ML20137S276
| ML20137S276 | |
| Person / Time | |
|---|---|
| Issue date: | 12/03/1985 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20137S260 | List: |
| References | |
| EA-85-124, NUDOCS 8512060202 | |
| Download: ML20137S276 (3) | |
Text
__
NOTICE OF VIOLATION AND PROPOSED IMPOSITIDH 0F CIVIL PENALTY De1 Monte Corporation General Licensee P. O. Box 9004 (10 CFR 31.5)
Walnut Creek, CA EA 85-124 As a result of a special safety inspection conducted at the DelMonte Corporation in Plymouth, Indiana during the period September 25 through October 10, 1985, several violations of NRC requirements were identified.
In accordance with the " General Statement of Po' icy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1985), the Nuclear Regulatory CommissionproposestoimposeacivilpenaltypursuanttoSection234ofthe Atomic Energy Act of 1954, as amended, ("Act'), 42 U.S.C. 2282, PL 96-295, and 10 CFR 2.205.
The particular violations and associated civil penalty are set forth below:
I.
VIOLATIONS ASSESSED A CIVIL PENALTY A.
10 CFR 31.5(c)(8) requires that a general licensee shall dispose of the
. device containing byproduct material only by transfer to persons holding a specific license pursuant to 10 CFR Parts 30 and 32 or from an Agreement State to receive the device.
~ Contrary to the above, a generally licensed device containing byproduct material was improperly disposed of in July or August 1985 when the licensee discarded the. gauge as scrap metal to a non-licensee.
This is a Severity Level III violation (Supplement VI).
Civil Penalty - $500 II.
VIOLATION NOT ASSESSED CIVIL PENALTY A.
10 CFR 31.5(c)(3) requires that the removal from installation of a generally licensed device containing radioactive material shall be performed in accordance with instructions provided by the label or by a person holding a specific license pursuant to 10 CFR Parts 30 and 32 or from a'n Agreement State to perform such activities.
Contrary to the above, a generally licensed Filtec gauge, S/N 105-150 containing 100 millicuries of americium-241 was removed from installation in May 1980 by individuals not authorized to perform such activities as provided by the label or by a person holding a specific license pursuant to Parts 30 and 32 or from an agreement. State.
8512060202 851203 IE GA999 EMVDMONT 99990003 PDR
. B.
10 CFR 31.5(c)(2) requires any person who acquires, receives, possesses or uses byproduct material in a device pursuant to a general license shall assure that the device is tested for leakage of radioactive material at no longer than six month intervals.
Contrary to the above, the licensee did not have leak tests performed by an authorized person at the required intervals.
Specifically, Filtec gauge S/N 105-150 containing 100 millicuries of americium-241 was not tested for leakage between May 10, 1980 and September 23, 1985.
This is a Severity Level IV violation (Supplement VI).
Pursuant to the provisions of 10 CFR 2.201, DelMonte Corporation is hereby required to submit to the Director, Office of Inspection and Enforcement, U.S.
Nuclear Regulatory Commission, Washington, D.C. 20555 with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region III, 799 Roosevelt Road, Glen Ellyn, IL 60137 within 30 days of the date of this Notice a written statement of explanation, including for each alleged violation:
(1) admission or denial of the alleged violation; (2) the reasons for the violation if admitted; (3) the corrective steps that have been taken and the results achieved; (4) the corrective steps which will be taken to avoid further violations; and (5) the date when full compliance will be achieved.
If an adequate reply is not received within the time specified in this Notice, the Director, Office of Inspection and Enforcement, may issue an order to show cause why the license should not be modified, suspended, or revoked or why such other action as~may be proper should not be taken.
Consideration may be given to extending the response time for good cause shown.
Under the authority of section 182 of the Act, 42 U.S.C. 2232, this response shall be submitted under oath or affirmation.
Within the same time as provided for the response required above under 10 CFR 2.201, DelMonte Corporation may pay the civil penalty by letter addressed to the Director, Of fice of Inspection and Enforcement, with a check, draft, or money order payable to the Treasurer of the United States in the cumulative amount of Five Hundred Dollars ($500) or may protest imposition of the civil penalty in whole or in part by a written answer addressed to the Director, Office of l
Inspection and Enforcement.
Should DelMonte Corporation fail to answer within the time specified, the Director, Office of Inspection and Enforcement, will issue an order imposing the civil penalty in the amount proposed above.
Should DelMonte Corporation elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalty, such answer may:
(1) deny the violation listed in this Notice in whole or in part; (2) demonstrate extenuating circumstances; (3) show error in this Notice; or (4) show other reasons why the penalty should not be imposed.
In addition to protesting the civil penalty in whole or in part, such answer may request remission or mitigation of the penalty.
. In requesting mitigation of the proposed penalty, the five factors addressed in Section V.B of 10 CFR Part 2, Appendix C should be addressed. Any written answer in accordance with 10 CFR 2.205 should be set forth separately from the statement or explanation in reply pursuant to 10 CFR 2.201 but may incorporate parts of the 10 CFR 2.201 reply by specific reference (e.g., citing page and paragraph numbers) to avoid repetition.
DelMonte Corporation's attention is directed to the other provisions of 10 CFR 2.205, regarding the procedure for imposing civil penalties.
Upon failure to pay any civil penalties due which has been subsequently determined in accordance with the applicable provisions of 10 CFR 2.205, this matter may be referred to the Attorney General, and the penalties, unless compromised, remitted, or mitigated, may be collected by civil action pursuant to section 234c of the Act, 42 U.S.C. 2282.
FOR THE NUCLEAR REGULATORY COMMISSION Qm.Ap gMrAw
(/ James G. Kepp Regional Administrator Dated at Glen Ellyn, Illinois s# ay of December 1985 this d
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U. S. NUCLEAR REGULATORY COPNISSION REGION III Report No. 999-90003/85-110(DRSS)
Docket No. 999-90003 Licensee:
DelMonte Corporation One Market Plaza San Francisco, CA 94119 Inspection Conducted:
September 25 through October 10, 1985 Onsite Inspection Conducted On: October 3, 1985 Located At:
DelMonte Corporation 306 W. North Street Plymouth. Indiana Inspector:
T.
L._ Simmons
[0/95/65 3
Radiation Specialist Date /
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O Reviewed By:
D. J. Sreniawski, Chief g
IO[M/83 Nuclear Materials Safety Datd Section 2
(
Approved By: W.L.Nxelon, IC
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Nuclear Materials Safety Date and Safeguards Branch Inspection Summary Inspection on September 25 through October 10, 1985 (Report No. 999-90003/85-110(DRSS))
Areas Inspected:
Special safety inspection of the circumstances involving a gauge containing radioactive material retrieved from a scrap yard.
This inspection included a review of records, letters and documents; and interviews with individuals involved.
The inspection involved a total of 21 hours2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br /> by one NRC inspector.
Results:
Three violations were identified:
(1) 10 CFR 31.5(c)(2) - failure to perform leak tests at required intervals (Section 3); (2) 10 CFR 31.5(c)(3) -
removal from installation by unauthorized individuals (Section 3); (3) 10 CFR 31.5(c)(8) - unauthorized disposal of byproduct material (Section 3).
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DETAILS l
i 1.
Persons Contacted F. Calhoun, President, Industrial Dynamics Co. Ltd., Torrence, California R. Ohms, Foreman, Milupa Corporation, East Troy, Wisconsin R. Filter, Plant Manager, Milupa Corporation, East Troy, Wisconsin J. Newton, QA Manager, De1 Monte Corporation, Dayton, New Jersey
- K. Peacock, Plant Manager, De1 Monte Corporation, Plymouth, Indiana
~
- D. Stevenson, Engineer, De1 Monte Corporation, Plymouth, Indiana l
P. Martin, De1 Monte Corporation, Plymouth, Indiana M. Morris, Manager, Franklin Scrap Yard, Plymouth, Indiana J. VanKirk, Driver, Franklin Scrap Yard, Plymouth, Indiana i
B. Mervis, Manager, Mervis and Sons Scrap Yard, Kokomo, Indiana C. Holderead, Director, Civil Defense Office, Marshall County, Indiana R. Hudson, Civil Defense Office, Indianapolis, Indiana H. Stocks, Indiana State Board of Health l
W. Spain, Director, Corporate Quality Assurance and Regulatory Affairs 4
- Present at exit interview (via telephone).
2.
Purpose of Inspection This was a special inspection to review the circumstances surrounding an americium-241 gauge found in a scrap yard.
This incident was reported to NRC Region III by the Indiana State Board of Health on September 25, 1985.
3.
Inspection Findings I
A 100 millicurie americium-241 gauge was discovered at a Kokomo, Indiana l
scrap yard on or about September 19, 1985.
The gauge was part of a load of scrap sent there for cutting by the Franklin Scrap Yard of Plymouth, Indiana.
The gauge was returned to Plymouth by a Franklin Scrap Yard driver on September 20, 1985 because it was labeled " radioactive material."
Yard perscnnel notified the local Civil Defense Office the following Monday (September 23).
Civil Defense personnel, upon confirming that the device was radioactive, transported it to the Indiana State Board of Health (see Attachment A - Civil Defense report).
Indiana State Board of Health (ISBH) personnel performed a leak test, a radiation survey, and photographed the device (see Attachment B - ISBH memo and photos).
No leakage was detected.
They also arranged to ship the device to the manufacturer.
Upon receipt, l
the manufacturer verified the integrity of the source (see Attachment C -
leak test results).
It was determined by device and source serial numbers that the gauge was purchased from Industrial Dynamic Company, Ltd. of Torrence, Cali-fornia by RJR Foods of Winston-Salem, North Carolina in 1979.
The device was installed by the manufacturer in a plant located in East Troy, I
Wisconsin (see Attachments D and E).
2
The gauge was removed from installation sometime after March 8, 1980 by RJR Foods /De1 Monte personnel and placed into storage at its Dayton, New Jersey plant (see Attachment F).
Removal of a generally licensed nuclear gauge from installation by a general licensee is in violation of 10 CFR 31.5(c)(3), which states that the removal from installation of a generally licensed device containing radioactive material shall be performed by a person holding a specific license or an Agreement State licensee to per-form such activities.
At some time after October 1980 the gauge, along with other surplus equipment, was transferred to the DelMonte plant in Plymouth, Indiana where it was placed in storage.
In August 1985, De1 Monte personnel discarded the gauge as scrap which was sold to Franklin Scrap Yard.
Disposal of licensed material in this manner is a violation of 10 CFR 31.5(c)(8), which states that a general licensee shall dispose of the device containing byproduct material only by transfer to persons holding a specific license or an Agreement State to receive the device.
In addition, the last leak test of the gauge was performed in March 1980 by the manufacturer.
No leak tests were performed while the gauge was in storage.
Failure to perform six month leak tests is a violation of 10 CFR 31.5(c)(2), which states any person who acquires, receives, possesses or uses by product material in a device pursuant to a general license shall assure that the device is tested for leakate of radioactive material at no longer than six month intervals.
Three violations were identified.
4.
Exposure Estimate The only person determined to be in proximity of the gauge was the driver who transported the device from Kokomo, Indiana to Plymouth, Indiana.
The driver stated that the trip took about 1-1/2 hours and that the gauge was on the front seat, four feet away from him.
It is not known whether the device was in the on or off position at this time.
However, the device was in the on position when confiscated by the ISBH.
Accordingly, assuming that the device was in the on position, the following exposure estimates were made based on the Indiana State Board of Health's radiation survey:
The source is 0.8 inches from the surface of the device.
The radiation level was 200 mR/hr at the surface of the device.
Theexposurerate(E]calculatedforadistanceof4ft.wouldbe:
E = 200 mR/hr (0.8") = 0.06 mR/hr
( 48")2 3
The dose (D) to the truck driver would be:
D = 0.06 mR/hr 9 4 ft. x 1-1/2 hrs.
D = 0.08 mR @ 4 ft.
Worst Case:
device 2 feet from driver D = 0.33 mR @ 2 ft.
In both cases, driver at 4 ft. or at 2 ft., would have resulted in a dose to the driver of less than 0.5 mR which represents no significant health hazard.
5.
Exit Interview On October 3, 1985, the inspector met with those individuals denoted in Sect. ion 1 of this report.
The discussion included a review of the incident, the licensee's corrective measures taken, and potential NRC enforcement action.
This matter was also discussed with Mr. W. Spain, Director, Corporate Quality Assurance and Regulatory Affairs on October 4, 1985. Mr. Spain submitted, in a letter dated October 7, 1985 (see Appendix 3), further corrective measures to be taken by De1 Monte.
6.
Enforcement Conference An Enforcement Conference was held by telephone on October 21, 1985'to discuss the findings of an NRC special safety inspection conducted os September 25 through October 10, 1985.
The conference was conducted between Messrs. Spain and Fish of DelMonte's staff, and Mr. J. A. Hind and members of the NRC Region III staff.
The purpose of the conference was to (1) discuss the apparent violations, their significance and causes, and the licensee's corrective actions; (2) determine whether there were any aggravating or mitigating circumstances, and (3) obtain other informa-tion which could help determine the appropriate enforcement action.
Mr. J. A. Hind, Director, Division of Radiological Safety and Safeguards, opened the conference by describing the purpose and scope of the meeting as well as the NRC enforcement policy and concerns raised as a result of the September 25 through October 10, 1985 inspection.
The apparent violations were reviewed with the licensee.
The licensee representatives were not in disagreement with the facts as stated.
The licensee representatives were informed that the unauthorized removal and disposal of the gauge could represent a Severity Level III violation pursuant to NRC policy.
4
n 4
b Attachments:
A.. Civil Defense Report B.
Indiana State Board of Health Memo and Photographs of Device 1
C.
Industrial Dynamics Co.
Ltd. Leak Test Results D,' Industrial Dynamics Co.
Ltd. Shipping Record E. Industrial Dynamics Co.
Ltd. Service Record 4
F.
Correspondence /Milupa and RJR Foods Appendix:
1.
Chronology of Events
,Concerning Filter Gauge
- 2. *5 ample Package Sent to
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General Licensees by t
Industrial Dynamics 3.
De1 Monte Corporation Letter dated 10/03/85 e
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STATE -
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INDIANAPOLIS,46204 I B DEPARTMENT OF CIVIL DEFENSE
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TELEPHONE: (317)232-3830 90 STATE OFFICE BUILDING 100 NORTH SENATE AVENUE October 9, 1985 Ms. Toye Simmons Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137 RE:
Radioactive Source Investigation Plymouth, Indiana 9/23/85
Dear Ms. Simmons:
On September 23, 1985 this office was contacted by Mr. Creighton Holderead, Director, Marshall County Civil Defense.
Mr. Holderead reported to Phil Roberts, Deputy Director, that a suspected radioactive source had been found at the scrap metal yard of Harry B. Franklin Co.,
Inc., 505 W.
Garro, Plymouth, Indiana.
Mr. Roberts contacted me at the Radiological Instrument Maintenance & Calibration Shop to inform me of Mr. Holderead's call. I contacted Mr. Hol-l deread, who informed me he was detecting the presence of radiation from this unknown source with the Civil Defense type instrument, CDV-700.
I then contacted Hal Stocks, Radiological Health Officer, State Board of Health.
He asked if I or someone from my department could follow up on this matter.
Dave s
Yount and myself went to Plymouth, Indiana.
We performed some basic wipe tests in and around the source. Wipes were tested with a Wm. B. Johnson GSM-5.
No radiation was de-tected on any of the wipes.
The source containment was clearly marked 100 milli-curies of AM-241, manufactured 1/18/79.
Information on the front of the device was:
Industrial Dynamics Co., Ltd.
l 2927 Lomila Boulevard l
Torrance, Falifornia Serial #105-150 Model FT-12 l
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y OCT U ATTACHMENT A
Ms. Toye Simmons October 9, 1985 We placed the device in a plastic bag; then into a cardboard box, monitored the surface areas and returned the device to Hal Stocks in Indianapolis.
On Wednesday, Sep-tember 25, 1985, Mr. Stocks contacted the Nuclear Regulatory Commission.
Mr. Stocks reported to me that the device had been sold by Industrial Dynamics Co. to the R. J.
Reynolds Food Co. of Dayton, Ohio.
Mr. Stocks contacted Industrial Dynamics Co. who furnished a shipping container for return of the device to them for proper disposal.
On September 26, 1985 material was shipped to Industrial Dynamics Co. from the Indiana State Board of Health.
Sincerely, rnu.Ad 0.
Ronald D. Hudson RADEF Officer RDH/ew i
+3 STATE BOARD OF HEALTH INDIANAPOLIS OFFICE MEMORANDUM DATE:
October 9, 1985 TO:
Woodrow A. Myers, Jr., M.D.
THRU:
Virgil J. Konopinski Ralph C. Pickard FROM:
Hal S. Stocks
SUBJECT:
Incident Involving Radioactive Source e
Ronald Hudson, Indiana Department of Civil Defense (IDCD),
contacted me on Monday, September 23, 1985, concerning a source of radioactive material found at a scrap yard in Marshall County.
I told Mr. Hudson that the proper course of action was to check for contamination on the finder of the source and on the county CD director who handled it.
After insuring that this contamination or any contamination in the vicinity of where it was found did not exist, I instructed him to then place the source in a plastic container and transport it to the ISBH. We would then identify the source and take appropriate action.
Mr. Hudson retrieved the source himself, following directions carefully, and delivered it to the Radiological Health Section. The source appeared to be part of a radioactive gauge utilized for density or moisture determinations.
It was labeled " Caution, Radioactive Material", 100 mci Am-241, Serial Number 105-150, Model FT-12 Industrial Dynamics Company, Torrence, California.
I called Darrel Wiedeman from Region,III, U.S. NRC in Glen Ellyn, Illinois, and recited the above information. The following calibrated Ludlum Geiger readings were reported to Mr. Wiedeman: open Geiger tube, source container closed, read 0.2 mR/ hour at surface; open Geiger tube, source container opened, read 200 mR/ hour at surface; closed Geiger tube, source container opened, read 30 mR/ hour at surface.
In a short time Mr. Wiedeman called and said the instrument was manufactured under a California Agreement State License, 1586-70 GL.
It was sold to R. J. Reynolds Foods in Dayton, New Jersey.
R. J. Reynolds told Mr. Wiedeman that the device had been sold to the Milupa Corporation in East Troy, Wisconsin. Milupa attested that the source had been returned to R. J. Reynolds Foods.
Mr. Wiedeman assigned the task of finding how the device ended up at the Harry B. Franklin Scrap Metals facility in Plymouth, Indiana, to Ms. Toye Simmons, a health physicist investigator on his staff.
Mr. Wiedeman gave a telephone number for Industrial Dynamics.
When called, they promised me a source container to ship the source back to them.
Michael Grider, ISBH photographer, produced photographs that displayed every number and letter on the device. The Radiological Health Section is appreciative of the excellent and prompt actions by 0[rT 151985
= 1 of the invo ved Parties and wishes to commend them.
I bec: Toye Simmonst Ronald Hudson ATTACHMEMENT B
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INDUSTRIAL DYNAMICS COMPANY, LTD.
2927 LOMITA BOULEVARD TORRANCE, CALIFORNIA 90509 LEAK TEST AND SOURCE INSPECTION CERTIFICATE (LAST RECORDED) 1.0 CUSTOMER NAME AND ADDRESS:
2.0 WIPE TEST AND CERTIFICATION _ DATA:
RJR Roods, Inc.
2.1 WIPE TEST & SEAL (S) AFFIXED BY Dayton - Jamesburg Road 2.2 DATE OF WIPE TEST 9/30/85 Davton. New Jersev 2.3 RADIATION MEASUREMENTS MADE BY Larry Schmehl ATTN: Mr. Jerry Paris 2.4 DATE OF MEASUREMENTS 9/30/85 CHECK IF NEW CONTACT 3.0 SOURCE *(100 MC AM-241) AND MACHINE DESCRIPTION:
- 0.005 /4Ci = 0.185 Kbg 3.1 3.2 3.3 3.4 3.5 3.6 3.7 3.8 3.9 SOURCE SHUTTER LABEL (S)
WIPE TEST PLASTIC CONDITION LEAD MACHINE S/N SOURCE S/N MOD. NO.
CONDITION CONDITION DATA *
- WINDOW INSIDE UNIT SEAL 6110 6765 MAN AUTO OK REPL OK
).005 c OK REPL OK REPAIR AFFIXE 3
3 105150 2816 X
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Source returned to IDC on 9/30/85 CERTIFIED BY:
MM M__/3_g;-g Fred L. Calhoun by Mr. Hal Stocks, Indiana State Bd. of Hlth.
Source located inside Inspection Head of Machine at TITLE: Radiation Safety Officer j
- Form No. 072 (6/84) Harry D. Colton Scrap Metals / Plymouth, IN.
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r3 gyg 3 IN DU STRI AL DYN AMICS Company, Ltd.
B27 LOMITA BOULEVAND. TORRANCE CALIFORMI A 90509 U.S.A.
. TELEPHONE: 213 325-5633. TWX; 910- 347 6230 IN DU SCO INVOICE 11926/M/A co RJR FOODS, INC.
g P.O. 80X 5037 8,T,fo 5 71216 a
WINSTON-5 alt'M, N. CAROLINA 27102 Y
C INVOICE DATE RJR POODS, IND. C/0 MILUPA CORP.
0 200 NORTH BEULAH STREET SHIPPING DATE EAST TROT, WI 53201 NET 30 T
ATTN:
MR. PHIL BOWMAN ~
TEnus:
y" ATTENTION PLANT PERSONNEL: DO NOT OPEN-0 SEALED RADIOISOTOPE SOURCE-HOLD POR F.O.B. POINT:
Terrence, Californie EMC IDC PIELD SERVICEMAN 1" PLE ASE Pay FROM eNvolC E. NO ST AT E M ENT WILL SE SENT y,y.
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$ 500.00
$ 500.00 100 MILLICURIES OF AMERICIUM 241.
DISTRIBUTED UNDER CALIFONIA GENERAL LICENSE GL 1586-70.
NOTE: THESE SOURCES ARE FOR THE FOLLOWINO MACHINE SOURCE S E R I AL NUM ER SERIAL NUMBER 105150 2816 AIR FREIGHT
-COLLECT-95038607 TOTAL AMOUNT DUE:
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SERVICE OFFICE PHO PURCHASE ORDER NO,
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"1: 31 RECD RJR Foods, Inc.
Winston Salem, N. C. 27102
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March 28, 1980 Mr.
C. R. Johnson, President Milupa Corporation 48 Church Street Canajoharie, NY 13317
Dear Mr. Johnson:
This letter is to confirm our oral agreement with Bob Pekel, of Milupa Co rpo ra t ion, to terminate our copacker agreement, dated May 25, 1979.
The effective date of termination is April 1, 1980.
No further production will be needed at your facility.
You have produced more than the 960,000 5% oz. bottles of Milk Mate guaranteed in the Agreement.
25,019 cases of 20 oz.
bottles were produced against the guarantee of 200,000 cases.
As the Agreement calls for a reimbursement of $0.05 per case the shortf all, we owe Milupa $8,749.05.
Please invoice on us for this amount.
Roger Simmons will contact Bob Pekel regarding the disposition of the equipment.
We have enjoyed our association with you and your people.
Si cerely,
- ' W James A. Merrill Director of Manufacturing JAM
- ne cc:
Mr. Bob Pekel 9
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2004 N. BEULAH AVE.
E. TROY. WISCONSIN 53120 414/642-7341
-2..
=j May 9, 1980 Mr. Jim Merrill RJR Foods, Inc.
P.O. Box 3037 Winston-Salem, NC 27102
Dear Mr. Merrill:
c We wish to inform you that all equipment and accessories belonging to RJR Foods has been removed and shipped from the East Troy facility (Milupa Corp. - Warehouse 424). This was done under the supervision of Mr. Jerry Parris. Effective May 9, 1980 there is no equipment or accessory belonging to RJR Foods remaining at the East Troy facility.
I wish to thank you for your cooperation and also inform you that Mr. Parris was very instrumental in the swift and effective removal of the equipment. He was very cooperative and knowledgeable l
in his job. He is an excellent representative of RJR Foods, i
l Sincerely,
[
.4 l.
~.
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- (
R. J Pekel Operations Manager l
l cc: E. Woods C. R. Johnson i
l 1
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l b ihl
DRAFT Chronology Gauge S/N 105150 - Source No. 2816 1979 Industrial Dynamics, Ltd. Torrence, CA sold a fill level gauge containing 100 mci Am-241 to RJR Foods, Wiston-Salem, N.C.
Industrial Dynamics, Ltd. installed the unit at Milupa Corp., East Troy, WI on 7/30/79 198o - Mel RJR Foods merged with Del Monte Corp.,
RJR Foods / Del Monte removed the gauge from Milupa Corp. 5/30 and transferred it to Del Monte Corp, Dayton N.J. where it went into storage.
1982 The gauge was sent to Del Monte, Plymouth, IN where it was placed in storage.
1985 i
l 8etween 7/5/85 and 8/21/85 gauge was discarded in dumpster provided by Franklin Scrap Yard The dumpster was picked up at Del Monte 8/21/85 I
Dn 9/17/85 Franklin Scrap Yard sent scrap to Mervi8 & Sons scrap yard located in Kokomo, IN APPENDIX 1
DRAFT
\\
Between the 17th and 20th Mervis & Sons discovered the gauge.
Mr. Mervis contacted Mr. Morris of the Franklin Yard.
Mr. Morris sent a drivendown to pick it up.
Mr. Morris contacted the Civil Defense office.
p ou o g.4..w.cs.
Mr. Holderead,took the gauge to his office and contacted the state Civil Defense office in Indianapolis. Mr. Ron Hudson of the Indianapolis Civil Defense transported the gauge to the Indiana State Board of Health on 9/23/85.
Mr. Hal Stocks took possession of the gauge.
His office performed a survey and a leak test.
The survey results are as follows:
Gauge in the on position:
surface (probe window open) 200 ar/hr surface (probe window closed) 30 ar/hr Gauge in off position:
surface (probe window open) 0.2 ar/hr Measurements taken with a Ludium - last calibration date 1/85 Leak test results:
less that.005uCi l
Region III notified 9/25/85 t
l On 9/26/851,SBN shipped gauge to Industrial Dynamics Ltd.
i On 9/30/85 manufacturer leak tested source results: <.005 uti l
l l
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INDUSTRIAL DYNAMICS COMPANY, LTD.
2927 Lomita Boulevard
- P.O. Box 2945
- Torrance, Cahfomia 90509 2945 U.SA Phone:(213) 325 5633
- Telex Int!. 4720345
- NA 664205
REFERENCE:
FILTEC MODEL FT-12 Inspection System Serial No.
103411 SOURCE Serial No.
1220 RJR FOODS, INC.
Date October 03, 1985 506 W. North Street Plymouth, Indiana 46563 Attention:
Mr. Paul Crane
Dear Sir:
Industrial Dynamics' FILTEC utilizes a radioisotope as a source of radiation.
This radioisotope source (SOURCE) is distributed to you under a General License issued to us by the State of California. As a General Licensee, using a generally licensed device, you must operate and maintain the FILTEC in accordance with the rules and regulations set forth by your Regulatory Agency.
These regulations require that you register the SOURCE within 30 days after its receipt!
This is your responsibility and should be attended to immediately!
We have supplied information to assist you in the registration of the SOURCE, but if you should require additional data, please contact us immediately.
We have enclosed the Registration Forms and instructions X
for registering the SOURCE in your state.
Please complete the forms and mail to your State Agency.
l N/A Please contact your Regulatory Agency (see enclosure) and l
request the necessary Registration Forms and instructions for registering the SOURCE.
(Your Agency prefers to send
(
the necessary forms directly to you.)
The following information is enclosed pertaining to the FILTEC and its i
SOURCE.
File them in a safe place for future reference.
1.
Industrial Dynamics' "FILTEC Radioisotope Source Information Manual".
2.
Radiation Rules and Regulations applicable to your FILTEC.
(
3.
The address and telephone number of the nearest office of Agency having regulatory responsibility for your SOURCE.
Continued........
APPENDIX 2 fike6
i The specifications on the FILTEC and its SOURCE are listed below:
Name and Model of Machine ----------------------------FILTEC, Model FT-12 Radioactive Material (Ceramic Enamel Form) -----------Americium-241 Sealed SOURCE Model No.
06110 Quantity of Radioactive Material ---------------100 Millicuries ea.
Use-----------------------------------Gamma Density Measuring Gauge Industrial Dynamics' General Distribution License No.-GL1586-70 The FILTEC will be shipped to your plant without the SOURCE.
This allows your plant personnel to begin preparation for machine installation prior to the arrival of our Field Service Representative.
When you are prepared to install and check out the FILTEC, please contact our Field Service Department to confirm an installation date.
Once the installation date is confirmed, the SOURCE will be sent to you by the following method:
The SOURCE will be shipped by Air Freight directly to your X
plant and marked to your attention.
You should place the SOURCE in a safe place (a locked area with limited access) until our Service Representative arrives.
DO NOT OPEN THE SOURCE PACKAGE.
If the package is damaged, please notify us immediately!
Our Field Service Representative will hand carry the SOURCE
.to your plant for installation and checkout.
Other:
IMPORTANT NOTICE Regulations prohibit the installation of the SOURCE in the FILTEC unit by unqualified personnel.
Industrial Dynamics' or other qualified agents must be employed to install the SOURCE in the machine.
Once the SOURCE is installed, dismantling or relocation of the FILTEC unit or maintenance and tests involving the SOURCE shall be performed by persons specifically licensed by the Nuclear Regulatory Commission or your State Agency.
Attachments to this letter show the information given on the label (s) af fixed to your FILTEC equipment.
The information on the label (s), as well as the other enclosed data, should be carefully studied to insure that you comply with all the radiation regulations and that proper operation and maintenance on your FILTEC unit is achieved.
Continued.
I
One very important regulation will be mentioned regarding the radiation leak test requirements on the SOURCE.
A leak test will be performed when the FILTEC is installed, and the tests must be conducted at six month intervals thereafter.
These tests must be made by an agency authorized by your state or the Nuclear Regulatory Commission to conduct wipe tests on Americium-241.
If you are unable to locate such an agency near your installation, Industrial Dynamics is authorized to make these tests.
Yours very truly, INDUSTRIAL DYNAMICS COMPANY, LTD.
Y 4
W Fred L. Calhoun Radiation Safety Officer FLCrab Enclosures i
l T
I i
i IDC Form 073 (1/79) l
EXCERPTS FROM TITLE 10, CODE OF FEDERAL REGULATIONS UNITED STATES NUCl. EAR REGULATORY COMMISSION RULES and REGULATIONS TITLE 10. CH APTER 1. CODE OF pWDERAL REOULATIONS-EsstlHBY PART GENERAL DOMESTIC UCENSES FOR BYPRODUCT MATERIAd 31 8**-
manufactured for the purpose of 8 31.3 Certain devices and equipment.
31.8 perpene and ecepe.
goggeting, measuring, seusing or 33.s Twine and comanisene.
A pneral bcense is hereby issued to controning * ' density, level, inter.
33.3 cene a devises sed eeulement.
transfer receive, acquire, own, possess and 33.s cerista maneurtas.seusms or eeneremas use byproduct material incorporated in I" * "**
9"*"
31.4 ceneral aissans to tastall e m ese sea-the fouowing devices or equipment which compostion, or for producing light or an
, amar inneaned na i 31.s.
have been saanufactured, tested and g
31.1 Leannome setery devera fw une la labeled by the manufacturer in ac-eerests.
cordance with the specifications con *
(b) The seseral bcense in paragraph 33.s es.tet in me et entiare-tained in a specific license ismaed to him (a) of this section applies only to by-33.s cenast ineesee se own arpeeduct,me.
by the Coaunission.
product amaterial contained in devices entat.
(a) Steric eliminerion device. Devices which have been manufactured or st.no ceawai heenes tw streouse.oo is nee l designed for use as static aliminators initially transferred and labeled in ac-si.it ceIn:
zwhich conth, as a saaled mum w sources, bypaduct material conasting of,,,cordance with the specifications con-tw use of arpeedvet a total of not more than 500 microcuries j;.tained in a specificlicense meseness tw sertaea la votre chancel 3 er neaeresery sesums.
to i 32.51 of this chapter or in ac-of polonium 210 per device.
- cordance with the specifications con-Aimenarry: seen. st. Ist. Ias es asas. sas.
(b) [ Deleted 34 FR 6651.1 f* tained in a specific license issued by an tea. 9as, as ameneses; 43 UAC. Silt. 2301 assa. por the puremsen et one. 233. as stas.
(c) (Deleted 35 FR 3982 l Agreement State which authorizes saa, as amenese. e2 UAC. 3:13. al.aramas.
(d) lon generating rde. Devices de-distribution of the devices to persons
$8d"",,d,31 g, e signed for ionization of air which contain 1
t prierally licensed by the Agreement e
3ee,,gnen,,s nos.a.
as a eseled source or sources, byproduct State.
material conasting of a total of not mors
=
3 31.1 Purpose and scope.
than $00 amicrocunee of polonium 210 " (c) Any person who acquires. receives, This part establishes pneral licenses per device or of a total of not more than possesses, uses or transfers byproduct l~for the possession and use of byproduct 50 millicuries of hydrosen.3 (tritium)per material in a device' pursuant to the matenal contained in certain items and a jev)ce.
pneral licante in paragraph (a) ef this n* seneral license for ownership of by-31.4 [ Deleted 34 FR 16893.)
section:
E product material. Part 30 of this chapte
.5 Certain snessurins. seusing or (1) Shall assure that alllabels affixed also contains provisaons applicable to th
,,g,,ggg,, g,,i,,,,s to the device at the time of receipt and mabject matter of this part.
bearing a statement that removal of the M A pd he h My W h pmh m maWW thmon 3 31.2 Terms and seeditions.
to commercial and industrial firms and research, educational and medicalinstitu h*"j[
(a) The, seneral bcenses provided in
.;this part are sabject to the provtston of l tions, intividuals in the conduct of theit (2) Shall assure that the device is Il 30.14(d), 30.34(a) to (e), 30.41, a business, and Federal, state or local 9 tested for leakage of radioactive material 3
m,30.51 to 30.63 and Parts 19,20, and 21; of this chapter' unless indacated other. g sovernm
'and proper operation of the on off Possess, use of transfer, in accordance mechansen and indicator, if any, at no wise in the language of the seneral li-with the praetsions of paragraphs (b),(c) noe and (d) of this section, byproduct me-lonpr than sia enonth intervals or at ruch 1
tenal contained in devices designed and other intervals as are specified in the Asientwa e serested pan 6eulertr se se label;however; preemeene of one rervieueas in part to of sans
'Pwe*as penemanas appredest meintal la (1) devices containing only krypton sassier wmen retene to the levelins of eaa. emew onew the seawat liesem en i 31.s need not be tested for leakage of radao-
.a ne,,'
a.rwe s. is. on mer...ua e se use w evenern east metenalin neweena wtan active material, and oe reeuveawnee of I ss.s in effect en sea.14, (ii)' devices contauung only tritium or
)
- sets, not more than 100 microcunes of other beta and/or samma ematting matenal or
)
za september t 1982
______________.y_._
EXCERPTS FROM TITLE 10, CODE OF FEDERAL REGULATIONS PART 20 o STANDARDS FOR PROTECTION AGAINST RADIATION A
(1) A description of the licensed ma-
~ M NW" b' "N*
~
~~
(8) R*"'Es *f disposal of haamaad terial involved. including kind. quand-Each Incensee shall within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />
, noufy by telephone and telegraph.
ty, chemical, and physical form:
1
.: meterials made permat to il suor.
(2) A descripuon of the circum-l[ mantrain, or faenn. W Dinctor of e
g ll: stuos. someved I an.aos.' and Part et of stances under which the loss or theft. the appropriate NRC Regional Office a this chapter are le be maintelmed untG occurred a listed in Appendix D of this part of
' the Consmissies authorises telt (3) A statement of disposition or '. any incident involving bcensed materi-O disposities.
probable disposition of the licensed '. al possessed by him and which may (4) Radiation exposures to individ- [have caused or threstans to cause:
material involved:
uals, circumstances under which the
~ 1) Exposure of the whole body of exposures occurred, and 2e extant of
(
possible hasard to persons in unres-any individual to S rems or more of ra.
~
(4) Records which must be main.
tHeted aN disuon: exposun of the skin of the (S) Actions which have been taken, whole body of any inevidual to 30 taand pursuant to 21s part may be or will be taken, to recover the Insteri-rems or more of radiadon; or exposure Se original or a reproduced copy w
'UI Th i
ithe or form is espable of producing a clear 3 of Besaned material.
. alin concentrauens which,if averaged and legible copy after storsge for the
- over a period of 34 hours3.935185e-4 days <br />0.00944 hours <br />5.621693e-5 weeks <br />1.2937e-5 months <br />, would (c) Subsequent to fDing the written h exosed EM Uma h Hans spech period specified by Comunission regu*
report the licensee ahan also report l
f adens.
any substantive addiuonal informa.
fw such matadals k Appendix 3 a (5) If there is a conflict between the Mon on the loss or theft which be.
Table II of his part; or
- a'ahaa's regulations in this part.
comes available to the licensee, within (3) A loss of one day or more of the a license condidon, or technical specif1-30 days after he learns of such infor.
operation of any facilities affected; or cauon, or other written Commission snation.
7
' approval or authorissuen pertaining (d) Any report fDed with the Com 2-(4) Damage to property in excess of to the retantion period for the same mission pursuant to this section shall ' 82.000*
type of record, the retendon period be so prepared that names of individ w=
specified in the regulations in this uals who may have receivsd exposure f*--(c) Any nwn W wnh the Com-part for such records shau apply to radiation are stated in a separate n unless the Comunission pursuant to part of the report.
2:nission pursuant to this section shall 8 be pnpand so that name of bd6 130.501. has granted a specific esemp-tion from the record retenuon require-a uals who have' received exposure to ra-ments specified in the regulauons.in diation wSI be stated in a separate this part.
403.Netlfleetiens ofincidents.
R part of the report.
Immediate notiAcation. Each 11 nsee shall immediately notify by I'(d) For nucleaIpower reactors H.
telephone and telegraph, mtDiram, or : censed under I S0.21 or i 50.22. the in-
).
403 Reports of theft er less of II*
facsimile, the Director of the appropri E eldents included in paragraph (a) and a
eeneed maserial.
m ate NRC Regional Office listed in Ap E paragraph (b) in this secuon shan in (a) Each Boensee sh&H report by *;pendix D of this part of any incident
- addluon be reported pursuant to invohing byproduct. source, or special :
telephone to the Director of the ap-nuclear material possessed by him and 8 i 50.72.
propriate Nuclear Regulatory Com-mission Inspecuan and Enforcement han caused or mastens use-g g,,,,4 gg,,,,,,gy
.Restonal Offlee listed in Appendix D 8 of this part. imroediately after its oc.
830.405 Repens of evertsposures and es-g currence becomes known to the licens.
(1) Exposure of the whole body of eenslee levels and eeneentrations.
oe any loss or theft of Ucensed materi.
any individual to 28 rems or more of I a)In addition to any notificadon re-radiation: exposure of the skin of the 3 qu(ired by i 20.403, each Ucensee shaU al in such quanudes and under such whole body of any individual of ISO s circumstances that it appears to the U.
consee that a substantial hasard asay rems or more or radiation: or exposure
- make a nport 2 wWung wnhin 30 result to persons in unrestricted areas.
of the feet, ankles, hands or forearms *. days to the Regional Offlee listed in Appendix D of this part. with a copy of any individual to 378 rems or snore to the Director of Inspecuan and En-of radiagon:or forcement. UA Nuclear Regulatory e (3) The release of radioacdve amatert.
Commission. Washington, D.C. 30888.
(b) Each licensee who is requires to
- al in sonoontrauens which. If averaged
,. 0,,f; snake a report pursuant to paragraph % over a period of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, would (a) of this secuen shan, within thirty exceed 8,000 times the limits specified (1) Each exposum of an indWual I t(30) days after he learns of the less or for such anaaerials in Appendix E, to radiauon in excess of W appucable i theft, make a report in wrlung to the Table II of this part; or limits in il 30.101 or 30.104(a) or the
' " appropriate NRC Restonal Offlee (3) A less of one working week or f.idual oscu' h as
. listed in Appendix D of this part with snore of the operauen of any facDiues of W
"8PUcahk Hans b
.ooples to the Director of Inspecuen ' pfessed; er
' and Enforcement; UA Nocher Regu. F g Il 30.103(aX1). 30.103(ax3). 30.104(b) latory Cosamission. Washinston. D.C.1 g or the Ucense:(3)lents of redisuon w a eencontrauens of radioacuve material 30858. setting forth the fonowing.n = (4) Damage to property in saceas of
- In a restricted area in excess of any on-g $300.000.
O other applicable Ilmit in the Beense.
s accuen NJH provleed for hurtal of g""
(4) any incident for which not.lfleation unau euaauuss of heenses matertans na seu.
is required by I 30.403; and (8) levels Meuee of its celeuen appears to uw yumana of radiation or concentrations of radio-Resisvun of Deseter so.1seo(46 FR 717821.
active material Iwhether or not involv-I SNI December 30,1982
INSTRUCT!OH5 FCII FIL!.I.MG CUT REGISTRATICN FORMS Return completed forms to: Indiana State Board of Health Division of Sanitary Engineering 1330 West Michigan Street Indianapolis 7, Indiana A.
PLEASE TYPE OR PRINT WITH SOINI' PENCIL OR BLACK INK.
B.
Fill out all the blanks applicable to yout installation. DO NOT USE CHECK MARKS.
C.
Attach sheets to the registration form if needed.
Item 1.
The owner shall mean the person or organization having by law the administrative con-trol of a source of radiation.
Item 2.
Radiation producing machines include x-ray machines, fluoroscopes, electron micro-scopes, x-ray diffraction apparatus. particle accelerators, reactors, etc. Radioactive ma-ter2als include those incorporated in devices such as radioactive static eliminators, thickness gauges, instruments, etc. The word " possess" as used here includes ownership, rental, or lease of any radiation machine or other radioactive materials. If the answer to this question is "no," insert "no" in the.pue provided, sign the space at the bot-tom 'of the form and mail to the State Board of Health.m-the-enclosed-envelope.
Item 3.
If your only use of radiation machines is as a test facility, the machines tested need not be listed under Items 6 or 7.
Item 4.
The " Person Responsib!c for Radiation Control" means the person to whom over.all re-sponsibility for radiation control is assigned. If ruponsibility for radiation control is divided, list additional names, addresses, and titles on a separate sheet and indicate to whom correspondence concerning radiation control should be directed. If same as owner,' insert "same."
Item 5.
If same as Item 1 or 4, insert "same as 1" or "same as 4".
" Installation" means n i
locntion or estab!ishment where one or more sources of radiation are used, cperated
~
or stored. A part of a building, en entire building. or a plant may be designated as an installation. If you have more than one installation, please prepare separate rag-istration forms for each installation. Where mobile sources are involved, locatan means central headquarters for the source.
i Item 6.
Under "Model" indiente year. Also under
- Model" enter letter "M" if mobile, letter "P" if portable and letter "F" if fixed.
"Use" means diagnostic, therapeutic, re-search, material analysis, industrial radiographic, inspection, etc. Under " Intensify-ing Screen Speed" insert the speed in terms specified by the manufacturer (slow, me-dium, fast). Under " Filter Thickness" indicate material and thickness in millimeters.
Under " Film Speed" indicate film speed in the terms specified by the manufacturer (regular, fast, very fast, ultra fast, etc.).
Item 7.
Other Radiation Producing Equipment. "Ty' pe of Machine" means electron microscope, x-ray diffraction instruments, particle accelerators, nuclear reactors, static eliminators, etc. Under " Rating" indicate the energy of the machine in Mev., and intensity in ma.
or roentgens per unit of time. If the radiation is produced by a radioactive materiel enter the isotope and the quantityin mi!!icuries.
Item 8.
- a. Indicate total amount of radium on hand at any one time regardless of whether it is owned, rented, leased, or stoled by the registrant.
- b. For " form of source" indicate whether needle, capsule, plaque, tube, etc.
Item 10.
Other Radioactive Materials. Include accelerator produced radioactive materials, nat-ural radioactive materials, radon, or any other radioactive materials not covered by Atomic Encrgy Commission license unless exempted from registration. Under "Chemi-cal or Physical Form" indicate if the source is sealed or unsealed and whether in solid, liquid, or gaseous form. Under " Maximum Quantity" estima*e the maximum 4
. quantity on hand at any one time during the past 12 months. Radon users should in-dicate maximum quantity obtained in any one shipment during the past 12 months.
Item 11.
"Ilave radiation surveys been made" means a survay of the occupied and adjacent t
nreas.
Signature If owner is other than.nn individual, the signature should be that of the manager or person of com;mrable status at the installation covered by the registration.
i c..
RADIOACTIVE MATERIAL REGISTRATION APPLICATION roR OFFICIAL USE Do Not Weise in Thes Spaca Matt ONE COPY TO-INDIANA STATE BOARD OF HEALTH.1330 W. MICHIGAN STREET, INDIANAPOLIS. IN. 46206. ATTENTION RADIOLOGICAL HEALTH, OlvlSION OF INDUSTRIAL HYGIENE AND RADIOLOGICAL HEALTH. UPON APPROVAL OF THIS APPLICATION. THE APF11 CANT WILL RECEtVE AN 15811 RADIOACTIVE MATERIAL REGISTRATION. AN ISRH RADIOACTIVE MATERIAL REGISTRATION IS ISSUED IN ACCORDANCE WITH THE GENERAL REQUIREMENTS %*tfAINED IN THE RADIATION CONTROL ACT OF INDIANA (IC 1918,13 1 2).
Co. Code! !
Reg.
- 1. (a) NAAAE OF REGISTRANT (Inststutson, hans hospetat, persort, etc.)
(b) ADDRESS Of REGISTRANT (includelap) 506 W. North Street RJR FOODS, INC.
Plymouth, Indiana 46563 Phonel l I l.1 1 I l.I I I I I Fac.
2 (a) COMPANY NAME AT WHICH RADIOACTIVE MATERIAL WILL BE USED (b) ADDRESS OF COMPANY WHERE USED (includelsp) phonel l l 1.1 I l 1.1 1 I I I
- 3. DEPARTMENT TO USE RADIOACTIVE MATERIAL 4.
NRC LICENSE NUMBER (S), IF ANY (Also rnostrecentamendenent.)
i S.
INDtVfDUAL USER (S} (Name and Torle of andendual(s) who mt! use or detectly supervuse use of
- 6. RADtATION PROTECTION OFFICER (Name of person desognaled as vadnation protect *on o!!*cer of radeoectove anseenats )
other that:induvedualuser.)
Phonel I I I.1 1 I I.1 1 I I i
- 1. SEALED SOURCE (Use addstronel sheets it requered.)
Mauimum Activity Storage Container Number of Element Moss #
(check appropriate unit)
Mtg Name
. ModelN Make and Model # (et available)
Type of Device These Devices C6 1
AIM 21411 1 10 10 I. I m ICi Ri Industrial Dynamics 06110 FT-12 FILTEC Fill C.
2 I
I I
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1.1 I
mci Level Insnector 3
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RADIOACTIVE MATERIAL (Use addelsonaisheetsitroquired.)
- 9. DESCRIBE PURPOSE FOR WHICH RADIOACTIVE MATERIALS AND/OR SEALED SOURCES WILL BE USED Masimum Activity Chemicalend/or Element Mese n (Check appropriate unit)
Physical Form l
I g
Fill Level Gauge (FT-12)
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Ri 11 Att INFORMAllON CONTAINED HEREIN. INCLUDING ANY SUPPLEMENTS ATTACllED HERETO, IS TRUE AND CORRECT TO THE DEST OF OUR KNOWLEDGE AND BELIEF BY:
lu t T AIT n'Atar t4At.tf sta IILM 3 TIILL OF (,tt:18tYitG Of TICfAL
RADIOACTIVE MATERIAL REGISTRATION APPLICATION FOR OrriciAL uSE Do Not Wnte in This Space WAIL ONE COPY TO-INDIANA STATE BOARD OF HEALTH.1330 W. MICHIGAN STREET. INDIANAPOLIS. IN. 46206. ATTENTION. RADIOLOGICAL HEALTH.
OlVISION OF INDUSTRIAL HYGIENE AND RADIOLOGICAL HEALTH. UPON APPROVAL OF THIS APPtl CATION. Tile APPttCANT Will. RECElVE AN ISGH RADIOACTIVE MATERIAL REGISTRATION. AN ISDH RADIOACTIVE MATERIAL RFCISTRATION IS ISSUED IN ACCORDANCE WITH THE GENERAL REQUIREMENT % %* STAINED IN THE RADIATION CONTROL ACT OF INDIANA (IC 1911.131-2).
Co. %II Reg.
- 1. (e) NAME OF REGISTRANT (fnsistutert term, hospsta( persort ofc.)
(b) ADORESS OF REGISTRANT (locludelap) 506 W. North Street RJR FOODS, INC.
Plymouth, Indiana 46563 pnonel i I 1.1 1 1 1.1 I I I I Fec.
2 to) COMPANY NAME AT WHICH RADIOACTIVE MATERIAL WILL BE USED (b) ADDRESS OF COMPANY WHERE USED (includelep)
Phonel I I l.1 l l 1.1 1 I I l
- 3. DEPARTMENT TO USE RADIOACTIVE MATERIAL 4.
NRC LICENSE NUMBER (S). IF ANY (Alsomostrecentamendment.)
S. INDIVEDUAL USLR(SI (Name and Tutte of andowedual(s) who wolt use or detectly supervise use of G.
RADIATDON PROTECTsON OFFICER (Name of person des *gnated as radsatron protecteon o!!>cer of radroectrve malenals.}
other than indowedualuser.)
pnonel i I l.1 I I 1.1 1 I I l
- 7. SEALED SOURCE (Use addetonal sheets streguered.)
Masimum Activity Storage Conta6ner Number of Element Mass #
(check appropriate unit)
Mig Name Model #
Malie eruf Model s (et availabse)
Type of Device These Devices 1
Cs A1M 21411 1 10 10 I. I m ICi Ri Industrial Dynamics 06110 FT-12 FILTEC Fill 2
Cs l
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I.I I
Ri Level Insoector 3
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1 Re S. RAOIOACTIVE MATERIAL (Use addersonalsheets if reguired.)
- 9. OESCRIBE PURPOSE FOR WHICH RADIOACTIVE MATERIALS AND/OR SEALED SOURCES Maximum Activity Chemical and/or WILL BE USED Element MostR (Chech appropriale unit)
Physical Form g
Fill Level Gauge (FT-12)
O 1
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Ri 11 Att INFORMATION CONIAINED Hf REIN. INCLUDING ANY SUPPLEMENTS ATTACHED HERETO.15 IRUE AND CORRECT TO THE DEST OF OUR KNOWLECGE AND BELIEF BY:
giA l f APPLt(;ANI T4AF.tE If4 :i t.: 1 Ilit t OF CLNiltVING Oll!CIAL
O DO'S AND DON'T'S DO.....
REGISTER RADIOISOTOPE SOURCE (S) WITH YOUR STATE / REG. AGENCY X
WITHIN THE SPECIFIED NUMBER OF DAYS (SEE LETTER AND/OR IMPORTANT NOTICE [ NOTE]) AFTER RECEIPT OF SAID SOURCE (S).
IF NECESSARY, CONTACT YOUR STATE / REG. AGENCY TOOBTAIN REQUIRED REGISTRATION FORMS FOR YOUR RADIOISOTOPE SOURCE (S).
COMPLY WITH ENCLOSED REGULATIONS REGARDING WIPE TESTS X
EVERY SIX MONTHS.
MAINTAIN COPIES OF ALL RECORDS, RECEIPTS, TRANSFERS, X
LEAK TESTS, ETC. PERTAINING TO THE RADIOISOTOPE SOURCE (S).
DON'T..
1.
RUN WIPE TEST ON RADIOISOTOPE SOURCE (S) YOURSELF UNLESS YOU HAVE A SPECIFIC LICENSE TO DO*SO.
2.
OPEN OR TAMPER WITH THE ENCLOSURE CONTAINING THE RADIO-ISOTOPE SOURCE (S).
3.
TRANSFER, ABANDON, OR DISPOSE OF THE RADIOISOTOPE SOURCE, EXCEPT BY TRANSFER TO A PERSON DULY AUTHORIZED TO RECEIVE SUCH DEVICE.
NOTE:
IF YOU HAVE ANY QUESTIONS CONCERNING THE ABOVE, PLEASE CONTACT INDUSTRIAL DYNAMICS.
i IDC Form 009 (11/78)
~.,
OFFICE OF AGENCY THAT HAS REGULATORY RESPONSIBILITY FOR YOUR RADIOISOTOPE SOURCE Indiana State Board of Health 1330 West Michigan Street Indianapolis, Indiana 46207 Attn:
Mr. Hal S. Stocks, Chief Radiological Health Section Division of Industrial Hygiene
& Radiological Health Telephon'e :
(317) 633-0150 1
(
NOTE:
RADIOISOTOPE SOURCE MU3T BE REGISTERED WITH THIS AGENCY WITHIN 30 DAYS AFTER ITS RECEIPT!
b
INDUSTRIAL DYNAMICS COMPANY, LTD.
2927 Lomits Boulevard
- P.O. Box 2945
- Torrance, Califomia 905092945 U.SA Phone: (213) 3255633
- Telex intt 4720345
- NA 664205 REGIONAL OFFICES For semi-annual wipe tests and/or service on your FILTEC equipment, please contact the office indicated below CALIFORNIA WISCONSIN Mr. Bob McKeand Mr. Al Natole Manager, Customer Service Regional Manager 2927 Lomita Boulevard 2040 W. Wisconsin Ave.
Torrance, California 90509 Suite 365 Milwaukee, Wisconsin 53233 (213) 325-5633 (414) 931-8990 CANADIAN 1
NEW JERSEY Mr. Graham Gore Mr. Ron Pokraka Regional Manager Regional Manager 200 Consumers Road 657 Bloomfield Avenue Suite 200 P.O. Box 348 Willowdale, Ontario Bloomfield, New Jersey 07003 Canada M2J 4R4 (201) 743-1222
)
(416) 491-4339 l
{
Mr. Don Webb i
Regional Manager 814 Sandtown Road Marietta, Georgia 30060 (404) 429-1974 l
429-1990 l
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L filtec J
SYSTEM RADI0IS0 TOPE SOURCE INFORMATION I
MANUAL MODEL FT-12
- J l
g' O 3%
TD INDUSTRIAL DYNAMICS Mt7 Larven Redsmed
- P.O. Bai345
- Tenence, Casorrde 9062945 USA
- Phone:(213) 355633
- Teles het 4720345
- NA 06420S Fonn #077 (4/85)
NOTICE This manual provides you, a general licensee, with information pertinent to the operation and safety requirements for your FILTEC Model FT-12.
The INTRODUCTION and RADIOLOGICAL SAFETY sections will familiarize you with details on the radioiso-tope source used in Model FT-12.
You have also been furnished, under separate cover, the appropriate Rules and Regulations regarding the use of the radioisotope source from the agency which has the regulatory responsibility for your area.
I i
INDUSTRIAL DYNAMICS COMPANY, LTD.
2927 Lomita Boulevard Torrance, California 90509 Telephone: (213)325-5633
+
TABLE OF CONTENTS 4
Page Introduction.
1 l
Radiological Safety 3
Fill Level Inspection System.
5 Inspection System Labels.
6
- a Radiation Notice Labels 7
Radioactive Material License.
8 Radiation Profiles.
11 Isodose Curves (Side View) 12 l
Isodose Curves (Plan View) 13 l,,
l, Major Assembly, Inspection Head U.F.
14 l
Assembly, So'urce Enclosure, Standard can.
15 l
Source Enclosure Assembly 16 l
l
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THE FILTEC MODEL FT-12 OPERATION AND MAINTENANCE MANUAL INTRODUCTION Inspection of fill level in moving containers without contacting
, them,is accomplished by passing the containers between a radiation source and a detector, where the radiation that penetrates the
.j container is affected in some way by the presence of its contents.*
The FILTEC FT-12 utilizes gamma radiation and a scintillation
/
detector to inspect fill level in applications where the character-istics of the container and contents make this type of radiation suitable.
X and gamma radiation (which are identical except for their origin) have been used for many years to measure density, thickness, and dimensions or levels.
Prior to the 1940's, however, the use of devices utilizing X and gamma radiation in industry was limited because of the cost, complexity and limited selection of radiation sources.
Since the 1940's, the availability of a number of low (radioisotopes) cost; artificially produced radioactive isotopes, ions of such devices.
has resulted in a large increase in the applicat Currently, gauges utilizing radioisotope sources to measure thickness, density or level are in widespread use in nearly every major industry.
Every scientific advance brings with it the necessity for certain precautions and controls to enable the full realization of its benefits without endangering life or property.
This was true of steam and electricity and is true for radioactivity.
Because the i
industrial use of radioisotopes is of relatively modern origin, the j'
manufacture and use of devices containing them are much more effec-y tively monitored and controlled by regulatory agencies than were earlier ucientific advances.
Thus, radiation materials and devices probably are safer than most potential industrial hazards, however, csrtain precautions must be observed for absolute safety and certain regulations have been established to promote their safe usage.
Both the precautions necessary to insure complete radiological safety when using the FILTEC FT-12 and the regulations which must be observed are quite simple.
Please read carefully the Radiological Safety instructions in this manual and see that all operating and mainten-ance personnel are advised of concerning portions that may apply to them.
It is recommended that the installation of FILTEC be supervised by an Industrial Dynamics' Field Engineer.
, Form 079 (10/78)
-4
/
l
(
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5 INTRODUCTION (Continued)
RESPONSIBILITY FOR OPERATIONAL ADJUSTMENTS OF THE FILTEC SHOULD BE DELEGATED TO ONE PERSON IN THE PLANT.
THIS PERSON, PREFERABLY SOMEONE IN A SUPERVISORY OR TECHNICAL CAPACITY, SHOULD BECOME THOROUGHLY FAMILIAR WITH ALL OF THE' OPERATING DETAILS TO INSURE OPTIMUM PERFORMANCE OF THE SYSTEM.
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1 Form 079 (10/78)
FILTEC MODEL FT-12 RADIOLOGICAL SAFETY The FILTEC FT-12 utilizes, as a-
+uurce of gamma radiation, a small quantity of the radioisotope Americium-241 sealed by double fusion welds into a special type 304 stainless steel capsule. The Americium-241 is in ceramic enamel form and its melting range is in the region of 900* to 1050*C.
This capsule is mounted in a cast aluminum enclosure at the end of the arm opposite the support column.
A shutter, operated by a rod which protrudes from the side of the enclosure, permits a narrow slit of radiation to pass
~
through the plastic window in the enclosure when the rod is pulled out (ON) and shuts off all radiation when the rod is pushed in.
(See attached drawings.)
There are two possible hazards from any radioactive material:
External (receipt of an excessive amount of radiation from a source outside the body), and internal (ingestion of radioactive
]
material into the body).
The FT-12 radioisotope is a relatively weak source of low energy (low penetrating power) radiation.
Further, the narrow slit (1/2" x 1/16") in the shutter greatly reduces the radiation everywhere except directly in front of the plastic window.
It is virtually impossible, under normal circumstances, to receive an appreciable radiation dose at a location other than directly in front of the plastic window when the shutter is open.
While it is recommended that personnel.do not place their hands in front of the plastic window when the shutter is open, as there is no necessity for doing so, it would require several hours for the hand to receive an excess radiation dose.
The primary potential hazard of radioactive material in general i
is ingesting them into the body where they can expose vital organs to their ionizing radiation at very close range.
This hazard is of primary concern where radioactive material exists in a form which cculd be absorbed into the body.
In the FT-12, however, the radionrtive material is sealed by double fusion welds into a stainless steel capsule.
At manufacture, and again at installation, this capsule is subjected to rigorous tests capable of detecting the leakage of five millionths of one percent of the contents. Thus, as long as the source capsule is not smashed or punctured in some way, there is essentially no danger of radioactive material being released.
As an additional precaution, the regulatory agencies require that some licensed individual inspect the source and shutter mechanism and conduct a leak test at periodic (six months) intervals, i l
Form 079 (10/78)
RADIOLC3ICAL SAFETY (Continued)
While the possibility is extremely remote that anything could happen to the FT-12 to create a hazard from the radioactive material it contains, the precautions are quite simple and should be adhered to as should the applicable regulations.
You have been supplied with a copy of the Rules, Regulations and registration requirements for your location, however, the following is a brief synopsis of the general requirements:
1.
Do not open or tamper with the enclosure containing the radioisotope source.
2.
Do not place the hands between the source and de-tector when the shutter is open (ON).
3.
Have inspection and wipe tests performed by a properly licensed person at the specified six (6) month intervals (Industrial Dynamics' personnel can do this).
Keep a record of each inspection and test.
4.
In the case of an accident which crushes or punctures the source enclosure, seal off the area, cover the FILTEC and surroundings with a plastic sheet or tar-paulin and call Industrial Dynamics immediately.
5.
Do not relocate or dispose of the FILTEC without proper approval.
A person with a Specific License must handle these functions.
6.
If you have any questions, call Industrial Dynamics.
)
1 e
9
)
. Form 079 (10/78)
FILL LDIEL TMSPECTXON SYSTEM INSPECTION HE AD VERTICAL TRIGGER BLOCM ADJUSTW(NT KNOS. S INCHES 1/4" RADIATION SHIELD TRIGCER BLOCK WERTICAt; ADJUSTMENT MNCS i
TRIOGER BLOCit VERTICAL AOJUSTMENT LOCM KN00 l
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DETECTOR rP-V HOUSWG Container:
1 ELECTn0NicS t
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CONVE70R 38 HE AD 7
8 Ng EXTENDEti
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INSPECTION HE AD 6l f.
VERTICAL LOCK KNOS l
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RADIATION j
SOURCE HOUSING f
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di SIDE VIEW l
ADJUSTED TO SUIT CONVETOR HEIGHT FLOOR STANDS AND PIPES FURNISHED wiTH FiLTEC
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.==
=
. =
. =
=
Y
=
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l LABELS ATTACHED TO FILTEC MODEL f:T-12 INSPECTION SYSTEM CONTAINING RADIOISOTOPE SOURCE. THE INFOR-MATION ON THESE LABELS IS VERY IMPORTANT AND SHOULD BE FOLLOWED IN EVERY DETAIL.
O NOTICE The receipt, possession, use and transfer of this device are subject to' o general license or equiv.
r-olent and the reevlotions of the U.S. NRC or of o state w*eh which the NRC hos entered into on j
ogreement for the exercase of regulatory authority.
' This device shall not be transferred. obondoned, or disposed of except by transfer to o person hold.
l ing a specific radioactive material license to
)
i O..
receive this device.
~
.I Operation of this device shall be 'immediately suspended until any necessory repairs have been mode if there is any indication of possible fail.
wie or demoge to the shielding or containment of radioactive material, or the ON.OFF mechanism or.
Indicato r.
This device shall be tested for proper operation
- q; of the ON.OFF mechanism and indicolor of intervals not to exceed six months.
The iented radioactive source contained in this device shall be tested of installotion and every' g
six anonths thereafter for lookoge of radioactive material.
Maintenance, tes.ts or 'other service involving th*
CAUTION f
radioactive material, its shielding and contain.
pf ment shall be performed by persons holding a spe-RADIOACTIVE MATERIAL cific radioactive material license to provide these services.
instatfotion, relocation, moine. nonce, repair and See Instruction Manual before attempting snitial radiation survey of this device and look.
to operate, repair, clean or move this testing, installation, replacement, and disposol device.
of sealed sources centoining radioactive material SOURCE r
used in this device shall be performed only by persons holding a specif,c rodeocctive motor,ial MM*
heh -m e
l.
license to provide these services.
Amount:
100 Millicuries Removal of this label is prohibited.
Date of Mfr:
Serial No.
Model No.
Removal of this label is prohibited.
Industrial Dynamics C o.,
Ltd.
L o mito Boulevard 1D Industrial Dynamics
[ M 2927 Torrance. California y
Torronce, California 90504 g
A
F 1
NOTICE This urut is approved for the inspectan of any food product, if operated in accordance with the FILTEC instruction Manual. Food products would have to be continuously exposed to the radiation beam for a period of 5 years to exceed the 1000 RAD dose
('
lirnit, as established by the Fosd and Drug Administration.
The radiation level around this FilTEC equipment is very low, but precautions should be taken to prevent direct exposure to any part of the body
]
to the radiation beam for extended periods of time.
J I
I ll n't l'
CAUTION EActOACTivt MATEstAL 00 NOT OPEN LOWER SEALED COvaa. THis PoeTION OF THE SOX CONTAINS NO SEtvlCIABLE PART5.
e l
4/85
_7_
- - - - - - - - - - - - ~ - -,,
n
= -
5
$ FATE of CAutoGNIA. -MEAlfH ANO WELFARE AoENCY otoRoE DEVO4EJtAN. Go.,,,ie, DEPARTMENT OF HEALTH SERVICES 79t/744 P $fREET
$ACRAAAENfo, CA 95814 (916) 445-0931 May 13, 1985 NOTICE OF RECEIPT OF RENEWAL APPLICATION FOR REVIEW Industrial Dynamics Company, LTD.
Attn:
Fred L. Calhoun P. O. Box 2945 Torrance, CA 90509 4
REFERENCE:
DOCKET NUMBER:
042685-1586 l
LICENSE NUMBER:
1586 APPLICATION DATED:
April 25, 1985 The above captioned renewal application has been received and docketed for review. Your applic6 tion is deemed timely, and accordingly, the license will not expire until final action has been.taken by the Department.
This application will be taken up in the order received. We are currently considering renewal applications received in the month of:
g,y, 19g4 Correspondence or other communication concerning the above referenced app-lication should be submitted in duplicate and should make clear reference to your assigned docket number pertaining to this specific request.
Future requests, not related to the above request, will be assigned a new docket number.
Thank you.
0 RADIOACTIVE MATERIALS LICENSING RADIOLOGIC HEALTH BRANCH
io 1
STATE OF CALIFORNIA 3
DEPARTMENT OF HEALTH
- s'
' 8, CORRECTED COPY RADIOACTIVE MATERIAL LICENSE CoRRECED COPY l
?
Pursuant to the California Administratin Code, Title 17, Chapter 5. Subchapter 4, Group 2, Licensing of Radioactie Material, and in reliance on statements asut seprenntations heretofore made by the licensee, a teense is hereby imued authorising the licenne to receive, use, possens, transfer or diuse of radioacthe materieflisted below;and to use such radioactive meterial for the purpose (s) and at the placelsi designated below, This license is subject to all applicable rules, regulations ud orders of the Department of Heetth now or hereafter in effect and to any conditions specified in this Jeanne.
1 m== No.
GL 1586-70 is hereby amended in 8-L '*""'
Industrial Dynamics Cocrpany, Ltd.
l its entirety amenemmt no. 9 l
2 Addre, 292'T Iomita Boulevard 4.
Earpiration date Torrance, CA 90509 May 26,1985 (
S.
Inspecnon egency l
Anationt Fred L. Calhoun f
Radiation Safety Officer Los Angeles Co. Dept. of Health Services 6.
Nuclide
- 7. Form 8.
Possession limit f'
A.
Scaled source (Industrial A.
Not applicable Model 06110), Ltd.
(See Condition No. 11)
Dynamics Co.
1 B.
Sealed source (Industrial B.
Not applicable L
Model 06765), Ltd.
(See Condition No. 11)
Dynamics Co.
l l'
9 Authorized use
~
A.
The licensee is authorized to distribute a Fill Level Device Filtee Model FT-12, ca:nifactured by the licensee, to persons Senerally licensed pursuant to Title 17, California Ad=inistrative Code, Section 30192('c)(1).
i,L l
B.
The licensee is authorized to distribute Case Inspection Device Filtec Model CI.2, canufactured by the licensee, to persons generally licensed pursuant to Title 17, m
California Administrative Code, Section 30192(c)(1).
1*
- 10. This license is subject to an annual fee of twenty (20) dollars due and payable on the anniversary of the date of issue of the associated manufacturing License No.
1389-59, May 26, 1966.
- 11. Each Model FT-12, Fill Level Device; and Model CI-2, Case Inspection Device, distributed under this license shall contain not more than 100 millicuries of Americium 241.
l
( cont' d)
~
2
~
DEPARTMENT O HEA H p.,.
W -70 G RADIDACTIVE MATERIAL LICENSE uu.a umi,o Supplementary het 9
c:ntinued
- 12. The device authorized by Item 9 of this license to be distributed to general licensees shall be only that device of the mmfacture of which is authorized by California Radioactive Material License No. 1389-59 and which is described in the following documents:
(a) letters and enclosures dated June 6, 1972 and June 23, 1972 signed by Fred L. Calhoun, (b) Radiation Rules and Regulations Filtec Model FT-12 (2/17/71),
(c) Radiation Rules and Regulations Filtec Model CI-2.
13 Each Model FI-12 or CI-2 device distributed under this license shall bear durable, clearly visible labels containing the radiation caution symbol of purple or j
j magenta on a yellow background,the words " Caution Radioactive Material," the quantity and isotope contained, the date of assay, the manufacturer's name and address, the Model and serial number of the device head and statements as follows:
l (a) "The receipt, possession, use and transfer of this device are subject to a general license or equivalent and the regulations of the U.S. NRC or of c
a state with which the NRC has entered into an agreement for the exercise of regulatory authority."
(b)
"This device shall not be transferred, abandoned or disposed of except by transfer to a person holding a specific radioactive material license to h
receive this device."
(c) " Operation of this device shall be immdiately suspended until any necessary l,I repairs have been made if there is any indication of possible failure or
,l damage to the shielding or containment of radioactive material, or the on-off mechanism or indicator."
-(d) "This device shall be tested for proper operation of the on-off mechanism and indicator at intervals not to exceed six months."
(e) "The sealed radioactive source contained in this device shall be tested at installation and every,six months thereafter for leakage of radioactive material'.'
- g (f)
" Maintenance, tests or other service involving the radioactive material, its shielding and containment shall be performed by persons holding a specific
~
radioactive material license to provide these services."
(g)
" Installation, relocation, maintenance, repair and initial radiation survey of this device and leak testin6, installation, replacement, and disposal l
of sealed sources containin6 radioactive material used in this device shall be performed only by persons holding a specific radioactive material license to provide these services."
( cont' d)
_9_
DEPARTMENT OF HEA TH p.,.
3
., 3 W -70 4 RADIOACTIVE MATERIAL LICENSE unow um.
continued supplementory Shect o
13.(cont'd)
(h)
"Each label required under this condition shan bear the legend ' Removal of this label is prohibited.'"
1k. The licensee shan furnish each licensee to whom it transfers a device described in this license with the fonowing:
(a) A copy of an instruction manual containing the radiation safety instruction sheet.
-(b)
(1) For devices instaned in California, a copy of the general license contained in Title 17, California Administrative Code, Section 30192(c)(1), Section 30192(c)(2), and an sections of Title 17 California Administrative Code referenced in Section 30192(c)(2);
the material should be prefaced by the words ' Excerpts from California Administrative Code, Title 17' or other appropriate title.'
(2) For devices instaned in Agreement States other than California, either the same material stated in Condition ik.(b)(1) above, with a statement that regulations of the state in which the device is instaned are similar to California regulations, or equivalent portions of regulations of the state in which the device is instaned.
(3). For devices instaned in non-agreement states, either the same material stated in Condition 14.(b)(1) above, with a state =ent that U. S. Nuclear Regulatory Co==ission regulations are similar to California regulations,
- R or Sections 31.5, 20.402, and 20.ko3 of Title lo, Code of Federal Resu-lations prefaced by the words ' Excerpts from Title 10, Code of Federal Regulat' ions' or other appropriate title.
e (c) The address and telephone number of the nearest office of the agency having regulatory responsibility for byproduct material at the general licensee's address.
15 The licensee chan report an transfers of radioactive material under this license.
Reports shan be filed with the agency having regulatory responsibility for byproduct '
material at the generany licensed recipient's address within 30 days after the end of each calendar quarter in which such trnasfer has occurred. These reports shan g
specify:
(a) The name and address of the regulatory agency to whom the report is directed.
(b) The authority for transfer, i.e., the name of the licensee specified in Item 1 of this license, and the license number specified in Item 3 (c) The name and address of the generany licensed recipient.
(d) The numbers and =odels of devices, together with an identification of nuclides and quantities contained in each device transferred to said recipient.
Copies of an reports required by this Condition shan be maintained subject to inspection by representatives of the Department.
For the State Departmen, f Health
/
~*d 111 Date September 21, 1978 by Radiologic Health Section l
CH 2551 (8/17) 714 P Street. Sacramento.CA 95814
RADIATION PROFILES (FIGURES I & II)
Attached are top and side radiation profiles, or Isodose Curves,of the FILTEC FT-12.
These curves were obtained with the indicated instrumentation using a 100 millicurie Americium-241 source with the geometry of the activity, collimator and mounting the same as that depicted for the production model.
Note that no appreciable radiation is present outside the main beam in the side profile due to the collimator which is 1/16" by 1/2" by 1/2" deep.
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dllIlllll1b Del Monte Corporation e nesearch Center, P.O. Box 9004. Walnut Creek CA 94598-2458 e Telephone: (415) 933-8000 FEDERAL EXPRESS October 7, 1985 c Ms. Toye L. Simmons Rad'ation Specialist i
Nuclear Regulatory Commission, Region III 799 Roosevelt Road Glen Ellyn, IL 60137
Dear Ms. Simmons:
I want to thank you again for your help with regard to the nuclear materials matter at our plant in Plymouth, Indiana.
I also want to re'.terate Del Monte's concern about this incident, and to reinforce 114 corrective measures that will be taken.
While.you were at our plant, I'm sure you were conscious of Ken Peacock's prompt attention to our obligations. Such responses are typical for our plant managers. After your inspection he telephoned both his line management and my corporate staff office to discuss the matter in detail. As I mentioned to you on the telephone, these kinds of matters are always brought to the immediate attention of our top production management.
Once assured that there were no immediate problems at hand; that this particular incident was under control, all of us immediately focused on the future -- how to prevent a recurrence.
I assure you there is full management support in this regard. As a first step, we will issue a reminder notice to our plant managers this week pointing out our basic obligations relative to using and testing equipment containing nuclear material.
I i
We concur with your suggestion to develop a centralized control system for all nuclear materials. However, we envision using this centralized approach more as a back up.
That is, in addition to this central approach, we are going to develop a means to reassure ongoing proper managemen/ control of the nuclear materials at each
(
location where they are used. This will be the primary control point, with the central repository being used for reassurance purposes.
In total, these control measures will assure us of l
knowing where the various materials are located, what the materials are, and that proper and timely testing is performed.
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APPENDIX 3
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o Ms. Toye L. Simmons October 7, 1985 Page 2 As I think you will agree, the circumstances behind the incident at Plymouth were highly unusual and unique. Certainly, had there been any knowledge that the material was present in the equipacnt being discarded it would have been handled properly. As a matter of routine, those plant managers having any nuclear material on site know their resultant obligations. With the additional safeguards discussed above, we will also be able to reassure both full awareness and knowledge of the substances we have on hand and the necessary testing and handling procedures for them.
Very truly yours, Del Monte Corp' oration M
William J. Spain Direct.r, Corporate Quality Assurance
& Regulatory Affairs WJS:lte cc:
K. L. Peacock - Plymouth
.