope som cen. and of the innponimice of these differences.
A review of this incident was held. 'Ihe causes were exmuined. Procedures wer e put in place so as to prevent a recurrence of this infmetion. Steel Warehouse was reassured that the integrity of the source was not violated, and that no exposure due to leakage had occuned. Steel Wm ehouse was also informed of the consequences, had the source been found to be leaking. My were told ofprocedmen that umst be followed if they suspect that a source holder has been dmnaged, and that they do not have the aufhority to make repairs to this unit.
Surveys were done in the presence ofSteel Warehouse personnel on each of the X-Ray med Isotope thichiess ganges on site. Safe areas were thiely noted. In the case of the 450 TXM 160 KV thickness gauges on the Mini-Mill, additional shielding was added in order to fiuther reduce the indicated radiation levels.
)
k ATTMH MENT rV T
2
/
h Steel Warehouse is presently using the following equipment:
l-Temper Mill 510TXC 160kv X-Ray nickness Gauge Exit 410 TAM isotope Hickness Gauge Entiy 2-Mini Mill 450TXM 160kvX-Ray %ickness Gange Exit 450TXM 160kv X-Ray %ickness Gange Entry 3-Pickle Line 510TXC 160kv X-Ray %ichness Gauge Exit 1-#1 Slitter 410 TAC isotope nickness Gange Exit 5-#2 Slitter 410 TAC isotope %ickness Gauge Exit
%e following items have been or will be implemented as soon as possible:
1-Rmliation safley classes will be given by an authorized DMC employee to all of the employees of Steel Wmehouse. nis will be set up by Steel Warehouse at their conveinence.
2-Steel Warehouse will purchase a s adiation monitoring device. %ey will contact DMC in order to ensure that the proper equipment is purchased, mul for tr aining on the proper use of this equipment.
3-Steel Wm ehouse will install a remote rhutter close puchbutton for the operator on the Pickle Line 510 TXC thickness gauge. DMC will assist in the installation.
4-Shutter status linteni lights ibr the gauges will be installed for the opemf ors near the gauges in such a rmumer that mnbiguous status interpretations are avoided. Openitors will have the s esponsibility ofinfonning maintemmce in a timely manner if these lights fail to function properly.
5-Radiation levels were monitored in crane cabs that could pass near the thickness gauges.
No unacceptible levels were observed. Levels were actually umneasureable in these areas.
6-Steel Warebonse requested that DMC suggest a safe nien distmice in the everit fliat a radioisotope were to become seperated from its holder. We recommended 30 meters to achieve n 0.25 mR/hr level, and 10 meters to achieve a 2.0 mR/hr level.
7-DMC will provide to Steel Wm ehouse a mimber of the gieen NRC published radiation booklets timt they may distribute or keep by the gauges.
8-DMC will provide the appropriate radiation signs to replace those that are missing on each of the thickness gauges.
9-DMC provided Steel Warehouse with another copy ofthe appropriate NRC rules mul regulations regm ding the use of this equipment mul the responsibilities of the users.
10-DMC will resnrvey each of the thickness ganges and leave hard copies of the levels monitored when the next regularly scheduled radioisotope leak tests are perfonned in Febnimy 1993.
I l-Steel Wm ehouse is siivestigating the possibility ofissuing radiation badges to the appropriate employees. DMC will assist them as necessary.
12-Steel Wmehouse was s eminded that our nidiation safety ollicer in Clais Bnniett, that DMC would assist in any way possible, and that they have been very conscientions in the past in ensuring timt all acquhrinents m e met regm ding the use mul maintenance orthia equipment. %.ir conmn for the well being of fbeir emtiloyeea ia +mlily oppnient.
~~
(o f
FOLLOW UP ON RADIATION SAFETY i
THIS IS A FOLLOW UP REPORT ON THE RADIATION SAFETY MEETING THAT WAS IIELD ON JANUARY 28 AND 29 AT STEEL, WAREHOUSE. GLEN SHULTZ FROM DATA MEASUREMENT ALONG WITH JERRY CZAJKOWSKI, GREG KLIEN, RON DUERKSEN AND ED GONZALEZ FROM STEEL WAREHOUSE WERE IN ATTENDANCE. THE FOLLOWING ITEMS WERE DISCUSSED AND TO BE IMPLEMENTED AS SOON AS POSSIBLE.
t 1-RADIATION SAFETY CLASSES BY DMC.
ECHEDULED FOR MARCH 17,18 2-STEEL WAREHOUSE WILL PURCHASE A RADIATION MONITOR DEVICE.
PURCHASED AND RECEIVED FEB 1993 3-REMOTE SIIUTTER FOR P/P X-RAY BY C FRAME PROJECTED COMPLETION DATE 2-27-93 pc 2 1545 4-SHUTTER LIGHTS FAILING ALL HAVE BEEN RELAMPED, MARCH MEETING WILL INFORM OPERATORS OF THEIR RESPONSIBILITY 5-RADIATION LEVELS IN CRANES NEAR GAUGES ALL CRANES WERE CHECKED AND OK'D BY GLEN f
t 6-SAFE AREA IN THE EVENT OF DAMAGED ISOTOPE DMC SUGGESTED 30 METERS, THIS WILL BE PASSED ON AT THE MARCH MEETING
% 7-DMC TO PROVIDE NRC RADIATION BOOKLET (x
RECEIVED BOOKLETS ON 2-17-93 WILL INSTALL ON EACH MACHINE WHEN WE WE WILL ORDER THESE HOLDERS ON 2-25-93 g
pgECEIVEHOLDERS, N
'8-DMC TO PROVIDE SIGNS TO PUT ON ALL GAUGES hp ULEN SHULTZ HAS ORDERED THESE ON 2-17-93 THEY WILL BE INSTALLED WHEN WE RECEIVE THEM a y WD 9-DMC TO PROVIDE NRC RULES AND REGULATION BOOK ON OUR RESPONSIBILITY WE HAVE RECEIVED THIS BOOK 10-DMC WILL SURVEY ALL X-RAY AND ISOTOPE GAUGES DONE ON 2-17-93 COPIES IN JERRY'S FILE
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I PAGE 2 11-STEEL WAREHOUSE WILL ISSUE RADIATION BADGES TO EMPLOYEES i
BADGES WERE RECEIVED AND HANDED OUT 2-93 cc: DAVE DOPP GLEN SHULTZ DAVE LERMAN GREG KLIEN JERRY CZAJKOWSKI ED GONZALEZ r
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.. nemetuselseer / vet. w N tas f reder, pair to.1ser / Nodcas assomosomssadoseuseet te:m Secretary of tbs
==i==laa U.S. ;
c Nedeer Regeistory ema=i==La=
Wa=hingeaa DC2 ness. ATIN:
1 Docketing and Serv 6ce Breach.
Hand deliver coussente to:One White Flint North.11885 Rockville pike.
Rockvtus.MD between 7:45 a.m.to 415
- p.m Federalworkdays.
Copies of ossemente may be examined
. at the NRC public Document Room. 2120 L Street.NW.(ImwerIsvel).
Weekington.DC -
pee rustunt espomaavions coerracn lames IJoberman. Director. Office of Enforcement. U.S. Nuclear Regulatory r==i==sa= Weebiaston.DC20555 (301-406 c41).
su m esmeensiv seessaarioic Beckymmed N NRC's current poucy on enforcesseet osoferences le addressed 'm Section V of the latest revision to the
- General Statement of poligr and proceduse for Enferosuant Actions."
(Enforcessent poucylte GR part 2.
appendixC that wee pubushedon February 18,1308(SF FR 5N1).N Enfera====r pelley states that.
endorsement
- wiB not noneany be span to the public."
However,theCommission has decided to hopieneeta and proyam to deteredse whetherto meistain the correst paherwith regard to enforoomset oseforences or to adopt a Two.YearTrialpropean for new poikythat wouldanow most CenessangOpen Endereement eederoomset osefsences to be open to, paesystatemeeg attendsome by au members of the pubhc.
N massevsNacieer Regulatory c==a==6 =-
Ibeition h NRCisi=pla==ating a two-year l
i I*I 8'ayan W aHow pubhc summannh Nedeer Regalatory obserosess etesiected enforcement NRQleleasing this pebey coederemons.1he NRCwiu monitor the Canademies(to =pB====e=da= of a statsseet as a
two year trial preyssa to ausw selected progen end dehraise whether to establiek a pumasat policy for enforcement conseremose to be spes to enteressent a =ada=as by a5===h-e of the coederemose on an assessment of n
generet pubbc.1 tie poucy stammest the feRowleg setterie-describes the twoyear trialprogram (1)Whaterthe fact that the andimianna the pubbeof how to get coefamosewas openimpacted the infonentisaen spea NRC's eheir to oseduct a meenmgful enforcement
- 'Iunes med/or implement the NRC1 omven'fhie etal isessenveon "#*""""' N i
. July 10, test, comments on the (2)Whetherthe speaconference proyma ese being neceived. Submit impmenad the16cenese's participation in cosuseets on er before the compledom the conferemos of the trtal prepas ediedeled for }ely 11.19e2. r====*= received after this
'(3) Whether the NRC expended a date will be considered if it is practical
='faine==* ameset of resources in to do so.but theemami==ian is.able to maldag the conference public: and,
assare canald=etion only for c5mments (4) N==*==t of public interest in received on or before this date.
opening the enforcement conference.
I I
i
r.dersi angineer / vol. sr. No.12: / Friday, July 10, test / Nasses
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agm L creamle For % Open three asengeries oflan====== wel be subject espesomeniesroenies that Endessessent Camiu m use '
mi
- reactora, afgun, beamere, poetese, etc not larger i
p Enfortweest conferences wGInot be W oemd - wM
&as W posisted, and that l
open to the pubheif the amiasmosat wn!asemist of the renaanang types of disrupthe passene may be removed.
llemanaes.
Each reglemaledbes wGIometinen to i
.cua.
2
- m (1) W be tahan agniest sa IL Aeneumaing Open Enferessenet condest the enfassumenteenference indivistaat or if the acelen, thosch met r ame--====
proceedisse la aeonidense with recomel taken against an individual turne en praedos.m enfaseement eneference whether an inevidualhas ra==ittad As soon asitle dWarmined that an enforceansat conference wG1 be open to wulcontimes tobe a messias between the NRC and thelineessa.While the I
(2) volvee algamraat personnel pubuc observatism, se NRC wGlmaHY f:Dmw where he NRC hn usted Doufy se Homem eat se enforcommt enforcement asefameosis open for
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puhucobservaten, Mis not open for th2t theIndivideal(s) involved confermee wGIbe open to 4 pubhc participemen, present at the conference:
88 P8ft 88 8
paresas ettendlag opea emiercoment l
(3)le based on the fladings of an NRC program and med b h a wpy d conferemose ese summandad that (1) the i
t e nonce est antinse Omco ofInva=Hr=Ma== (Of) report; or (4)lavolves safeguarde infonnanen, es proyam wm be asked to
,pp,,,g,g,g,gg,,,gg,,,,,,g,,,,,,
j numete enumbw dper6cipane n endesoament osaissemens are ambiect to Privccy Act infonnation, or other further review and may be embpect to 1
i infonnetion which could be considered
"*88*
so that the NRC can schedule en change prior toanyseenlaims prop,g,en,y, h aedom and(1)ea apPropna sized confmum room Enfora== ant conferences involving
.,,g,g,,,,,
m_1, og l
1 medical misadministretions or 88ttfy apprapnete opinion made byNRC j%,a at overexposures willbe open assuming Pen enforcement conferences or the the confersone can be condocted he bn lack thereef are estintended to withont M -t the exposed P"
puhuc o
den.
represset final deter =d==Ma== or behefs.
Individaars name.In addition.
I"
% NRClatends to i
enfosonneset osoferesess wiR mot be enforcement the agency's propanla accadiance i
open to the pebbe if the conference wGI w t asaddam m h tMe nedce,p a w ns be eaadar*=d by of n or the nonnaHy atleast to workhug dereis advance of the enforcement conference ettmee8*pm h h e l
conference wGl be condested at a theinuewees h willbeprwided asopportunity to j
relatively small ite=a=== e lackhty.
(1)
Wtu the Pabits wrnam ommmeou amanymonely i
Finally, with the appresel dthe i g to the regionaledBoe.Dese comments DocumentNWphone=====mpam and wm embeespeestly be forwenied to the l
Executive Director for Operationa.
(2) tee caforcement confersoons wlB notbe (3) Toll-tres actronic benissa heard Director d 6e OdRee af Enfan-mant for open to &e pobhc ta spedalcasse review and consideration.
where good comes has beenabeum after Pendlag estahllah====t of the tolMree Deted as BeeheBe. nSA this Fe day of July balanctag the benefit ofpublic message eyeesses,the pubue may ceH 28eL s
oburvamos agniast ne potential lapest (seil ess.4 ras se obtain a recording of rarseN= seer rtaa yce==i
.en.
e
= se menney's enforcement actionia a upcond.g.,e. asmesse.t se.e ai.cnam.
particular e=.
confme.o nowRcwmiamamen see, 7enuca es b NRC will strive to conduct open Fedesel Register modos sheres tolMree [ymone,sweessygedy w m ;
enforcement conferences duttas the mesesse eyeeses are==*=hh=h=d i
4 tw* rear anal presramin accordmos To.uin ee NRcin seeking
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wie as fouewas ihr. goals:
a a a,,aag ete n es,,et (1) Appnmunasaly25 percent of an observaties ofemisseement M754 l
elisible enforcement conferences acaderessee, toevedeals ietsressed in caducied by a.NRcwGlbe open sor puhucohorreaa:
ceders.s a p nc.iar m fmo.m.
at es coaheau eeemevident Correctl0nS
- =d "**
t (2) At lanat oss opse enforessent idestIBedin the meetles notice conference et) be randar2=d la sack of
======d=g the opse enforr====r
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vet nr. No.138 l
the reponalomces;and
. couderesse ao letar than Sve busioone Frtder. July tr. test j
(3) Open ertforcement samferences days prior to the endoronment wdl be conducted with a vertety d the couderesco.
I i
i types cf heensees.
HUCLEAR RgGULATOftY i
To evoid potentialbiaela the IIVW of Open Enforcement C00Aes01006 i
selection process and to attempt to meet te three goele stated above,every in encordemos with corrent proctica.
Two. Year Tited prograra kr l
2 i
fourth ehybis enforcement comieremos enforcessent conferences will contfaue Conducung Open esdoreement J
involving one of thru categories of to =a-nany be held at the NRC regional Confereneens pocoy Statement i
licensees wGI marmeDy be span to the omces. Members of the public wulbe Corrveden l
l public dones the tnal proyam.
allowed access to the NRC regional However,in cases where there is en omons te setend open enioremmans la notice dar===at 9216233 beginmns l
Ongoing adfudicatory prooW with confermarna in accordaoos wrth the on page som in the laeus of Priday, one or snore laterrenors, enfor====t
- Standard Opereting procedores For July,10. teer, on page 3cm. In the conferences involving teouse related to MC., Secertty Seppert For NRC
==cand colusan, under thaves, beginning tha subject metterof the onsoms Heartage And Meetings" published in the fifth ham," July 11.1992" should ed}udication may also be opened.For November 1.1991(36 FR 5c51).These rud " July 11.1994.
the purposes of this trialprogram, the procedures provide that visitors may be enuma sees imeme I
.