ML20234D989
| ML20234D989 | |
| Person / Time | |
|---|---|
| Issue date: | 03/18/1987 |
| From: | Lickus R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Doda R, Horner J, Woodruff R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20234D394 | List: |
| References | |
| FOIA-87-809 NUDOCS 8801070363 | |
| Download: ML20234D989 (17) | |
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March'18, 1987
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MEMORANDUM FOR: Richard Woodruff. State Agreements Officer, Region 11-Robert Doda, State Agreements Officer, Region IV .
Jack Horner, State Agreements Officer, Region.V ]
FROM: Roland Lickus, Chief, State and Government Affairs, Region III Enclosed you will find a notification of Significant Enforcement Action against Radiation Sterilizers, Inc. This action was.taken based upon violations identified at two facilities (Gamma Irradiators) in Illinois and Ohio. We understand that similar Radiation Sterilizer facilities are operated in the states of Texas, California, and Georgia, and suggest that you may want I to pass this information along to those states.
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l Roland Lickus, Chief State and Government Affairs l
Enclosure.: As stated cc w/e~nclosure:
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8801070363 B71231 PDR FDIA-DEVICB7-009 PDR
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March 12, 1987 EN 87-20 0FFICE OF INSPECTION AND ENFORCEMENT l NOTIFICATION OF SIGNIFICANT ENFORCEMENT ACTION
. License,. Radiation Sterilizers, Inc.
Docket No. 030-19025 . .
Subject:
PROPOSED IMPOSITION OF CIVIL PENALTY - 510,000 This is to infore the Commission that a Notice of Violation and Proposed l
]eposition of Civil Penalty in the amount of Ten Thousand Dollars (530,000) '
will de issued on or about March 17, 1957 to Radiation Sterilizers, Inc. This action is based on numerous health physics violations including: (1) failure to raintain warning devices in an operable condition, (2) f ailure to. check irradiation cells for personnel prior to exposing the source, and (3) f ailure to utilize personnel access control tags. The base civil penalty was increased by 100% because: (3) the licensee failed to take effective corrective actions i, for previous violations, (2) the licensee had notice that the safety device's were inoperable but did not correct the problem, and (3) some of the violations-existed for several months.
It should be noted that the licensee has not been specifi.cally inforced of the enforcement action. The Regional Administrator has been authorized by the Directer, Office of Inspection and Enforcement, to sign this action. The schecule of issuance and notification is: 1 Mailing of Notice March 17, 1987 i
Telephtne hetification of Licensee 4
March 17, 1957 A news release has been prepared and will be issued after the licensee receives the hetice.
Tht State 3ef Californian ill be notified. I
% tw/M The licensee has thirty days frot the date of the Notice in which to respond.
Following NEC evaluation of -the. response, the civil penalty may be reritted, mitigated, or imposed by Order.
Contact:
P. Robinson, IE 295E3 A. Beach, IE 24909 Di st ribut ion:
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H Street MNBB Phillips i Chairman 2ech EDO EW Willste j NRR IE NMSS Com: Roberts DED/RO3P, 01A Comm. Asselstine PA 01 Comm Bernthal 03C AEOD Comm. Carr RM ACRS SECY Air Rights Regional Offices MAIL CA SP RI RIV ADM: Doc. Mgt. Br.
03C RII RV PDR-RIII RES j
PRELIMINARY INFORMATION - NOT FOR PUBLIC DISCLOSURE UNTIL PUELICLY " A!
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/*% UNITED STATES !
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e, NUCLEAR REGULATORY COMMISSION ;
OFFICE OF PUBLIC AFFAIRS, REGION lli 799 Roosevelt Road, Glen Ellyn, filinois 60137 i NEWS ANNOUNCEMENT: 87-24 N' Y' CONTACT: Jan Strasma 312/790-5674 :
Russ Marabito 31?/790-5667 j i
NUCLEAR REGULATORY COMMISSION STAFF PROPOSES $10,000 FINE AGAINST A CALIFORNIA FIRM FOR VIOLATIONS OF NRC REQUIREMENTS AT ITS TWO RADIATION STERILIZING FACILITIES IN ILLINDIS AND OHIO '
The Nuclear Regulatory Commission staff has proposed a $10,000 fine against Radiation Sterilizers, Inc., of Menlo Park, California, for violations of NRC safety requirements at the company's irradiator facilities in Schaumburg, Illinois and Westerville, Ohic. i The compan and cesium-137)y to is licensed sterilize by the products medical NRC to use radioactive through material (cobalt-60 irradiation.
An NRC inspection on January 14, 1987, at the Schaumburg facility and {
January 27, 1987, at the Westerville facility, determined that the licensee j failed to promptly repair safety-related systems after they became aware that '
the systems were not functioning properly.
Specifically, NRC inspectors found that operators at each location failed to make a thorough visual check of the entire irradiation cell (a large room containing the radioactive sources) prior to exposing the sources---a violation of NRC requirements. The inspections also found that smoke and temperature 1 alams in the cells were not tested on a monthly basis, as required.
Other violations included: At the Schaumburg facility -- failure to maintain an oper'able warning light outside the cell to warn when irradiation was taking place and failure to maintain an emergency telephone call list in the control room. At the Westerville facility -- failure of a cell entry door !
to remain closed (it malfunctioned and opened during the NRC inspection r.aising the possibility that it could open again at a more critical time) and failure j to maintain a seismic detector in an operable condition to automatically halt '
irradiation in the event of an earthquake.
In notifying the company of the proposed fine, A. Bert Davis, Acting .
Regional Administrator, said "these violations demonstrate a significant breakdown in management oversight and control of the company's radiation safety program."
The company has until April 16, 1987, to pay the proposed fine or protest it. If the fine is protested, the NRC staff will consider the basis of the '
protest in detemining whether to formally impose the fine. If the fine is imposed, the utility may request a hearing.
March 20,1987
k V .. maw *o 4 UNITED STATES
' E NUCLEAR REGULATORY COMMISSION i', I OFFICE OF INSPECTION AND ENFORCEMENT
\.....,/ Washington, D.C. 20555 INSPECTION AND ENFORCEMENT MANUAL DI l
CHAPTER 2800 MATERIALS INSPECTION PROGRAM 2800-01 PURPOSE To establish the inspection program for licensees authorized to possess and use licensed material for radiography, medical programs, academic and industrial uses, waste disposal operations, manuf acturing and distribution of products, and leak testing, calibration, other types of services, and transportation related thereto.
2800-02 OBJECTIVES 02.01 To establish general policy for the materials inspection programs, including priorities for inspection.
02.02 To define specific requirements for inspection of materials licen-ses.
I 02.03 To aid in the achievement of a consistent process of inspection for materials licensees.
2800-03 DEFINITIONS 03.01 Inspection Priorities. The priority number assigned For to a licensee R example, R is based on the potential hazard of the licensee's programs. !
a license with an inspection Priority 1 is one in which there is the great- R est potential for hazards in health and safety; this priority requires the R l most frequent inspections because of the nature of the operations. On the R i other hand, an inspection Priority 7 involves little potential hazard to RR l health and safety and requires less frequent inspection.
03.02 Telephonic Contacts. These are contacts done by telephone using a _R questionnaire to determine the status of licensees'Priorities These con- R activities.6 and tacts are only used for the low priority licenses, 7, and R l under certain conditions, Priority 5 licenses (see Enclosure 1 for instruc- R 1 R
tions).
03.03 Telephonic Inquiries. These are inquiries done by telephone to de- R termine (1) some facts about the licensed program such es reminding the R i licensee that its license is near expiration, (2) if there is sufficient R activity to conduct an inspection (radioactive material may be in storage), R or (3) if the licensee actively possesses radioactive material under its R i
Issue Date: 04/08/87 :
. 04.06 Inspection Activities and Licnnsce Inspection Fees. The follo:ing R guidance is being provided to assist in determining when activities con- R stitute an inspection and when fees applicable to those activities will be R R
charged to the licensee. :
- a. Before scheduling an initial inspection, determine if the licensee R possesses any radioactive material. An initial inspection should R not be attempted if it is' determined that the licensee does not R possess licensed material. An inspection should not be considered R to have been performed if, after arriving on an announced initial R i inspection, it is found that no radioactive material is possessed. R j Before attempting an initial inspection, the licensee should be con- R ]
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R tacted by telephone.
i An inspection should not be considered to have been performed (1) R j b.
if, after arriving on an unannounced inspection, it is found that no R I
radioactive material is possessed or used because of disposal or R storage of the material and no inspection activities are performed R l or (2) if the licensee or licensee's representatives are not avail- R l able to assist with the inspection and the inspector is unable to R perform inspection activitics. On the other hand, if it is possible R ,
to inspect records or other items according to license conditions or R l NRC regulations, such activities should be inspected and be recorded R I' as an inspection whether the radiation safety officer (R50) is pre- R sent or not, including those licenses that have been terminated. R
- c. For any situation where an inspection was not performed as defined R above, the region should not prepare an NRC form notification to the R licensee or other type of document that is sent to the licensee and R the region should not record the attempted inspection in the Li- R cense Management System (LMS) as "an inspection." However, a note R should be placed in the docket file to record the reason an inspec- R '
tion could not be performed and giving a date when the next inspec- R tion should be performed. The "next inspection date" data element R in the LMS should be changed to reflect the new date. R
- d. Telephone contacts are not inspections. Therefore, the results of R these activities should not be recorded on an NRC-591 form or in a R Notice of Violation. The fact that a telephone contact of a licen- R see was made should not be entered iato the LMS as an inspection. R However, the Regulatory Information Tracking System (RITS) allows R the time spent in gathering factual material to be charged against R the time budgeted for performing routine inspections. R 04.07 Unannounced Inspections. With the exceptions provided in the above R sections of this manual chapU r, all other materials inspections should be R performed on a strictly unannounced basis. R 2800-05 TELEPHONE CONTACTS As defined in 03.02, contacts by telephone are a useful means of maintain- R ing contact with licensees who are never inspected or are inspected infre- R quently. Such contacts may be performed by an adequately trained person R 2800 Issue Date: 04/08/87
The designated inspection priority for these licensees should not be changed in the LMS. However, the "next inspection date" data element in the LMS should be changed to contain the extended date for the next inspec- R tion. To support the extension in- the interval between inspections, a R brief note should be written giving the basis for the extension, approved R R
by the Section Chief, and placed in the docket file.
2800-08 REDUCTION OF INSPECTION INTERVAL The interval between inspections may be reduced (shortened) and inspections conducted more frequently than specified by the priority system on the basis of minimally satisf actory performance on the part of the licensee.
The governing consideration in reducing the inspection interval should be a lack of confidence in the level of performance in safety and compli-ance on the part of the licensee that indicates continuing adequate pro-tection of worker and public safety will not be provided without increased attention by the licensee and the NRC. The determination to reduce the inspection interval shall be made on the basis of an inspection, consider-1 ing current and prior findings. For computer entry, the letter R shall be entered for licensees on a reduced inspection interval.
The designated inspection priority for these licensees should not be R changed in the LMS. However, the "next inspection date" data element in R LMS should be changed to contain the date for the next inspection based on R a reduction of the interval between inspections. A brief note should be R written giving the basis for the reduction, approved by the Section Chief, R and placed in the docket file. R I
2800-09 SCHEDULING OF INSPECTIONS 09.01 Basis for Scheduling. The month in which an inspection is actually performed may be completed earlier or later than scheduled (by its place-ment in the priority system) for the purpose of the efficiency realized in inspector travel time. The efficiencies of travel- time should be balanced against the basic purpose of the inspection priorities, that is, effective use of an inspector's time versus the potential hazards in a licensee's operation. A low priority licensee should not be over inspected just be-cause an NRC inspector is in the area of the facility. Inspection of a high priority licensee should not be unduly delayed merely for scheduling purposes.
09.02 Radiography Inspections. For radiography licensees that are autho-rized to conduct radiography at temporary job sites, an inspection of a temporary job site should be attempted for at least 25% of these licensees.
For a number of the inspections of temporary job sites, attempts should be made to accompany licensee auditors during a quarterly audit of those sites. The' accompaniment of auditors may be on an announced basis.
09.03 Combining Inspections. If a licensee holds more than one kind of license (that is, of different priorities), a single inspection may be scheduled whenever practicable to aid in more effective use of inspector's time spent in travel status. In the determination to combine inspections on a continuing basis, consideration should be given to "over inspecting" a lower priority license versus the need and desirability of inspecting a licensee's total activities for a more complete picture of its safety and 2800 Issue Date: 04/08/87
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- 2800-10 REG 10NAL RESPONSIBILITY FOR LICENSES-10.01 General. When a license authorizes operations in more than one re-gion, the responsibility for inspection shall reside with the regional of-The main office means fice in which the licensee's main office is located.
the corporate' office, normally the address given on the license.
Assistance in Inspections. In the interest of efficiency in travel 10.02 time and funds, the responsible regional office shall request another re-gional office to conduct inspections (assist inspections) of the activities of such licensees when the licensee is operating outside the geographical area of the responsible region. The inspecting region should provide com-plete documentation (draft inspection report) and recommend enforcement action to the responsible region. The responsible region should distribute the documentation, initiate enforcement action, and take other followup actions, as appropriate to the case. These last two' actions shall be completed by mutual agreement of the regional offices involved.
When requesting assist inspections, the regional offices shall take into consideration the sample size of inspections for which they are requesting assistance. In this effort, the regions should differentiate between large and small companies and establish different inspection programs for each general class of licensee. Some companies have many field offices and others have few. The strength of the licensee's internal inspection pro-gram is another factor in determining the sample size of the licensee's field operations 10.03 Transfer of Responsibility. Notwithstanding the above (10.01 and 10.02), when a license carries an address that places the inspection responsibility in one region and operations under the license occur princi-pally within another region, the inspection responsibility may be trans-ferred to the region in which the operations are performed. This transfer shall be done with mutual agreement of the regional offices involved. The regional offices should ensure that the appropriate changes are made to the LMS to show which office- has the overall responsibility for inspection and enforcement.
2800-11 INSPECTION OF GENERAL LICENSEES Routine Inspection Not Required. With the exceptions specified in 11.01 11.02, inspections of general licensees are not required on a routine ba-sis. However, inspections shall be made to resolve allegations, com-plaints, or other indications of an unsafe practice or a case of noncom-pliance, or when such an inspection is directly pertinent to an inspection involving a specific license. Any inspections conducted under the above provisions should be done during activities conducted in areas of NRC jurisdiction.
11.02 Inspection of Activities Under Reciprocity. The NRC region in which an Agreement State is ircated is the recipient of the NRC-241 form report from a State licensee of its proposed activities in non-agreement States.
The regional of fice receiving the NRC-241 form shall take action on the report, including prompt notification of the NRC regional office having jurisdiction in the area in which the Agreement State licensee's activities take place. The responsible regional office shall make every reasonable effort to conduct inspections of Agreement State licensees at the same fre-quency as the NRC licensees.
Issue Date: 04/08/87 2800
15~.02 Data should be em ered. promptly into the LMS at the time a new li- R. fg R 'Ir:*,
cense is issued or an insjection has been performed, including the dates for initial inspections of new licensees, the last inspection date,' and the-RR * (,)
next inspection date for licensees already inspected.
R 2800-16 INSPECTION PROCEDCRES FOR THE MATERIALS PROGRAM Table 2. lists the inspection procedures that should be used.in the mate . RR rials inspection program and the frequency for use of each procedure.
END
Enclosures:
- 1. Tables
- 2. Appendix l
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2800 Issue Date': 04/08/87
Table 1 Inspection Priority by Program Codes Program Priority Category Title Remarks Code Academic Type A Broad Committee approved users 2 01100 3 01110 Academic Type B Broad R50 approved users ,
Named users 5 01120 Academic Type C Broad .
l Academic Other (Secondary Code) Classroom teaching- ,
01200 Physics, Biology, or i Chemistry (see program {
j code 03620) l Hospitals only 2 j 02110 Medical Institution Broad 02120 Medical Institution Other - Group Hospitals only 3 02121 Medical Institution Other -
Groups I, II (includes Diagnostic - 5
{
Limited Therapeutic)
Medical Private Practice - Group 5 02200 Clinics and diagnostic medical centers with 4 one or more physicians 3 ,
02201 Medical Private Practice - Lixiscopes by podia-Groups I, II (includes Limited trists, physicians Diagnostic, Limited Therapeutic) (bone mineral analysis)
Also iodine-131 for diagnostic / therapeutic 5 02210 Eye Applicators Strontium-90 Hospitals or physician's offices 5 3 1 l
02220 Nuclear Medical Vans l 02300 Teletherapy Human use only 3 5
02400 Veterinary Nonhuman In Vitro Testing Laboratories 5 02410 2
02500 Nuclear Pharmacies - R 02510 Medical Product Distribution-32.70 (No active licenses) 02511 Medical Product Distribution-32.72 Radiopharmaceuticals 3 R 02512 Medical Product Distribution-32.73 Reagent Kits 5 R Mo/Tc generators 3 R 02513 Medical Product Distribution-32.74 Group VI materials, calibration and references sources 3 R 03110 Well Logging Byproduct and/or SNM 3
Tracer and Sealed Sources 03111 Well Logging Byproduct and/or SNM Sealed Sources Only 3 03112 Well Logging Byproduct Only-Tracers 3
Only 3
03113 Field Flooding Studies 7
03120 Measuring Systems Fixed Gauges Industrial Lixiscope 5 03121 Measuring Systems Portable Gauges Moisture / density gauges 4 R 1
04/08/87 l
2800 T1-1 Issue Date:
I O
Program Priority
, Category Title Remarks Code 03251
- Exempt Distribution Time Pieces - 32.14 H-3, Pm-147, and other isotopes in 30.15 5 R Sc-46 resins 5 R' 03252
- Exempt Distribution - 32.17 03253
- Exempt Distribution - 32.18 Byproduct material in processed chemical elements, compounds, mixtures, tissue samples, bio-assay samples, etc. 5 R 03254
- Exempt Distribution - 32.22 Self-luminous
' products 5 R
- Exempt Distribution - 32.26 Smoke detectors 5 R 03255 Industrial Radiography Fixed 1 03310 Industrial Radiography Temporary 1 03320 Job Sites 03S10 Irradiators Self Shielded <10,000 Curies 3 03511 Irradiators Other <10,000 Curies Animal teletherapy 3
<1000 curies from which no beam can be extracted 6 R- ;
W i 03511 Irradiators Under Construction 03520 Irradiators Self Shielded >10,000 Curies 3 03521 Irradiators Other >10,000 Curies Pool type, other 1 gamma cells 3 R 03521 Irradiators Under Construction W 1
03610 Research and Development Type A Broad Committee approved !
Users 2 03611 Research and Development Type B Broad R50-approved users 3 03612 Research and Development Type C Broad Named users 5 and nonBroad Small 1 Multisite-Multiregional Type A Broad -
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l (Secondary Code) l 03620 Research and Development Other Teaching, non-l routine in vitro, l Program Code 01200, and other 5 R 1
03710 Civil Defense 7 1 11200 Source Material Other <150 Kilogram 3 i 11210 Source Material Shielding 7 R 11220 Source Material Military Munition Indoors / 7 Testing outdoors 3 R l
l 11230 Source Material General License Distribution - 40.34 5 R i
2800 T1-3 Issue Date: 04/08/87
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Table 2 Inspection Procedures The procedures listed in this table comprise the inspection program for materials licensees. The list of procedures is divided into two parts, programmatic and generic. The programmatic procedures specify the inspec-
' tion requirements for operational and radiological safety aspects of licen-see activities; the generic procedures cover instructions and requirements applicable to all licensees.
Inspection l Procedure Frequency
- Number Title PROGRAMMATIC PROCEDURES I, P 83822 Radiation Protection Manufacturing and Distribution Relicensing W R 87100 I, P R 87100 Manufacturing and Distribution Postlicensing I, P 87100 Multisite Broad License I, P R 87100 Radiography I, P R 87100 Radiography - Field Sites I, P R 87100 Waste Disposal 87100 All other Special Nuclear Material, Industrial, Academic, Environmental, I, P R and Other Specific Licenses Multisite/Multiregional Broad Licensees I, W ,
MC 2810 MC 2815 Construction and Preoperational Inspection of Panaramic Wet Source Storage Gamma Irradiators W R I, P R 87100 Medical Medical Teletherapy I, P R 87100 Inspections of Waste Generator Requirements I, P **
84050 I, *** R l 89100 Performance Indicators GENERIC PROCEDURES 1
W R 0517 Management of Allegations (proposed MC) i X
30703 Management Meeting--Entrance and Exit Interviews )
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- See footnotes at end of table.
1 l 2800 T2-1 Issue Date: 04/08/87 !
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i Enclosure 1 Telephone Contact Procedures for Priority 5, 6, and 7 Licenses Program Objectives: In the past there have been times when manpower limita-tions have required exempting lower priority licensees from routine inspection by the NRC. As a result of this practice, the regions were lef t with a large number of licensees many of which had never been inspected. To improve general performance of these low priority licenses, this telephone contact procedure was developed so each licensee would be interviewed at least once during the duration of the license and at some periodic frequency thereafter to be determined by the regional staff.
- 1. Select license to interview at random (see 2800-05) from the computer Af ter this is done, select li-listing of licenses never inspected.
censees that have had initial inspections (Priorities 6 'and 7) and those inspected infrequently (Priority 5).
- 2. Pull the license file and review the file to determine the person to contact for information needed to complete interview questionnaire (Enclosure 2).
- 3. Telephone licensee and complete questionnaire. Note that not all licen-ses require each procedure mentioned in the questionnaire.
- 4. If the licensee reports any problems, namely:
- a. personnel exposures in excess of 1.25 rems for a calendar quarter i
- b. lost licensed material
- c. leak tests indicating source leakage or
- d. any event the licensee considered unusual The person filling in the questionnaire should promptly notify the Ma-terials Section Chief. Provide the Section Chief with the appropriate draft letter (Enclosure 3).
- 5. If the licensee responses confirm no problems are present, prepare the .
appropriate draft transmittal letter (Attachment 4) for signature by the l l
Section Chief. 1
- 6. Send package to Section Chief for review. ,
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NOTE: The first priority on use of an inspector's time should be reduction of the backlog of overdue materials inspections in the higher priori-ties (1, 2, 3, 4).
2800 El-1 Issue Date: 04/08/87 1
Enclosure 2 ;
i EVALUATION OF POSSESSIONS AND USE OF BYPRODUCT MATERIAL Namt: License Number: l i
Address: Phone Number: i Name and Title of person responsible for radiation safety program:
)
Describe how this material is used:
4 Describe how you safeguard the byproduct material from use by unauthorized personnel- I Describe how you safeguard the material from loss or theft:
1 Describe controls which prevent individuals who work in the area around the material from becoming exposed to radiation:
i Do you have a personal monitoring program for your employees such as film badges, dosimeters, . Yes No If yes, were there any exposures to individuals in excess of 1.25 rems for any calendar quarter for the year (s) ?
Yes No 2800 E2-1 Issue Date: 04/08/87
- Enclosure 3 i
License No.
Gentlemen:
This refers to a telephone contact conducted on , 19 ,_.
The contact was an examination of activities conducted under your license as they relate to radiation safety and to compliance of the Commission's rules and regulations and with the conditions of your license. The contact con- !
sisted of discussions with .
As a result of this examination of activities, regulatory concerns were noted and are specified below. These may be evaluated at an onsite inspection at your facility in the near future.
As you described on the telephone, the following apparent regulatory concerns were identified.
(examples)
- 1. failure to leak test sealed sources at the required intervals
- 2. an exposure of rems to an individual during the third quarter of ,
1986*
- 3. an apparently lost gauge containing curies of *
- (If apparently serious enough (such as overexposure), add the following)
You should examine your license and NRC regulations to determine how you can correct the apparent regulatory concerns that you discussed on the telephone.
In addition, we would like to highlight the following items that licensees should pay particular attention to as follows:
- a. maintaining awareness and control of licensed material
- b. proper transfers and disposal of radioactive sources
- c. promptly reporting losses or thefts of licensed materials If you have any questions regarding this contact, you may contact us at Sincerely,
, Chief Nuclear Materials Safety and Safeguards (Branch or Section) i DCC DCS/RSB (RIDS) 2800 E3-1 Issue Date: 04/08/87 j j
.2 Enclosure 4- I
~1 License No.
l
'Gentiemen: l This refers to a telephone contact conducted on , 19' _.
The contact was an examination of activities conducted under your license l as they relate to radiation safety and to compliance of the Commission's rules and regulations and .with the conditions of your license. .The contact
~
i consisted of discussions with .
1 1
No regulatory concerns were identified.
If you have any questions regarding this contact, you may. contact us at -
Sincerely, i
, Chief-Nuclear Materials Safety and.-
Safeguards (Branch or Section) )
.)
bCC DCS/RSB (RIDS)
.i 2800 E4-1. Issue Date: 04/08/87
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