ML20199J699
| ML20199J699 | |
| Person / Time | |
|---|---|
| Issue date: | 02/03/1998 |
| From: | Steven Baggett NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Pederson C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20199J704 | List: |
| References | |
| SSD, NUDOCS 9802060016 | |
| Download: ML20199J699 (4) | |
Text
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February ' 1998 MEMORANDUM TO:
Cynthia D. Pederson, Director Divislan of Nuclear Materials Safety, Region lli FROM:
Steven L. Baggett, Section Chief Or' ird Signed By:
Sealed Source Safety Section g
Medical, Academic, and Commercial StwenLB@gett Use Safety Branch Divisien of Industrial and Medical Nuclear Safety, NMSS
SUBJECT:
LETTER FROM DETORA ANALYTICAL, INC.
Please find attached a January 12,1998, letter from Detora Analytical, Inc. to Grand Gulf Nuclear Generating Station. A copy of the letter was sent to NRC to inform NRC of the transfer of a generally licensed device.
Detora'c letter incorrectly states that the recipient of the device is a general licensee.
Specifically, the recipients are not authorized to receive the material under the 10 CFR 31.5 generallicense since Detora does not have a 10 CFR 32.51 distribution license. Based on information previously provided by Detora (previously known as Detex) and conversions between Bart Stuchell of Detora and members of my staff, the cnly U.S. recipients of Detora's devices are persons specific licensed in accordance with 10 CFR Par 150 to receive the devices. Therefore, Detora must verify that the recipient is specific licensed to receive the material and the letter to the recipients of the devices should indicate that possession and use of the devices must be in accordance with the recipient's specific license. Detora should not indicate that the recipient is using the device under a general license.
My staff and I nave attempted to clarify to Detora the 10 CFR 31.5 transfer requirements via telephone conversations and letters. However, based on the information contained in Detora's January 12,1998, letter, we are concemed that Detora does not understand the transfer requirements and !s not verifying that recipients are specifically licensed to receive the devices. Therefore, I request that the next time your staff is in the area that they petform an inspection of Detora to verify that transfers of devices are in accordance with NRC regulations.
If you have any questions or nuestions arise during the inspection at Detora, please contac!
Mr. John Lubinski of my staff a' (301) 415 7868.
)
Attachments:
k
- 1. Detora's January 12,1998, letter to Grand j
Gulf Nuclear Generating S'ation
- 2. August 26,1997, letter to Detex, Inc. with Enclosures MO,,UL,$Mi oit iEib'!.I Distribution, IMNS r/f NE02 SSD 1 SMoore (w/ encl.)
DOCUMENT NAME: C:\\ FILES \\DETORA.WPD b teceive e copy of this document, hid cate in the boa: "C" - Copy ethot.1 attachment / enclosure
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NAME JLubinshihl SBagg6tt DATE 0263/98-02/4/98 OFFICIAL RECORD COPY 9002060016 900203 PDR RC SSD PDR
n g DETORfl AnalyHcaUnc.
PO Box 2747 + Alhonce, Ol.io 44601-0747
- 330-8216604
- f AX 330 8219557 January 12. ")98 Mr. Rkhard Scaibrough Grand Gulf Nuclear Generating Station llald 11i11 Road Port Gibson, Mississippi 39150 Dear Mr. Richard Scarbrough With thJ recent upgrade and change of X ray system in yoct OCPM we are sending this letter to meet the requirements of 10 Cl~f 1.5 c-(ll). As you know, the Detora Analytical Inc. On line Metals Analyzing System (OCPM) contains radioisotope sou,cet in one of the components within the complete system. T he Me, ores inc, X-ray l luorescence Analyzer (s)(XRI' anat. er)is the component it t contains the source (s). (IlliPS Model 20H12 Isotope S/N 11111dD (llCPS Model114M3 Isotops N lju J4D The type of sources and their radioactive strengths are shown on the silver label aflixed to the Metorex analyzer, Your Operator's Manual outlines your obligations as a general licensee (user) of these materials. We have enclosed a copy of the page from the manual which highlights the major portion of your obligations. Please note that you may not transfer (mm e) the analyzer to another kication without transferring it through and agency that holds a specific license to possess radioactive materials. Should it become neessary to move the analyrer, please contact our office first to arrange the shipping details.11 may be i.ecessary for you to ship the analyict to Metorex inc. and they, in turn, will forward it to the hication you specify (another general licensee).
You are required to retain documentation of receipt or transfer of these inatrt.ments as well as all leak tests. We recommen(t that you save the shipping documents and leak test certificates that are included with your instrument.
Please feel free to contact us at any time with questions regarding your XRl' analyrer, its radioactive ruaterials, or the regulations governing its use, pmsession and transfer, We will be happy to discuss them with you.
Should your facility ntaintain a speellic Ilcense through the Nuclear Regulatory Consnsission (NRC) you should cantDIY with all specific license regui.:tions.
itnd the above information will not apply.
Sincerely, av -
Ilart Stuchell Vice President Manufacturing
.-. -.. - ~ - -
E Ag DETORfl AnalyHcaUnc.
PO Box 2747
- Alliance, Ohio 446014747
- 330821-6604
- TAX 330 821.9557 YOUl; OllLIGATION AS A GENERAI, LICENSED USER OF RADIOACTIVE MATERIAL i
Under normal operating conditions, the lieps X ray probe presents no significant radiation hazard since the operator is well shielded from the sources at all thnes. Without shielding, however, a significant radiation hazard may be present.
DO NOT DlSASSEMill.E Tile INSTRUMl!NT DO NOT MODIFY Tile INSTRUMENT Should you ever observe a primary source positioned in the sample aperture when the turret is open (e.g., while changing samples), this would indicate that the automatic shielding mechanism has failed. in this event, close the turret to shield the source and tape it s(curely in place to prevent accidental exposure. Contact Detex inc. for corrective action.
t YOU MUST MAINTAIN Tile LAllEl.S IN 1.EGillLE CONDITION Clean the labels with a damp towel if necessary, Do not scrub excessively.
YOUR MUST REPORT INCIDENTS TO YOI!R REGULATORY AGENCY Any failure of or damage to the shielding system requires you to suspend operation of the instrument until corrective action can be taken by a person licensed to perfbrm such activities.
Within 30 days, you must furnish to your regulatory agency a report containing a brief description of the event and the remedial action taken.
.YOU MAY NOT TRANSl:ER Tills UNIT TO ANOTilER GENERAll.Y LICENSED USER DO NOT AllANDON Tile INSTRUMENT e
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1 PO Box 2747
- Allionce, Ohio 446014747
- 330-8214604
- FAX 330 8219557 i
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CODE OF FEDFRAL RFOULATIONS SECTION 31.5(9)(i)and(ll)
(i) Where the device remains in use at a panicular location. In such case the transferor shall give the transferee a copy of this section and any safety documents i
identified in the label of the device and within 30 days of the transfer, report to the Director of Nuclear Material Safety and Safeguards, U.S. Nuclear Regulatory Commission, Washington, DC 20555, the manufacturer's name and model number of device transferred, the name and address of the transferee, and the name and/or position of an individual who may constitute a point of contact between the Commission and the transferee; or (ii)- Where the device is held in storage in the original shipping container at its intended location of use prior to initial use by a general licensee, e
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