ML20059A358
| ML20059A358 | |
| Person / Time | |
|---|---|
| Site: | 03032546 |
| Issue date: | 10/07/1993 |
| From: | Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Grass C QUALITY INSPECTION & TESTING |
| References | |
| NUDOCS 9310260310 | |
| Download: ML20059A358 (1) | |
See also: IR 05000290/2038001
Text
.
,
.
Docket No.
030-32546
License No.
50-29038-01
Quality Inspection & Testing, Inc.
3111 Davis Road
Fairbanks, Alaska 99709
Attention:
Christian Grass, Radiation Safety Officer
Thank you for your letter of September 22, 1993, in response to our Notice of
Violation dated August 22, 1993, informing us of the steps you have taken to
correct the items which we brought to your attention.
Your corrective actions
will be verified during a future inspection.
Sincerely,
Cregory P. Yuhas, Chief
Radioactive Materials Safety Branch
bec w/ copy of ltr dtd 9/22/93:
Docket File
Inspection File
G. Cook
B. Faulkenberry
State of Alaska
bec w/o enclosure:
'
M. Smith
J. Zollicoffer
'l
TPruetk
GY h
lo /7/O
ID /7 /43
'
JND 10 DCS
SEND TO PDR'-
S
REQUEST COPY ~
REQUEST
REQUEST COPY
dt3 / NO
YES / NO
YES / N0
AtS / NO ' /TES, / NO 1
'
'
v
v
v
V
l
9310260310 931007
ADOCK 03032546
C
37E o'7
u
-
. .
.
'[
UNITED STATES
[L
- ,
NUCLEAR REGULATORY COMMISSION
'
5
l.
E
REGION V
3
e
g
S
8
1450 MARIA LANE
%,,,
8
WALNUT CREEK CALIFORNIA 94596-5368
AUG 2 21993
. . .
Docket No.
030-32546
License No.
50-29038-01
Quality Inspection & Testing, Inc.
3111 Davis Road
Fairbanks, Alaska 99709
Attention:
Christian Grass, Radiation Safety Officer
SUBJECT: NOTICE OF VIOLATION
This refers to the inspection conducted by Troy W. Pruett of this office on
August 4 and 6, 1993. The inspection included a review of activities
authorized for your Fairbanks, Alaska facility and observations of activities
during radiographic operations performed at Tank Farm Number 6, Eielson Air
Force Base, Alaska.
The findings were discussed with you and other members
of your staff at the conclusion of the inspection.
The inspection was an examination of the activities conducted under your NRC
license as they relate to radiation safety and compliance with the
Commission's rules and regulations and the conditions of your license. Within
these areas, the inspection consisted of selective examinations of procedures
and representative records, interviews with personnel, and observatien of
activities in progress.
Based on the results of this inspection, certain of your activities appeared
to be in violation of NRC requirements, as specified in the enclosed Notice of
Violation (Notice). The violations are of concern because they demonstrate
the need for you to be more familiar with the requirements specified-in
Department of Transportation (DOT) regulations as they relate to the shipment
of hazardous radioactive material.
You are required to respond to this letter and should follow the instructions
specified in the enclosed Notice when preparing your response.
In your
response, you should document the specific actions taken and any additional
actions you plan to prevent recurrence. After reviewing your response to this
Notice, including your proposed corrective actions and the results of future
inspections, the NRC will determino whether further NRC enforcement action is
necessary to ensure compliance with NRC regulatory requirements.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of
this letter and its enclosures will be placed in the NRC Public Document Room.
/
}-
4 '. 0 ~n oTZ ])() U 6 l
gg
m
-
a
_ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
_
..
_.
.
.
.
'b
..
2
The responses directed by this letter and the enclosed Notice are not subject-
to the clearance procedures of the Office of Management and Budget as required
by the Paperwork Reduction Act of 1980, Pub. L. No.96-511.
a
Sincerely,
kMC
'
Gregory P. Yuhas, Chief,
Radioactive Materials Safety Branch
l
Enclosure:
i
l
l
l
l
t
{
1
_ _ _ _ _ _ _ - .
1
-.
(
.
.
. .
h.'
4
,
'
Quality Inspection & Testing, Inc.
Docket No.
030-32546
Fairbanks, Alaska
License No.
50-29038-01
i
-:
During an NRC inspection conducted on August 4 and 6,1993, violations of NRC
,
requirements were identified.
In accordance with the " General Statement of
Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C,
the violations are listed below:
,
A.
10 CFR 34.42 requires, notwithstanding any provision in 10 CFR 20.204(c),
that areas in which radiography is being performed be conspicueusly
posted as required by 20.203(c)(1).
10 CFR 20.203(c)(1) requires that each high radiation area shall be
conspicuously posted with a sign or signs bearing the radiation caution
symbol and the words " CAUTION HIGH RADIATION AREA."
Contrary to the above on August 6, 1993, during radiography performed at
Tank Farm Number 6, Eielson Air Force Base, Alaska, the licensee did not
post the high radiation area in which industrial radiography was being
performed.
This is a Severity Level IV violation (Supplement'VI).
B.
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
i
applicable requirements of the regulations appropriate to the mode of
transport of the Department of Transportation (DOT) in 49 CFR Parts 170
through 189.
..
49 CFR 173.25 requires, in part, that for packages containing hazardous
i
materials and transported in an overpack, that the overpack be marked
with a statement indicating the inside (inner) packages comply with
prescribed specifications when specification packagings are required,
l
unless specification markings on inside packages are visible.
Pursuant
'
to 49 CFR 172.101, radioactive material is classified as hazardous
material.
j
Contrary to the above, as of August 4,1993, the licensee routinely
transported Gamma Century Model SA exposure devices containing up to 100
1
curies of iridium-192 in overpacks which were not marked with the proper
statement indicating that the inner package complied with the prescribed
specifications; and the markings on the inside package were not visible.
This is a Severity Level IV violation (Supplement V).
C.
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
Y
'~
fth$
f
-
. . .. .
'
.
2
delivers licensed material to a carrier for transport, comply with the
applicable requirements of the regulations appropriate to the mode of
transport of the DOT in 49 CFR Parts 170 through 189.
49 CFR 173.431 states, in part, that a Type A package shall not contain a
m
quantity of radioactivity greater than A for special form radioactive
3
material as listed in 49 CFR 173.435. The A quantity for iridium-192 in
3
special form is 20 curies.
Contrary to the above, as of August 4, 1993, the licensee routinely
transported greater than 20 curies of special form iridium-192 in Gamma
Century Model SA exposure devices, a DOT Type 7A package.
(93-01-04)
<
This is a Severity Level IV violation (Supplement V).
D.
License Condition 16 of License No. 50-29038-01 requires that licensed
material be possessed and used in accordance with statements,
representations and procedures contained in an application dated August
25, 1991.
Section 10, Item 10.1.1, of the license application dated August 25,
,
1991, requires, in part, that each radiographer be audited at intervals
not to exceed 90 days.
Contrary to the above, as of August 4, 1993, the RSO/ radiographer has not
been audited.
This is a Severity Level IV violation (Supplement VI).
Pursuant to the provisions of 10 CFR 2.201, Quality Inspection & Testing, Inc.
is hereby required to submit a written statement or explanation to the U.S.
Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C.
20555, with a copy to the Regional Administrator, Region V, 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
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 furthe violations, and (4) the date when full
compliance will be achieved.
If an adequate reply is not received within the
time specified in this Notice, the Commission may issue an order or a Demand
for Information as to why the license should not be modified, suspended, or
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.
Dated at Walnut Creek, California
3
this # day of August 1993
k-
h