ML20045G537
| ML20045G537 | |
| Person / Time | |
|---|---|
| Issue date: | 06/21/1993 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20045G533 | List: |
| References | |
| NUDOCS 9307140091 | |
| Download: ML20045G537 (3) | |
Text
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-j f10TICE OF VIOLATI0f4 Alpha Quality Services Docket tio. :
15000004 Vacaville, California License flo.:
CA 4927-48 l
During the f4RC inspection conducted on May 21 and 26, 1993, violations of f1RC requirements were identified.
In accordance with the " General Statement of l
Policy and Procedure for f4RC Enforcement Actions," 10 CFR Part 2, Appendix C, the violations are listed below:
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10 CFR 71.5(a) requires that a 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, comply with the applicable requirements of the regulations appropriate to the mode of transport of the i
Department of Transportation (DOT) in 49 CFR Parts 170 through 189.
l A.
49 CFR 177.842 requires, in part, that packages of radioactive materials l
be so blocked and braced that they cannot change position during l
conditions normally incident to transportation.
Contrary to the above, on May 21, 1993, the licensee transported a j
package containing a 30-Ci Iridium-192 source in its SPEC 2T exposure device (S/f4 753) outside the confines of its storage location, and the package was not blocked and braced such that it could not change position during conditions normally incident to transportation.
This is a Severity Level IV violation (Supplement V).
B.
49 CFR 177.817(a) requires that a carrier not transport a hazardous material unless it is accompanied by a shipping paper prepared in accordance with 49 CFR 172.200-203.
Pursuant to 49 CFR 172.101, radioactive material is classified as hazardous material.
49 CFR 172.203(d) requires, in part, that the description for a shipment of radioactive material include:
(1) the name of each radionuclide, (2) the physical and chemical form of the material, (3) the activity contained in each package of the shipment in terms of curies, millicuries, or microcuries, (4) the category of label applied to each package (e.g., RADI0 ACTIVE WHITE-1), and 5) the transport index assigned to each package in the shipment bearing RADI0 ACTIVE YELLOW-II OR -III labels.
Contrary to the above, on May 21, 1993, the licensee transported licensed material in an exclusive use vehicle, and the description on the shipping paper that accompanied the shipment did not include the correct category of label nor the correct transport index.
Specifically, the correct label should have been a RADI0 ACTIVE YELLOW-II because the transport index for the SPEC 2T exposure device was measured at 0.4 on that date.
The shipping papers incorrectly specified a label of RADI0 ACTIVE YELLOW-III and a transport index of 2.0.
930714o091 930621 PDR STPRG ESGCA PDR
2 This is a Severity Level IV violation (Supplement V).
C.
49 CFR 172.504 prescribes requirements for placarding vehicles used to transport hazardous materials. Specifically, Table 1 requires that the transport vehicle be placarded on each side and each end with a "RADI0 ACTIVE" placard when transporting:
a) packages bearing a.
"RADI0 ACTIVE YELLOW-III" label, and b) low specific activity (LSA) radioactive materials shipped as exclusive use.
t-Contrary to the above, on May 21, 1993, the licensee transported a 30-Ci j
Iridium-192 source in its SPEC 2T exposure device (S/N 753) outside the confines of its storage location in a package with the YELLOW-III label, and the transport vehicle was not placarded with a "RADI0 ACTIVE" placard.
This is a Severity Level IV violation (Supplement V).
In addition to the violations of DOT regulations listed above, one specific violation of NRC regulations was identified:
D.
10 CFR 71.12 states, in part, that a general license to transport licensed material, or to deliver licensed material to a carrier for transport, applies only to a licensee who has a quality assurance program approved by the Commission as satisfying the provisions of subpart H of 10 CFR Part 71; has a copy of the specific license, certificate of compliance, or other approval of the package; and submits in writing to NRC, prior to the first use of the transport package, the licensee's name, license number, and package identification number Contrary to the above, on May 21, 1993, the licensee transported to Mare Island Naval Shipyard its SPEC 2T radiographic exposure device (S/N 753),
a Type B transport package, under the general license pursuant to 10 CFR 71.12, and the licensee did not have a quality assurance program approved by the Commission and had not submitted in writing to NRC prior to the first use of the transport package the licensee's name, license number, and package identification number.
This is a Severity Level IV violation (Supplement V).
Pursuant to the provisions of 10 CFR 2.201, Alpha Quality Services, Vacaville is hereby required to submit a written statement or explanation to the Regional Administrator, Region V, with a copy to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555, within 30 days of the date of the letter transmitting this Notice of Violation (Notice).
This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation:
(1) the reason for the violation, or, if
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contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps.that will be taken to avoid further violations, and (4) the date when full compliance will be achieved.
If an adequate reply is not received within the
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time specified in this Notice, the Commission may issue an order or demand for.
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information as to why the license should not be modified, suspended, or
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revoked, or why such other action as may be proper should not be taken..Where
. good cause is shown, consideration will be given to extending the response time.
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Dated at Walnut Creek, California this 2j 5 day of June 1993 i
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