ML20206T003

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Confirmatory Action Ltr CAL-1-93-14 Re Violations Noted Involving Unauthorized Removal of Source Housing Containing 100 Mci Pr-147 Shielded Source from Main Unit of Gauge Mfg by Ahlstrom Automation,Inc in Order to Replace Housing
ML20206T003
Person / Time
Issue date: 10/01/1993
From: Hehl C
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To: Ziebell M
APPLETON PAPERS, INC.
Shared Package
ML20206S934 List:
References
SSD, NUDOCS 9902110189
Download: ML20206T003 (3)


Text

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4 UNITEo STATES g NUCLEAR REGULATORY COMMISSION

[ REGION 1

% :j i* g a 475 ALLENDALE ROAD l g ,8 KING oF PRUSSIA. PENNSYLVANIA 19406 1415  !

OCT i Em i

Docket No. 99990001 General Licensee CAL No. 1-93-014 l Appleton Papers, Incorporated ATrN: Mr. Michael Ziebell Plant Manager 2850 Appleton Street Camp Hill, Pennsylvania 17011 l

l

Dear Mr. Ziebell:

l

Subject:

Confirmatory Action Letter No. 1-93-014 l

On September 30, 1993, Messrs. S. R. Courtemanche and S. W. Shaffer conducted a special inspection of the above named facility of activities authorized by your General License. Three apparent violations were identified during the inspection; a written notice about the apparent violations will be sent to you in a separate transmittal. One of the apparent violations involved l an unauthorized activity. Specifically, on May 19,1993, an employee who was not qualified  ;

under NRC regulatory requirements removed the source housing containing a 100 millicurie l promethium-147 shielded sealed source from the main unit of a gauge manufactured by Ahlstrom j Automation, Incorporated in order to replace the mylar window of the source housing. This is an apparent violation of your Geneml License. Apparently, the gauge was properly labeled )

according to the manufacturer's distribution license and the label stated, in part, that, "The l receipt, possession, use, and transfer of this device are subject to a general license or the  !

equivalent and the regulations of the U.S. NRC or a state with which the NRC has entered into  !

an agreement for the exercise of regulatory authority. ... Removal of the radioactive material, the shielding or the containment of the radioactive material shall only be performed by persons

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specifically licensed by the NRC or an Agreement State." The employee notified management i of the instructions on the label prior to removing the source housing and was informed by management to remove it and replace the mylar window. The employee then removed the source housing, containing the source and source shield, from the unit in order to replace the mylar window. On six other occasions between 1991 and 1993, the mylar window apparently j was replaced in this manner, either by your employees or by a representative from Lippke Corporation, none of whom were authorized to perform such work.

Pursuant to a telephone conversation between Mr. F. Gillespie of your organization and Dr. W.  ;

J. Pasciak of this office on October 1,1993, it is our understanding that you have taken or will take the following actions with regard to the above unauthorized activity:

I L

I 9902110189 931019 PDR RC

  • SSD PDR r* r w am e- --

Appleton Papers, Incorporated l You shall not perform work which involves the removal of the source housing containing the shielded scaled source from any licensed gauge in your possession, or perform any work that involves the shiciding in the source housing or the sealed source itself, unless the work is performed by an individual who is licensed by NRC or an Agreement State to perform such work.

Pursuant to Section 182 of the Atomic Energy Act,42 U.S.C. 2232, and 10 CFR 2.204, you are required to:

1. Notify me immediately if your understanding differs from that set forth above.
2. Notify me in writing within 5 days of the steps you have taken to ensure that 1 unauthorized activities addressed in this Confirmatory Action letter are not performed.

Issuance of this Confirmatory Action Letter does not preclude the issuance of an Order fo m?!!*- the above commitmerts or requiring other actions on the part of the licensee. Nor does it preclude the NRC from taking enforcement action for violations of NRC requirements that may have prompted the issuance of this letter. In addition, failure to take the actions addressed in this Confirmatory Action Ixtter may result in enforcement action.

The response directed by this letter is not subject to the clearance procedures of the Office of Management and Budget, as required by the Paperwork Reduction Act of 1980, Publication L.96-511. In accordance with 10 CFR 2.790(a), a copy of this letter will be placed in the NRC Public Document Room.

Sincerely,

- /

A 1arles W. Hehl. Directne Division of Radiation Safety and Safeguards O .

Appleton Papers, Incorporated ,

cc:

! Public Document Room (PDR)

Nuclear Safety Information Center (NSIC)

Commonwealth of Pennsylvania bec:

Region I Docket Room (w/ concurrences)

H. Dompson, DEDS J. Lieberman, OE T. Martin, RI W. Kane, RI C. Paperiello, NMSS J. Glenn, NMSS K. Smith, RI D. Holody, RI S. Lewis, OGC S. Childakel, OGC (.h

C. Hehl, RI '

S. Shankman, RI R. Bellamy, RI W. Pasciak, RI S. Courtemanche, RI S. Shaffer, RI M. Miller, RI-1 i

f: E .