ML20206P359

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Notice of Violation from Insp on 860710.Violations Noted: Intl Shipments Exceeding 3 Ci Package Limit Shipped W/O Required Type B Packaging & 4.73-Ci Pu:Be Sealed Neutron Source Possessed W/O Proper Authorization
ML20206P359
Person / Time
Site: 07001342
Issue date: 08/21/1986
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20206P354 List:
References
70-1342-86-01, 70-1342-86-1, NUDOCS 8608270176
Download: ML20206P359 (2)


Text

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APPENDIX A NOTICE OF VIOLATION Coratomic, Inc. Docket No. 070-01342 Indiana, Pennsylvania 15701 License No. SNM-1319 As a result of the inspection conducted on July 10, 1986, and in accordance with the NRC Enforcement Policy (10 CFR 2, Appendix C), the following viola-tions were identified:

A. 10 CFR 71.5(a) requires that no licensee deliver any licensed material to a carrier for transport without complying with the applicable requirements of the regulations appropriate to the mode of transport of the Department of Transportation in 49 CFR Parts' 170-189.

49 CFR 173.415 specifies packaging authorized if the package quantities of radioactive material in special form do not exceed the A2 quantity listed in 49 CFR 173.435. 49 CFR 173.416 specifies packaging authorized if quar.tities exceed the A2 quantity specified in 49 CFR 173.435.

49 CFR 173.435 states the2A , quantity limit for plutonium 238 to be 3 curies. 49 CFR 173.435 (footnote 1) also states that for shipments solely within the United States the A2 , value is 20 curies for plutonium-238 .

contained in nuclear pcwered pacemakers.

1. Contrary to the above in November 1985, the licensee shipped as limited quantity (UN2911), on two separate occasions, two Model C-101-P isotopic pacemakers (S/N 1196, S/N 1202) containing =4.3 curies of plutonium-238 to customers in Brussels, Belgium. Specifi-cally, the two shipments each exceeded 3 curies for international '

shipments and therefore required Type B packaging as specified in 49CFR 173.416. ,

This is a Severity Level IV violation. (Supplement V)

2. Contrary to the above on nine occasions from June 1985 to July 10, 1986, the licensee shipped isotopic pacemakers containing =4.3 ceries of plutonium-232 to customers within the United States as a ltmited quantity article or instrument when the article (pacemaker) excaeded the activity limit of 0.2 curies per article as stated in 49 CFR 173.422(a) and S 173.423 Table 7. Specifically, the p4cKaging did not conform to the requirements of 49 CFR 173.415 and was not otherwise exempted. [

l This is a Severity Level IV violation. (Supplement V) 8608270176 860821 REG 1 LIC70 i SNM-1319 PDR 0FFICIAL RECORD COPY OL CORATOMIC INC - 0004.0.0

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Appendix A 2 B. 10 CFR 20.201(b) requires that each licensee make such surveys as may be necessary to comply with all sections of Part 20. As defined in 10 CFR 20.201(a), " survey" means an evaluation of the radiation hazards incident to the production, use, release, disposal, or presence of radio-active materials or other sources of radiation under a specific set of conditions.

Contrary to the above, as of July 10, 1986, no surveys were made to assure compliance with 10 CFR 20.105(b), which limits radiation levels in un-restricted areas. Specifically, no surveys were made in the hallway, an unrestricted area, adjacent to the wall of the Quarantine Laboratory where a shipping container containing a 4.73 curie plutonium-beryllium sealed neutron source was stored. Additionally on July 10, 1986, the inspector measured radiation level of more than 2 millirem per hour against this wall.

This is a Severity Level IV violation. (Supplement IV)

C. Conditions 6, 7, and 8 of License No. SNM-1319 limit the amount of Plutonium (Principal radionuclide Pu-238) in sealed sources (plutonium batteries) that you may possess at any one time to sources not to exceed 250 milligrams per source (=4.35 Ci).

Contrary to the above since May 4, 1983, you have maintained possession of a 4.73 curie plutonium-beryllium sealed nautron source a form and amount not authorized by your license. .

This is a Severity Level IV violation. (Supplement VI)

D. 10 CFR 20.203(b) requires that each radiation area be conspicuously posted with a sign or signs bearing the radiation caution symbol and the words: " Caution Radiation Area."

Contrary to the above, on July 10, 1986, the radiation area in the Quarantine Laboratory where a shipping container containing a 4.73 curie plutonium-beryllium sealed neutron source was not posted as required specifically radiation levels measured by the inspector twelve inches from the container were in excess of 5 millirem per hour.

Pursuant to the provisions of 10 CFR 2.201, Coratomic, Inc. is hereby required to submit to this office within thirty days of the date of the letter which transmitted this Notice, a written statement or explanation in reply, includ-ing: (1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further violations; and (3) the date when full compliance will be achieved. Where good cause is shown, con-sideration will be given to extending this response time.

OFFICIAL RECORD COPY DL CORATOMIC INC - 0005.0.0 08/18/86

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