IR 05000235/2023001

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Discusses Safety Insp of License 50-23523-01 on 890504 & 0614 & Forwards Notice of Violation
ML20245F229
Person / Time
Site: 05000235, 03028608
Issue date: 06/19/1989
From: Pate R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To: Mallory H
CONSTRUCTION TECHNICAL SERVICES
Shared Package
ML20245F233 List:
References
NUDOCS 8906280066
Download: ML20245F229 (4)


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UNITED STATES NUCLEAR REGULATORY COMMISSION

  • ,e i nraion v H00 MARIA LANE, SulTE 210

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%,"****/[ WALNUT CREEK. CALIFORNIA ME06 s3BB JUN 191999 License No. 50-23523-01 Construction Technical Services '

3340 Meander Way Juneau, Alaska 99801 Attention: Mr.' Howard Mallory Radiation Protection Officer Gentlemen:

SUBJECT: NRC Inspection This refers to the routine safety inspection conducted by Mr. J. F. Pang of

this office on May 4,1989 and June 14, 1989 of activities authorized by NRC License No. 50-23523-01 and to the discussion of our findings held by Mr. Parg with you at the conclusion of the inspection on May 4, 198 Tne inspection was an examination of the activities conducted under your license as they relate to radiation safety and to compliance with the Commission's rules and regulations and the conditions of your license. The inspection consisted of select'ive examinations of procedures and representative records, interviews with personnel, and observations by the inspecto Based on the results of this inspection,'it appears that certain of your activities were not conducted in full compliance with NRC requirements, as set forth in the Notice of Violation enclosed as Appendix A to this letter. These items have been categorized into severity levels as described in the NRC Enforcement Policy, 10 CFR Part 2, Appendix The findings from this inspection, indicate two repetitive violations (See Appendix A, Items A and C.) from the inspection conducted on June 27, 198 We are concerned about the repetitive nature of the violations during our .

inspections. In addition to the need for corrective action regarding the i specific violations included in Appendix A, we are concerned about the implementation of your management contrcl which allowed these repetitive violations to occur. Consequently in your reply you should describe in particular those actions taken or planned to improve the effectiveness of your overall management syste On June 9,1989, I and Mr. D. D. Skov held a telephone management meeting with j you regarding the findings of ths inspectio I summarized the findings and i

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emphasized the seriousness of the violations. It was reiterated to you that any further noncompliance with leak testing or physical inventories is unacceptable to the NRC staff and could re= ult in escalated enforcement action including the assessment of a civil penalty and the modification, suspension or revocation of your license. You were also notified that an early reinspection would be conducted to determine the effectiveness of your management commitment to correct the violation (

0906280066 090619 [

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'JUN' 19 1989

. Based on the documents we received in the mail from you on June 14,.1989, the following comments apply, The Comments are referenced to the violations in the attached Appendix A, dotice of Violation as follows: Leak Tests Although you sent records of a leak test dated 5/17/89, this does not obviate the violation since the gauge had not been leak tested iri a timely manner prior to use as t:ited in the violatio ,

0.1. DOT 7A Test Results and Evaluation

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The certificate provided by Troxler Electronics Laboratories, Inc.

J' (hereafter referred to as "Troxler"), is unacceptable in that it

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does not include the test results and evaluation,

'f D.2. The model shipping paper that you have prepared is acceptable for use. However, note that the regulations require it to be present in the cab of the vehicle whenever the gauge is being transporte Since this or a similar document had not been used prior to the inspection on May 4, 1989, the violation stand No further response to this item is require D.3. Special Form Certificate The Special Form Certificate provided by Troxler is unacceptable in that it does not include the test results and evaluatio Alternatively an IAEA Certificate of Competent Authority issued for the Special Form Material is acceptable in lieu of the Special Form Certificate with test results and evaluation. The certificate provided to you by Troxler only alludes that such a certificate had been issue However, such a statement cannot be used as a substitute for a copy of a IAEA Certificate of Competent Authority issued by the Department of Transportation for the Special For For the above reasons, items A, D.1, 0.2 and D.3 remain as violation We understand that Troxler has been amiss in providing you and other licensees with incomplete information for the Special Form Certification and the DOT 7A test results and evaluation. We are in the process of correcting this situation. Nevertheless, you must obtain the required information from Troxle Because we are sending you copies of the letters which you do not have relative to the violation stated in Item F, Appendix A, no further response to this item is require Your response to this Notice is to be submitted in accordance with provisions of 10 CFR 2.201 as stated in Appendix A, Notice of Violatio _ - - _ - _- __ ______ _

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-3-The responses directed by this letter and the accompanying Notice are subject-to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-51 If you have any questions on this matter or concerning this inspection, please telephone Mr. Pang on 415-943-370

Sincerely,

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Robert J. Pate, C5ief

Nuclear llaterials Safety and Safeguards Branch i

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