ML20148E296
| ML20148E296 | |
| Person / Time | |
|---|---|
| Issue date: | 05/23/1997 |
| From: | Blough A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Rashat S AFFILIATION NOT ASSIGNED |
| Shared Package | |
| ML20148E300 | List: |
| References | |
| REF-QA-99990001-970523 CAL-1-96-13, EA-97-151, NUDOCS 9706030058 | |
| Download: ML20148E296 (3) | |
Text
-
l MAY 2 31997 I
Docket No. 99990001 EA No.97-151 CAL No.1-96-013 1
Mr. Subash Rashat Director Hera Tech Environmental Labs 1879 Old Cuthbert Road Suite l Cherry Hill, NJ 08034
SUBJECT:
TRANSFER OF REGULATED BYPRODUCT MATERIAL TO AN j
UNAUTHORIZED RECIPIENT AND CLOSURE OF CONFIRMATORY ACTION LETTER NO. 1-96-013
Dear Mr. Rashat:
This letter refers to your possession and transfer of regulated byproduct material without a proper NRC license and our Confirmatory Action Letter (CAL), dated l
November 27,1996. The byproduct material consisted of approximately 15 millicuries of nickel-63 in each of two electron capture detectors (ECDs), eech in a separate gas chromatograph (GCs).
During a telephone discussion between Mr. Lee Greenwald of Quality Control Laboratory and Mr. Steven Courtemanche of this office, Mr. Greenwald stated that he transferred the above byproeduct material to you on November 4,1996. On the same day, you stated to Mr. Courtemanche that you did not possess a specific NRC license to receive the byproduct material. Our review of NRC records also indicates you did not possess an appropriate NRC license. 10 CFR 30.3 provides, with exceptions not p
applicable in this case, that no person shall possess byproduct material except as j
authorized in a specific or general license. On January 8,1997, during a telephone j
0 discussion between you and Mr, Courtemanche of this office, it was determined that you had transferred the ECDs, on or about January 8,1997 to Precision Analytical
-no Laboratories, Inc. (PACl). The regulations restricting transfer of specifically-licensed l
M material and generally-licensed material, described in 10 CFR 30.41 and 10 CFR
- W 31.5(c) respectively, prohibit the transfer from Hera Tech Environmental Labs (Hera Tech) to PASI.
Com 08$
4 hillllllOllllWillllllll!I!IHill RETURN ORIGINAL 10 gg b.gO*,(I) 4 REGION I I
~
(" iy 6 l60[
d swo.
""" 030011 OFFICIAL RECORD COPY
}
ges A5 i
t)0%
J
l S. Rashat.
Hera Tech Environmental Labs Based on the results of these telephone discussions, it appears that your activities were not conducted in full compliance with NRC requirements. A Notice of Violation is enclosed and categorizes these violations by severity levelin accordance with
" General Statement of Policy and Procedure for NRC Enforcement Actions,"
(Enforcement Policy), NUREG 1600. The NRC has concluded that information regarding the reason for the violations, your corrective actions, and your actions to prevent recurrence is already adequately addressed on the docket in telephone discussion records from November 21,1996 through January 8,1997. It is our understanding from the above telephone discussions between you and the NRC Region i staff that you no longer possess regulated byproduct material requiring a general or specific license and that you do not intend to do so in the future. Therefore, you are not required to respond to this letter unless this understanding does not accurately reflect your actions or your position. In that case, or if you choose to provide additional information, you should follow the instructions specified in the enclosed Notice. Should you decide to conduct licensed activities in the future, we expect you to pay meticulous attention to compliance with all NRC regulations and requirements.
Based on a facsimile received on April 15,1997, from Precision Analytical Services, Inc., who received the GCs from Hera Tech about January 8,1997, the NRC has found that all the commitments listed in the CAL have been met.
No further response is required regarding the CAL.
In accordance with 10 CFR 2.790, a copy of this letter will be placed in the NRC Public Document Room.
l Your cooperation with us is appreciated.
Sincerely, CRIGINAL S!GTED BY:
A. HANDOLPH E'.WiH A. Randolph Blough, Director Division of Nuclear Materials Safety Docket No. 99990001 Non-Licensee
Enclosure:
Notice of Violation cc w/ enclosure:
State of New Jersey OFFICIAL RECORD COPY
' S. Rashat Hera Tech Environmental Labs RiE@titi9E PUBLIC w/enci Nuclear Safety Information Center (NSIC)
Region i Docket Room (w/ concurrences)
W. Axelson, RI J. Lieberman, OE J. B. Fewell, Rl D J. Holody, RI C. Buracker, RI DOCUMENT NAME: R:\\WPS\\MLDL\\HERATECH to r.c.iv.. copy of pie docum.nt. indic.t. in ih. box: c = Copy w/o attach /.nci "E" = Copy w/ attach /.nel
'N" = No copy
' OFFIC E DfMS/,RI lN DNJAS/RI lM DNMS/RIQ l l
NAME JKtemanche/src JK H#dfnan ARBlough 's DAT&(F C5/20/97 0502/97 05/17/97 05/ /97
-