ML20247E087
| ML20247E087 | |
| Person / Time | |
|---|---|
| Issue date: | 04/06/1998 |
| From: | Costello F, Reber E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20247E081 | List: |
| References | |
| REF-QA-99990001-980406 99990001-98-02, 99990001-98-2, NUDOCS 9805180203 | |
| Download: ML20247E087 (7) | |
Text
_ - ___ - _ - __ _ __ _ _ _- ___
U.S. NUCLP.AR REGULATORY COMMISSION REGION I Docket No.:
999-90001 License No.:
None (as of the date of the inspection)
Report No.:
98-002 Facility:
Breitling USA, Inc.
Location:
2 Stamford Landing Stamford, Connecticut 06902 Date:
March 10,1998 j
i i
Y
]
A lnspector:
/
s Eric H. Reber dale Health Physicist Approved by:
uX'kS A
9/L /9V Frqheis M. Costello, C
~
date s
Nudear Materials Safet ranch 3 l
EETIT3N ORIGIN?.L TO REGION I 9805180203 900406 REG 1 GA999 EMV*****
99990001 PDR
[
EXECUTIVE
SUMMARY
Breitling USA, Inc.
NRC Inspection Report 999-90001/98-002 I
An announced inspection was performed on March 10,1998 at Breitling USA, Inc.
(Breitling) Breitling had been distributing, possessing, and repairing their Swiss-made watches containing up to 3.1 millicuries (mci) of tritium luminous paint since 1989 (with repair commencing in 1990) without a license authorizing distribution or a license authorizing possession and repair of the watches. An apparent violation for failure to obtain proper licenses was identified. A Confirmatory Action Letter (CAL) dated March 6,1998 was issued that confirmed that Breitling will cease distribution of watches containing tritium, place all licensed material in locked storage, perform surveys, decontaminate their facility and take steps to obtain appropriate licenses. As of the date of the inspection, Breitling was in compliance with the CAL dated March 6,1998. The inspectors surveyed the facility for removable contamination. The results of the inspectors' removable contamination survey indicated low-level contamination throughout the facility. Of the eighteen wipe samples taken, two wipes indicated removable contamination in excess of the NRC guidelines for unrestricted release.
1 999-90001/98-002
___-________________-_L
E l.
1 l
l REPORT DETAILS
1. Background
in February 1998, the Connecticut Department of Environmental Protection (CTDEP) l contacted NRC Region I about the possibility that Breitling may be possessing and l
repairing watches containing tritium without appropriate authorization. Region I determined, through contact with Breitling, that they were possessing, repairing and distributing watches containing tritium without the appropriate licenses. A CAL dated l
March 6 1998 was issued that confirmed that Breitling will cease distribution of watches containing tritium, place all licensed material in locked storage, perform surveys, decontaminate their facility, and take steps to obtain appropriate licenses, ll. Compliance with Confirmatory Action Letter dated March 6,1998 a.
Inspection Scope l
The inspectors reviewed the licensee's compliance with the CAL dated March 6, 1998.
b.
Observations and Findinos Breitling ceased distribution and repair of watches containing tritium and all radioactive material was placed in a locked vault on March 6,1998. Breitling hired NES, a consultant, to survey their facility. Breitling plans to send a copy of the survey results, l
a plan for decontamination, and the name of their qualified consultant to the NRC by l
March 20,1998. Breitling was in the process of preparing license applications, with their consultant, for a possession /use license and a distribution license. (Survey results, a plan for decontamination, and license applications were submitted to Region I by the time this report was prepared.)
l c.
Conclusions As of March 10,1998, Breitling was in compliance with the CAL dated March 6, 1998.
ll1. Licensing of Breitling a.
Inspection Scope I
The inspectors reviewed Breitling's authorization to possess, repair, and distribute l
watches containing licensed material for compliance with NRC requirements.
l l
l 999-90001/98-002 l
b.
Observations and Findinas Breitling receives shipments of watches containing tritium from their parent company (Breitling SA) in Switzerland. They attach the watchbands and make shipments of one to five watches to jewelry stores. Breitling also receives watches back for repair. Sometimes during repair, the watches are opened and the watch dial and the watch hands may be replaced with parts provided by their parent company.
Breitling has been distributing, possessing, and repairing their Swiss-made watches containing up to a maximum of 3.1 millicuries (mci) of tritium luminous paint since 1989 (with repair commencing in 1990) without a license authorizing distribution or a license authorizing possession and repair of the watches. During this period, Breitling j
distributed approximately 70,000 watches containing tritium (with up to a maximum of 3.1 mCl of tritium in each timepiece). On March 10,1998, Breitling possessed approximately 2,000 watches containing 1.7 to 3.1 millicuries of tritium and l
approximately 350 loose watch hands and cals.
c.
Conclusions l
10 CFR 30.3 requires, in part, that except for persons exempted, no person shall l
transfer, possess, or use byproduct material except as authorized by a specific or general license issued pursuant to Title 10, Chapter 1, Code of Federal Regulations.
l The finding that, from late 1989 to March 6,1998, Breitling transferred approximately 70,000 watches containing byproduct material (tritium luminous paint in an amount up to a maximum of 3.1 millicuries in each timepiece) without a valid NRC license issued pursuant to 10 CFR 32.14 authorizing distribution, and was not exempt from the 1
requirements for a license is an apparent violation.
l The finding that, from late 1989 to March 10,1998, Breitling possessed and used watches containing byproduct material (tritium luminous paint in an amount up to a maximum of 3.1 millicuries in each timepiece) without a valid NRC license issued pursuant to 10 CFR 30, and was not exempt from the requirements for a license is an apparent violation. Specifically, Breitling possessed watches incident to distribution and performed repairs on watches. On March 10,1998, Breitling possessed approximately 2,000 watches containing 1.7 to 3.1 millicuries of tritium and approximately 350 loose watch hands and dials.
IV. Removable Contamination Survey a.
Inspection Scope The !nspector porformed surveys for removable contamination at the Breitling facility l
by obtening eQhteen wipe samples. Each sample consisted of dry Whatman filter l
paper wipd over an area of approximately 100 square centimeters (cm ).
I 2
l Wipes were obtained in the Lunch Room, Watch Workshop, hallway adjacent to the Watch Workshop, Polishing Room, Vault, Workroom adjacent to Vault, Cleaning Room, and Conference Room.
i 999-90001/98-002 1
l l
4 The NRC Region I laboratory counted each wipe for 20 minutes for tritium emissions using a Packard Model 2250CA Liquid Scintillation Analyzer. The approximate efficiency of the counter is 18% for tritium beta emissions. The Lower Limit of 4
Detectability (LLD) of the system for tritium is 28 dpm. Background was 488 j
disintegrations for a twenty minute count or 24.4 dpm. The removable contamination criteria in Table I of the " Guidelines for Decontamination of Faciliti i Equipment Prior to Release for Unrestricted Use or Termination of Licenses i-
- product, Source or Special Nuclear Material" for beta-gamma emitters (applicable t
. tium), is 1,000 dpm/100 cm'.
b.
Observations and Findinas Wipe Number Location Tritium (dpm/100 cm')
1 Lunch Room Table 207 11 2
Lunch Room Coffee Station 205 11 3
Lunch Roe Counter Top 220111 4
Lunch Room Sink 125 1 10 5
Watch Workshop Cabinet 1080!20 6
Watch Workshop Workstation 494 1 14 7
Watch Workshop Workstation 672116 8
Watch Workshop Work Area 489114 9
Wate:i Workshop Floor 474114 10 Floor adjacent to Watch Workshop 3700 30 11 Polishing Room Polishing Table 391 !13 12 Polishing Room Polishing Table 360 13 13 Vault Counter Top 348 13 14 Vault Floor 498i14 15 Workroom adjacent to Vault 148 11 16 Cleaning Room Sink 683116 17 Cleaning Room Counter Top 440!14 18 Conference Room Table Top 161 11 l
l 999-90001/98-002 l-
r c.
Conclusions The results of the inspectors' removable contamination survey indicate that low-level tritium contamination is present throughout the facility. Two wipes indicated removable 1
contamination in excess of the NRC guidelines for unres'ricted release. Although a formal dose estimate was not performed, based on the levels of contamination detected, it is highly unlikely that any employee received a dose in excess of the f
NRC's dose limits for individual members of the public.
1 l
V. Management Meetings Preliminary results of the surveya were discussed with Marie Bodman and Keith Brown at the conclusion of the inspection.
1 1
1 I
I I
I
. 999-90001/98-002
t PARTIAL LIST OF PERSONS CONTACTED Breitlina Marie Bodman, President Keith Brown, Vice President Willy Yee, Technical Manager (Workshop) l Christin Digesare, Retum Person -
l Jim Bohrer, Shipping Manager l
l l
! 999 90001/98-002
'