Information Notice 1987-37, Compliance with the General License Provisions of 10 CFR Part 31

Compliance with the General License Provisions of 10 CFR Part 31

ML031130396
Person / Time
Site:	Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Kewaunee, Catawba, Harris, Wolf Creek, Saint Lucie, Point Beach, Oyster Creek, Watts Bar, Hope Creek, Grand Gulf, Cooper, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Three Mile Island, Braidwood, Susquehanna, Summer, Prairie Island, Columbia, Seabrook, Brunswick, Surry, Limerick, North Anna, Turkey Point, River Bend, Vermont Yankee, Crystal River, Haddam Neck, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Duane Arnold, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Yankee Rowe, Maine Yankee, Quad Cities, Humboldt Bay, La Crosse, Big Rock Point, Rancho Seco, Zion, Midland, Bellefonte, Fort Calhoun, FitzPatrick, McGuire, LaSalle, 05000000, Zimmer, Fort Saint Vrain, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant, Skagit, Marble Hill
Issue date:	08/10/1987
From:	Cunningham R NRC/NMSS/IMNS
To:
References
IN-87-037, NUDOCS 8708040157
Download: ML031130396 (6)

'

SSINS No.: 6835 IN 87-37 UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS

WASHINGTON, D.C. 20555 August 10, 1987 NRC INFORMATION NOTICE NO. 87-37: COMPLIANCE WITH THE GENERAL LICENSE

PROVISIONS OF 10 CFR PART 31

Addressees

All persons specifically licensed to manufacture or to Initially transfer

as defined in

devices containing radioactive material to general licensees,

10 CFR Part 31.

Purpose

about the

This notice is to inform manufacturers and distributors (vendors) This study

results of a study on the effectiveness of the general license.

included specific cases where general licensees violated NRC regulations.vendors

to help

It is expected that recipients will review this notice in order Vehdors will

better understand what constitutes potential violatibns. Thus, requirements and

be more effective in helping their customers comply with NRC

in this information

avoid violations at their facilities. However, suggestions actions or

notice do not constitute NRC requirements; therefore, no specific

written response to this information notice is required.

Description of Circumstances

radioactive

NRC regulations allow general licensees to use devices containing such as labeling, material. These devices are subject to certain requirements

are not aware of

accountability, and proper disposal. General licensees often devices

these requirements. Several incidents involving generally licensed devices

have raised radiation safety concerns at NRC. These incidents involved lost.

that were either dismantled and melted with scrap steel, or were

that were noted

From 1984 through 1986, the following are examples of deficiencies radioactive

that relate to the use, under general licenses, of devices containing

material:

In many

Some users did not know the location of their gauging devices.

devices had been disposed of, but

cases, they simply assumed that their

learned of disposal methods that

did not know where or how. The NRC

or removal as scrap steel by

included onsite burial, offsite burial, material for disposal

recycling companies. Unlicensed persons who receive

materials for radio- or scrap recycling do not normally test incoming

activity; thus, they may not be aware that radioactivity is present.

8708040157

IN 87-37 August 10, 1987 If a device follows one of the aforementioned disposalpathways and is

damagedirn handling, it could cause contamination of the receiver's Ad

equipment,'or of the receiverls plant', employees., or product.- This '

contamination could become widespread before being detected, possibly

causing serious risks to public health and safety. Disposal of gauging

devices MUST be entrusted only to someone specifically licensed: for this

activity. Inmost cases, gauging devices should be returnedto thevendor

for disposal. The NRC staff found that in several

violated transfer requirements by redistributing thecases, general licensees

devices to others as

general licensees, which iscontrary to NRC regulations.

The NRC staff found that vendors usually supply customers with a copy

of the applicable NRC egulations. However, the general licensee

frequently misplaces or does not read them. Thus, many general licensees

do not-realize they have any responsibility to comply with NRC requirements.

The NRC staff found that many general licensees were unaware of the NRC

requirements; most relied on the vendors'to inform them of requirements

such as device leak testing and shutter checks.' In one case, the general

licensee's employees tried to arrangefor the required tests, but the

general licensee's management denied the funds forthe tests.

The original owner of a device containing radioactive material properly

_noti fie-d the NRC oftthe-sale of-thefacl1ty and-equtpment-(-hn4eThdg--the---

device) to a new company. However, the original owner did not inform the

new company's management that it now possessed radioactive

uncontrolled surroundings, where the presence of radioactivematerial.

material

In

may

not be known, the unidentified devices can cause radiation exposures to

members of the general public.

The NRC staff found that some vendors' material transfer reports did not

contain correct or complete information on the name and full address of

the general licensees. Some of these transfer reports did not identify any

intermediate persons who temporarily possessed the device'at the intended

place of use, before its possession by the final user. Reports of no transfers

during a calendar quarter are also important. Pertinent transfer report

requirements are found in the appropriate section of 10 CFR Part 32 Subpart B.

Discussion:

Vendors should consider the following:

Vendors can communicate more effectively with their-customers about regulatory

requirements. This should increase customer awareness of, and compliance with, the NRC. requirements.

Vendors can provide more detailed information on general licenses and the

products distributed in their quarterly reports to the NRC.

-

IN 87-37 August 10, 1987 NRC and the Agreement States may have slight differences in their requirements

for general licensees. However, the vendor is responsible for compliance with

NRC and State requirements..

If you have questions about this matter, please contact the appropriate NRC

Regional office, or this office.

Aev zl

Ag

Richard E. Cunningham, Director

Division of Industrial and

Medical Nuclear Safety

Office of Nuclear Material Safety

and Safeguards

Steven Baggett, NMSS

(301) 427-9005 Lloyd Bolling, GPA

(301) 492-9889 Attachment: List of Recently Issued Information Notices

Iiw !:I i ' _1. :S ! :!? 1 . . ..

Attachment

IN 87-37 August 10, 1987 LIST OF RECENTLY ISSUED

INFORMATION NOTICES 1987

.UV;W.

Notice No. -

Subject Issuance Issued to

R7-36

• Signtficant Unexpected 0/4/87 All nuclear power

Erosion of Feedwater Lines reactor facilities

holding an OL or CP.

87-35 Reactor Trip Breaker, 7/30/87 All nuclear power

Westinghouse Model DS-416, reactor facilities

Failed to Open on Manual holding an OL or

Initiation from the Control CP employing W 0S-416 Room reactor trip Breakers.

87-34 Single Failures in Auxiliary 7/24/87 All holders of an

Feedwater Systems OL or a CP for

pressurized water

reactor facilities.

87-33 Applicability of 10 CFR 7/24/87 All NRClicensees.

Part 21 to Nonlicensees

87-32 Deficiencies in the Testing 7/10/87 All nuclear power

of Nuclear-Grade Activated reactor facilities

Charcoal. holding an OL or CP.

87-31 Blocking, Bracing, and 7/10/87 All NRClicensees.

Securing of Radioactive

Materials Packages in

Transportation.

87-30 Cracking of Surge Ring 7/2/87, All nuclear power

Brackets in Large General reactor facilities

Electric Company Electric holding an OL or CP.

Motors.

87-29 Recent Safety-Related 6/26/87 All NRClicensees

Incidents at Large authorized to possess

Irradiators. and use sealed sources

in large irradiators.

87-28 Air Systems Problems at 6/22/87 All nuclear power

U.S. Light Water Reactors. reactor facilities

holding an OL or CP.

OL

• Operating License

CP* Construction Permit

UNITED STATES

NUCLEAR REGULATORY COMMISSION FIRST CLASS MAIL

POSTAGE b FEES PAID

WASHINGTON, D.C. 2056 USNRC

WASH. D.C.

PERMIT No. 047 OFFICIAL BUSINESS

PENALTY FOR PRIVATE USE, $300

IN 87-37 August 10, 1987 NRC and the Agreement States may have slight differences in their requirements

for general licensees. However, the vendor is responsible for compliance with

NRC and State requirements.

If you have questions about this matter, please contact the appropriate NRC

Regional office, or this office.

Original Signed by, Richard _E Cun gtm

k

Richard E. Cunningham, Director

Division of Industrial and

Medical Nuclear Safety

Office of Nuclear Material Safety

and Safeguards

Steven Baggett, NMSS

(301) 427-9005 Lloyd Bolling, GPA

(301) 492-9889 Attachment: List of Recently Issued Information Notices

(See previous concurrence)

OFC: PAB* :FCOB* :FCAB :FCAB :FCAB :FCOB :NRR

_-_-_______________________________________

NAME:EKraus :JRMetzger:SBaggett :Karagiannis :VMiller :JHickey :ERossi

_-________________________________________

DATE:6/2/87  : 6/17/87 6/22/87 :6/ /87 : 6/28 /87 :7/31/87 :8/ /87 OFC: IMNS/NMSS :UMNS/NMSS god  :  :

---

---------------------------------------- ___

NAME:GSJoblom :Ruunnngna  :

DATE:8/ /87 :8/, 87 :  : *

OFFICIAL RECORD COPY

Document Name:

IN 87-37 Requestor's ID:

SHIRL

Author's Name:

SBaggett

Document Comments:

Compliance with the general license provisions of 10 CFR 31 Destination Name:

SHIRL

Distribution Name:

NRCDPLA KING 0034

Addressee:

Shirley Rohrer x7-4152 (NMSS/FC) room 566 Date Sent:

08/04/87 Time Sent:

14:33 Message:

Shirl, ready for Mr. Cunningham's signature