ML20056C992
| ML20056C992 | |
| Person / Time | |
|---|---|
| Site: | 07109056, 07100767 |
| Issue date: | 07/12/1993 |
| From: | Foster R ALPHA QUALITY SERVICES |
| To: | Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| References | |
| NUDOCS 9308020035 | |
| Download: ML20056C992 (2) | |
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Alpha Quality Services Consditing, inspection and Testing Page 1 oi 2 397 Camellia Way Vacaville, California 95688 l
(707)446-006I July 12, 1993 United States Nuclear Regulatory Commission
[
Region V 1450 Maria Lane Walnut Creek, Ca.
94596
)
Docket No:
15000004 License No:
CA 4927-48 RE: Reply to a Notice of Violation Gregory P.
Yuhas. Chief
Dear Mr. Yuhas,
)
In response to your letter dated June 21, 1993 concerning a notice of violations, I have compiled the following information.
A.
Failure to block camera shipping container.
1.
Reason: This occurred because the radiographer was unaware that special precaution was needed to restric t movement of the. shipping container within the vehicle.
2.
Correction:
This has been remedied by removing the exposure device from the shipping overpack and placing it inside a specially designed and constructed box that is a permanent part of the i
interior of the mobile darkroom.
The box has a lead lining that is sufficient to prevent radiation emissions above the allowed limits and has a secure lock.
3.
Prevention of Further Violations: This topic has been reviewed with l
the radiographers and will be included in the semi-annual training.
4.
Date:
Compliance was met on May 21, 1993.
Leaving the job site on May 21, 1993, the shipping overpack containing the exposure device was firmly fastened to the film processing tanks.
Since that date the correction described above has been implemented.
B.
Incorrectly labeled transport index.
1.
Reason:
This occurred because I modified the shipping label that was on the container after it arrived at AQS containing a new source.
The reading I placed on the index was correct at @ 2.0 mr/hr, however I did not replace the Yellow III with a Yellow II label.
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2.
Correction:
In future, shipping labels will be replaced and not modified.
3.
Prevention of Further Violations: The DOT regulations involving transport indexes have been reviewed and a copy has been placed in the file where shipping forms are kept.
The topic has been reviewed with radiographers.
4.
Date:
Full compliance was achieved on May 26, 1993.
C.
Placarding of Vehicle 1.
Reason:
This occurred due to the incorrect (Yellow III) label on the shipping container not having been replaced with the correct (Yellow II) label.
2.
Correction:
Placarding should not be necessary when the exposure device is carried in the lead lined box in the darkroom.
However, careful monitoring of the external surfaces of the storage trea within the transport vehicle will be conducted'and should the reading be above the limits for Level II the outside placards will be used.
3.
All radiographers have reviewed DOT regulations concerning placarding and it will be included in the semi-annual review.
4.
Date: Full compliance was achieved May 26, 1993.
D.
Failure to have NRC approved QA program.
1.
Reason:
There was a misunderstanding on my part about the approval of the QA program.
2.
Correction:
The application for approval of the quality assurance program was submitted to Mr. Charles E. MacDonald, Office of Nuclear Material Safety and Safeguards, on June 21, 1993.
3.
Prevention:
There should not be further problems since the e
procedure is now understood.
4.
Date:
Request submitted on June 21, 1993.
Approval dated July 14, 1993 has been received.
i I have responded to the request for correcting problems that have led to i
violations.
If you need further information or these corrections are not satisfactory please notify me and I will make the adjustments necessary.
Since 1
Rosa de Foster i
ALPHA QUALITY SERVICES (707) 448-5500 VACAVILLE, CA.