ML20198N163
| ML20198N163 | |
| Person / Time | |
|---|---|
| Site: | 03001214 |
| Issue date: | 01/15/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20198N152 | List: |
| References | |
| 30-01214-97-01, 30-1214-97-1, EA-97-529, NUDOCS 9801200284 | |
| Download: ML20198N163 (2) | |
See also: IR 07100016/2011014
Text
_ . . .
. __
_ __ _ _ _ _
_ _ . _ _ _ _ _ _ _ _
_ _ _ _ _ _ .
u
,
I
l
l
!
Department of Veterar affairs
Docket No. 030-01214
l
San Francisco, Califorti.
License No. 04 0042105
i
EA 97-529
.
During an NRC inspection conducted October 16 through November 14,1997, violations of NRC
requirements were identified. In accordance with the " General Statement of Policy and
Procedure for NRC Enforcement Actions," NUREG 1000, the violations are listed below:
,
A.
10 CFR 20.2001(a) requires that the licensee dispose of licensed material only by certain
.
specified orocedures.
i
Contrary to the above, on August 18,1997, the licensee disposed of approximately
'
305 microcuries of phosphorus 32 by release to non-radioactive trash, a method not
authorized by $20.2001. (01013)
B.
License Condition 24.A requires the license to conduct its program in accordance with
the statements, representations, and procedures, including any enclosures contained in
the application dcted October 11,1990. The application October 11,1990, states in item
,'
No.10.7 that, except for radiopharmaceuticals and kits procured and administered to
patients directly by the Nuclear Medicine Service, the licensee will establish and
implement the model procedure for opening packages contfning radioactive material as
described in Appendix L to Regulatory Guide 10.8, Revision 2. Model procedure 2.d.(3),
Appendix L in the abovo regulatory guide, requires the licensee to open a shipment's
l
inner package and verify that the contents agree with the packing slip. Appendix L
model procedure 2,g. requires the licensee to monitor the packing material and the
ernpty packages for contamination with a low range GM survey meter before discarding.
Contrary to the nbove, on August 18,1997, a hcensee researcher who opened an inner
I
,
package of a shipment enclosing three vials, each containing 305 microcuries of
phosphorus 32, did not verify that the radioactive contents agreed with the packing slip
accompanying the shipment. Also, on August 18,1997, the researcher did not monitor
the packing material and package with a low range GM survey meter to ensure that it
was empty and free of contamination before it was discarded as normal, non-radioactive
l
waste. The discarded package, containing a single vial of approximately 305 microcuries
of phosphorus 32, was later disposed as normal trash in a general waste landfill. (01023)
These violations represent a Severity Level lll problem (Supplement IV).
The NRC has concluded that information regarding the reason for the violations, the corrective
,
actions taken and planned to correct the violations and prevent recurrence, and the date when
'
full compliance will was achieved is already adequately addres3ed on the docket in inspection
Report No,030 01214/97-01 and the letter from the Licensee dated December 23,1997,
,
- However, you are required to submit a written statement or explanation pursuant to
-10 CFR 2.201 if the descriptioin therein does not accurately reflect your corrective actions or
your position. In that case, or if you choose to respond, clearly mark your response as a " Reply
to a Notice of Violation," and send it to the U.S. Nuclear Regulatory Commission,
Pir M it M 1
'
Ph
y;
C
!
E
'
-
,
-
-
_
,_
_-
_ _ . .
_ . .
._
. _ . .
_._m..
. . _ _ . . _ . _ _ _ _
.
e
f
!
.
l
2-
l
l
ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional
l
Administrator, Region IV.
j
if you contest this enforcement action, you should also provide a copy of your response to the
i
Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC
!
.
20555 0001, and a copy to the Enforcement Officer, NRC Region IV.
,
.
Because any response you choose to submit will be placed in the NRC Public Document Room
!
'
(PDR), to the extent possible, it should not include any personal privacy, proprietary, or-
3
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 -
l
bracketed copy of your response that identifies the information that should be protected and a -
'
.
redacted copy of your response that deletes such information. If you request withholding of
such material, you musj specifically identify the portions of your response that you seek to have
~ withheld and provide in detail the bas 6s for your claim of withholding (e.g., explain why the
-;
disclosure of 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 com -
j
mercial or financialinformation).
,
, Dated at Arlington, Texas
this 15th day of January 1998
3
)
.
i
!
!
!
.
i
6
l
,
P
T
C
,
1
,.
'-
-
, a .. -
-
-
-
,