ML20197H581
| ML20197H581 | |
| Person / Time | |
|---|---|
| Site: | University of Virginia |
| Issue date: | 12/09/1998 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20197H573 | List: |
| References | |
| 50-062-98-202, 50-62-98-202, NUDOCS 9812140139 | |
| Download: ML20197H581 (2) | |
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University of Virginia Docket No. 50-62 1
University of Virginia Research Reactor License No. R-66 l
During an NRC inspection conducted on November 16-19, 1998, a violation of NRC requirements was identified. In accordance with the " General S+atement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below:
J 10 CFR 71.5(a) requires that a licensee who delivers licensed material to a carrier for transport comply with the applicable requirements of the regulations appropriate to the j
mode of transport of the Department of Transportation (DOT)in 49 CFR Parts 171-189.
l 49 CFR 172.202(a)(1) requires that the proper shipping name prescribed for the material in j
Column 2 'of the 172.101 Table be included on the shipping papers.
49 CFR 172.204(a) requires that a specific certification or declaration stating that the l
material is offered in accordance with the regulations be included on the shipping papers.
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Paragraph 172.204(c) specifies a certification statement that may be used in place of the one required by paragraph (a)if the materialis to be transported by air.
l 49 CFR 173.422(a) requires that excepted packages containing limited quantities of radioactive material offered for shipment must be certified as being acceptable for transportation by having a specific notice enclosed in or on the package.
10 CFR 71.12(c)(2) requires that, under the terms of the general license for an NRC-approved package, a licensee shall comply with the terms and conditions of the Certificate
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of Compliance issued for the package.
1 Certificate of Compliance (CoC) No. 5957, Revision 24, dated March 26,1996, issued for the BMI-1 Shipping Cask, requires in Condition 5(c) that the minimum Transport index to be shown on the label for nuclear criticality control (when shipping intact irradiated MTR-type fuel assemblies containing not more than 240 grams of uranium-235 (U-235) per assembly) shall be 0.4.
Contrary to the above the shipping papers and/or label for various radioactive material shipments were not completed as required in that:
(1)
On the shipping papers filled out for shipments made using Federal Express as the carrier, at least two sets of shipping papers did not list the proper shipping name of the material being shipped.
(2)
The correct wording for the shippers' certification was not listed on various shipments of radioactive material designated as " Radioactive Material, N.O.S., UN 2982," when the licensee's own " shipping form" was used.
9812140139 981209 PDR ADOCK 05000062 g
2 (3)
The correct wording for the certification of excepted packages was not listed on a notice enclosed in or on the package for shipments of radioactive material des:gnated as " Radioactive Material, Excepted Package - Limited Quantity of Material".
(4)
For Shipment Number R-66-98-1, a shipment of four MTR-type control rod fuel elements classified as a Highway Route Controlled Shipment of RO, Radioactive Material Fissile, N.O.S., UN2918 and using the BMI-1 Shipping Cask, the Transport
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index of 0.4 required by the CoC when shipping MTR-type fuel was not listed on the label affixed to the cask nor indicated on the shipping papers for the shipment.
This is a Severity Level IV violation (Supplement V).
l Pursuant to the provisions of 10 CFR 2.201, University of Virginia 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 responsible inspector, U.S. Nuclear Regulatory Commission, Region 11,61 Forsyth St. S.W., Suite 23T85, Atlanta, GA 30303, within 30 days of the date of this 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 further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately i
addresses the required response. If an adequate reply is not received within the time specified in this Notice, an order or demand for information may be issued 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 respon" time.
Because your response will be placed in the NRC Public Document room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected I
and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure or information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financialinformation). If safeguards information is necessary to provide an acceptable response, please provide the level of 1
protection described in 10 CFR 73.21.
Dated at Rockville, Maryland this i
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