ML20237H286

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Responds to NRC Re Violation Noted in Insp Rept 50-170/87-02.Corrective Actions:All Specified Waste Drums Properly Labeled Per 10CFR20.203(f) & Health Physics Procedure 6-2 Accordingly Revised.Procedure Encl
ML20237H286
Person / Time
Site: Armed Forces Radiobiology Research Institute
Issue date: 08/07/1987
From: Irving G
DEFENSE, DEPT. OF, DEFENSE NUCLEAR AGENCY
To:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20237H290 List:
References
NUDOCS 8708170134
Download: ML20237H286 (2)


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gg DEFENSE NUCLEAR AGENCY ARMED FORCES RADIOBIOLOGY RESEARCH INSTITUTE BETHESD A, M ARYLAND 20814-5145 7 August 1987 w

RSDS-Reactor

SUBJECT:

Notice of Violation from Inspection Report # 50-170/87-02 Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 Gentlemen:

In response to the Notice of Violation dated 9 July 1987, the following statements of fact are submitted for your consideration.

The volation did occur as stated. However, we believe that this violation was minor and would not have resulted in an increased threat to the public health and safety for two reasons. First, the unlabeled drums were being stored in an area to which unescorted access is strictly controlled and limited to members of the Reactor and Radiation Safety staffs. Second, that storage area was appropriately marked as an area that contained radioactive materials.

l At the time this violation was identified to the radiation safety staff by the NRC inGpectors, immediate corrective action was l taken. All the speed.fied waste drums were properly labeled.

l resulting in full compliance with 10 CFR 20.203(f).

To avoid the future potential for non-compliance with l 10 CFR 20.203(f), Health Physics Procedure 6-2, paragraph 70, (at the enclosure) has been revised to indicate that any container in which radioactive material is accumulated and could exceed Appendix C quantities will initially be posted with a clearly visible label bearing the radiation symbol and the words " CAUTION, RADIOACTIVE MATERIAL." The radioactive codtents will also be identified by a tag or otherwise clearly visible label.

I 8708170134 e70007 PDR ADOCK 05000170 0 PDR 1\

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.:, , 1 Full compliance was achieved immediately after the violation was identified as noted in paragraph two, above. Changes to the Health Physics Procedure 6-2 were made on 7 July 1987. This

( completes all action concerning this Class V violation.

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GEORQ f. IRVING, II Colonel, USAF, BSC Director 1 Enol SS l