ML20198L895
| ML20198L895 | |
| Person / Time | |
|---|---|
| Issue date: | 12/21/1995 |
| From: | Scarano R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Limtiaco F HONOLULU, HI |
| Shared Package | |
| ML20198L898 | List: |
| References | |
| SSD, NUDOCS 9901050158 | |
| Download: ML20198L895 (3) | |
Text
g.%REICENED FEB 'O 21996' uNiTEo: TATE:
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' NUCLEAR REGULATORY COMMISSION
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RESION IV
- e 511 RYAN PLAZA DRIVE, sulTE 400
_ ARLINGTON, TEXAS 780118064 December 21, 1995 f
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/
f* f City County of Honolulu
- Department of Wastewater Management,
g Division of Treatment and DisposnV W
g ILMr. Felix B.limthco Director
~1350 Sand Island Parkway Honolulu, Hawaii 96819
SUBJECT:
NRC INSPECTION REPORT 999-90004/95-05 AND NOTICE OF VIOLATION This; letter refers.to the special, announced inspection conducted by Mr. Emilio M. Garcia of this office on November 13'and 16,1995. The-
' inspection included a review of activities authorized under a general license o
pursuant _to 10 CFR 31.5.
At the conclusion of the inspection, the findings
. were discussed with Mr. Mike'Nunn of your staff.. Subsequent to the' site visit on' December 6, 1995, a telephone conversation pertinent to the inspection was
- conducted between Messrs. Garcia and Nunn. The enclosed NRC Inspection x
Report 999-90004/95-05 documents this inspection.
1 l
LTheinspectionwasanexaminationofcircumstancesrelatedtothe
. inappropriate disposal of a 139 microcurie _ cesium 137_ source and to the transfer of. other sources genera 11y' licensed. The inspection consisted of
.. selective examinations of procedures and representative records, interviews of personnel, and independent measurements.
Based on the results of 'this inspection, the NRC has determined that violations'of NRC requirements occurred. These violations are cited in.the-i enclosed Notice of Violation-(Notice). The violations involved the improper L
disposal of licensed material and the failure to report the proper transfer of i
j other licensed sources.
j SThe NRC has reviewed your report'datedjepteiiSir 18, 1995',~ describing the
~
liinsating cell source.
d~Mdividual-could-have'Jhe' report investigation of disposal of the c
- indicates that the maximally expc received 0.1 mrem during the removal and disposal a he compensating cell. The report also l
C '
estimates, using conservative assumptToiii, that if the source was dissolved in ff
- the groundwater aquifer, the committed effective doseLequivalent to a member of the public drinking froin this water would be 4.7 x 10-' millirem. These l
estimates place the dose potentially received by individual members of the
[d43
. public well below' the total. effective' dose equivalent limit of 10.CFR'20.1301(a)(1) for an individual member of the public.
The NRC normally considers the loss of byproduct material to be of significant
' concern because of the potential for members of the public to receive
, unintended and possibly significant radition exposures, the potential for f
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I l-i 9901050158 951221
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z City and County of Honolulu -
Department of Wastewater Management l
contamination of other material, and the impact on the environment of improper disposal of byproduct material. The " General Statement of Policy and Procedures for NRC Enforcement Actions," (Enforcement Policy) (NUREG-1600, 60 FR 34381, June 30, 1995) indicates that violations involving the loss of sources will be considered under discretion (see Section VII of the Enforcement Policy) and may be assessed civil penalties to emphasize the importance to licensees being aware of the location of their sources and to recognize that there should not be an economic advantage for inappropriate disposal or transfer.
i We recognize that, in this case, the disposal was not an intentional act to avoid the cost associated with proper disposal. Nevertheless, we are concerned that the loss of this source indicates a loss of control of licensed materials in that it appears to have been disposed in a trash bin and taken to the local landfill. However, given the small quantity of radioactive material
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involved which, given the nature of the material poses no real risk to members of the public, the NRC is exercising discretion and classifying the violation that resulted in the improper disposal of this source at Severity Level IV and is not assessing a civil penalty.
Based on your consultant's report of September 18, 1995, the information collected during this inspection and because your Division has ceased NRC-licen.ed activities, you are not required to respond to this letter and the enclosed Notice of Violation.
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 (PDR).
Should you have any questions concerning this letter, please contact Emilio M. Garcia at (510)975-0239.
Sincerely, 4
hRossA.Scarano, Director i
Division of Nuclear Material Safety Docket: 999-90004 License: General License (10 CFR 31.5)
Enclosures:
1.
NRC Inspection Report 999-90004/95-05 cc w/ enclosures:
Hawaii Radiation Control Program Director
g.ch.
City and County of Honolulu.
. Department of Wastewater Management 1
1 bec w/ enclosures:
DMB-Original.(IE-07)'\\.
LJCallan DBSpitzberg LLHowell FAWenslawski
- EMGarcia j
1
- MIS System
- WCF0 Files (2)
- NMI&FC/DB l
- W/ IFS Form j
I DOCUMENT NAME: G:\\ HONOLULU.NOV
. To receive copy of document, indioste in box: "c" = Copy without enclosures *E" = Copy with enclosures "N" = No copy WCF0:MB E
C:MB/WC(69, _,4:)pjfp l D:DNMS A l
EMGarcia dW't'/.- -
FAWenslifwskf dlQimimberlain RASegano 12//F/95 12//c//95
'12/// /95 If( /95 OFFICIAL RECORD C0FY L
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