ML20236V000
| ML20236V000 | |
| Person / Time | |
|---|---|
| Issue date: | 07/22/1998 |
| From: | Kirkwood A NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Rose C AFFILIATION NOT ASSIGNED |
| References | |
| NUDOCS 9807310233 | |
| Download: ML20236V000 (2) | |
Text
an 54
[fj.%,t 4 1 UNITED STATES j
y NUCLEAR REGULATORY COMMISSION
- t WASHINGTON, D.C. 20555-0001 t,,
July 22, 1998 l
NC Systems, Inc.
ATTN: Mr. Charles H. Rose 560 Airport Blvd., Suite 101 Boulder, Colorado 80301 1
Dear Mr. Rose:
This letter responds to your question in a letter dated May 19,1998, addressed to Mr. Charles M. Hosey, Nuclear Regulatory Commission (NRC), Region 11 and those discussed during a July 9,1998, telephone conversation you and I had.
Your question in the May 19,1998, letter asked "if a supplier accidentally ships a source to a site where no license exists, discovers the error prior to the arrival at the site, arrange (s) to intercept the source on behalf of a licensee who would take possession of the source and did indeed intercept the source so that the unauthorized site never has possession of the source, has a license violation occurred?"
in response to the May 19,1998, question we assume you mean that the shipper and the interceptor are specifically licensed by the NRC for the byproduct material in question. In this j case 10 CFR 30.41, Transfer of Byproduct Material, requires, in part, that before transferring i byproduct material the licensee shall verify that the transferee's license authorizes the receipt of l the byproduct material transferred by one of 5 methods. If this was not done a violation of ;
10 CFR 30.41 would occur. However, if the shipper or other authorized licensee were able to I intercept the package before receipt by the unlicensed person, the violation could be considered as self-identified and providing action was taken to prevent recurrence, and it was not repetitive or willful, this could be considered a non-cited violation at Severity Level IV.
During our July 9,1998, conversation you added the situation of the shipper sending the i byproduct material to the wrong address and again intercepted by an authorized licensee.
Assuming your license verification process required by 10 CFR 30.41 was performed and reasonable and prudent care was taken to ensure delivery to a licensed receiver, the situation described does not appear to constitute a violation of NRC requirements.
In addition, during our July 9,1998, conversation you mentioned that Landauer, a commercial 0 dosimetry provider, was about to change its customers service from monthly film to bi-monthly l Optical!y stimulated Oght (OSL) dosimeter's unless Landauer werra cotified otherwise by their '.
customers. You mentioned two concerns related to this actior The first concern related the 'O necessity for license amendments if this should occur and the resultant costs that would be Y-imposed on your clients. The second concern related the issue of monitoring occupational exposure to a declared pregnant woman pursuant to 10 CFR 20.1208, and of how a " licensee shall make efforts to avoid substantial variation above a uniform monthly exposure rate to a declared pregnant woman." The short answer to your first question is there does not appear to be any wrongdoing or violation of NRC requirements by Landauer since they have given their customers (licensee's) an opportunity to not accept this change. Since Landauer's customers are given an opportunity to reject the change from monthly service, your second question would already appear to be answered, , L-t I h 3o N9* 4 3
m i
C> fb C. Rose I trust this responds to your questions. If you have any additional questions on these matters you may contact me at (301) 415-6140 or Mr. Steven L. Baggett at (301) 415-7273.
Sincerely, Original S!0 nod By:
Anthony S. Kirkwood Anthony S. Kirkwood Materials Safety Branch Division of Industrial and Medical Nuclear Safety Office of Nuclear Materials Safety and Safeguards i
cc:
Charles M. Hosey, Ril DISTRIBUTION IMNS r/f PDR ,NR03 Central file > NMSS r/f DOCUMENT NAME: H:\KIRKWOOD\lNFOLTRs\CROsE.WPD C = COVER E = COVER & ENCLOSURE N = NO COPY OFC MSB.NMSS C MSB NMSS . , , ,C _n OE C
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NAME ASKirkwood ask 0 SLBagge , _fcA. JLiet a ,
DATE 07/15/98 07/)V/98 07/ 3.1 198
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