ML20199K004

Informs of an Investigation Conducted by NRC OI on 980508. Investigation Determined That Licensee Willfully Possessed & Used Moisture Gauges Containing Byproduct Matl in Area Under NRC Jurisduction Without Specific or Genenal License

ML20199K004
Person / Time
Site:	15000019
Issue date:	12/30/1998
From:	Reyes L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Darrell Todd PUERTO RICO, COMMONWEALTH OF
References
IA-98-066, IA-98-66, NUDOCS 9901260307
Download: ML20199K004 (10)

Text

a &

j e* W Og'c UNITED STATES NUCLEAR REGULATORY COMMISSION p ,,

o REGION 11 3( i y y ATLANTA FEDERAL CENTER g I 4[e t 61 FoRsYTH STREET. sW. sulTE 23T85

>Qg ATLANTA. GEORGIA 30303-3415

• • • • • December 30, 1998 IA 98-066 1

Mr. Dale Todd, President Roof Systems Design,Inc.

Monte Claro il i MK-1, Plaza 44 Bayamon, Puerto Rico 00961

SUBJECT:

CONFIRMATION OF AGREEMENT

Dear Mr. Todd:

l This is in reference to an investigation conducted by the Nuclear Regulatory Commission's l (NRC) Office of investigations (01) on May 8,1998. The Ol investigation determined that you and Roof Systems Design, Inc., willfully possessed and used moisture gauges containing byproduct rnaterial, in an area under NRC jurisdiction, without a specific or general license issued by the NRC. Specifically, on May 8,1998, you were found to be in unauthorized possession of four Troxler Model Number 3216 moisture gauges, each containing l approximately 40 millicuries of Americium-241, in violation of 10 CFR 30.3 and 150.20. In I addition, based on your statements to 01, you used the gauges at various job sites in Puerto Rico, including Searle Pharmaceutical in 1992 and Ft. Buchanan and Intel in Las Piedras in September 1997 without a specific or generallicense issued by the NRC. You acknowledged ,

to Ol that you were aware that the jobs in Puerto Rico required an NRC license and that you did i not obtain one. Deliberately failing to comply with NRC regulatory requirements is a violation of l 10 CFR 30.10. Enclosure 1 is a copy of the synopsis of the 01 investigation.

On May 12,1998, you were sent a Confirmation of Action Letter which confirmed your agreement to transfer the moisture gauges to an authorized recipient by June 7,1998. By letter to Mr. Mark Lesser of the NRC, dated June 11,1998, you stated that you had transferred i the gauges to an authorized recipient.

l As Mr. Lesser discussed with you on December 4,1998, the NRC is considering issuing you and Roof Systems Design, Inc. an Order, as a result of the investigation findings. Enclosure 2 is a document containing the terms we propose to incorporate into the Order and issue. The terms reflect the agency's intent to prohibit you and Roof Systems Design, Inc. from either engaging in licensed activities or supervising or directing licensed activities within the l jurisdiction of the NRC for a period of one year. These terms are being proposed as a result of 1 your willful violation of NRC regulations governing the use and possession of licensed materials.

In consenting to the proposed terms of the Order, you are waiving your right and Roof Systems Design, Inc.'s right to request a hearing on any part of the Order. In addition, should you sign l the Acknowledgment (Enclosure 3), you are indicating that you agree to such commitments and are consenting to the issuance of the Confirmatory Order. If you agree, please sign and return i ,

the Acknowledgment no later than five business days from the date of this letter to me at the I

,n n - - - ,

9901260307 981230 PDR STPRG ESGPR PDR , ,

dGG1

Roof Systems Design, Inc. Atlanta Federal Center,23T85,61 Forsyth Street, S.W., Atlanta, GA 30303-3415. You may also respond initially by tacsimile at (404) 562-4766. After receiving your written consent, the NRC will issue the Order which will be followed by issuance of a press release approximately 24-hours following your receipt of the Order. You should also note that information regarding this Order will be published semi-annually in a publicly available document that lists NRC enforcement actions.

Copies of the applicable regulations are enclosed. Questions concerning this letter should be addressed to Mr. Douglas Collins at 404-562-4700.

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter will be placed in the NRC Public Document Room.

Sincerely, Luis A. Reyes Regional Administrator Docket No. 150-00019 Maryland License No. MD-33-095-01 (expired)

Enclosures:

1. Synopsis to 01 Report No. 2 98-015

2. Proposed Order Provisions

3. Acknowledgment

4. 10 CFR 30.3

5. 10 CFR 30.10

6. 10 CFR 150.20 cc w/encis:

Commonwealth of Puerto Rico State of Maryland

l SYNOPSIS The Office of Investigations (01), U.S. Nuclear Regulatory Commission (NRC),

Region ll, initiated this investigatio'1 on May 8,1998, to determine whether Roof Systems Design, Inc. (RSD), possessed and used moisture gauges containing byproduct material, in an area under NRC jurisdiction, without a specific or general license issued by the NRC.

Based upon evidence developed during this investigation,01 determined RSD willfully possessed and used Troxler moisture gauges, containing byproduct material, in the

, Commonwealth of Puerto Rico without a specific or generallicense issued by the NRC.

Additionally, O1 determined RSD possessed and used Troxler moisture gauges, containing byproduct material, in the non-agreement states of New Jersey, Pennsylvania, and Virginia without a specific or general license issued by the NRC.

However, the investigation did not determine RSD willfully operated in the non-agreement states of New Jersey, Pennsylvania, and Virginia :!hout a specific or generallicense issued by the NRC.

s.

r

- 410T FOR PUBL-lG-DECLOSURE W!THOUT ,^ PPROVAL CI- Approved by OI I ELO CII'OC OlnCOTOn, Orr!OC OI!NVCGT!GATIONS, REGION !iDirector on 12/7/98 Case No. 2-1998-015 1 Enclosure 1

PROPOSED PROVISIONS

1. For a period of one (1) year from the date of this Confirmatory Order, Mr. Dale Todd and RSDI are prohibited from engaging in or exercising control over individuals engaged in l

NRC-licensed activities. NRC-licensed activities are those activities which require a l l

specific or general license issued by the NRC including, but not limited to, those l activities of Agreement State licensees conducted pursuant to the authority granted by 10 CFR 150.20. This prohibition includes, but is not limited to: (1) using licensed j materials or conducting licensed activities in any capacity within the jurisdiction of the NRC; and (2) supervising or directing any licensed activities conducted within the jurisdiction of the NRC. l l

2. At least five (5) days prior to the first time that Mr. Dale Todd and/or RSDI engage in or 1 l

l exercise control over, NRC licensed activities during a period of five (5) years following the one year prohibition stated in Section IV.1 above, the Director, Office of I l Enforcement, U. S. Nuclear Regulatory Commission, Washington, DC 20555, shall be l notified in writing of the name, address, and telephone number of the NRC or l

Agreement State licensee and the location where the licensed activities will be performed. The notice shall be accompanied by a statement, under oath or affirmation, that Mr. Dale Todd and/or RSDI understand the applicable NRC requirements and are j committed to compliance with NRC requirements. Mr. Dale Todd and/or RSDI also l

! should provide a basis as to why the Commission should have confidence that Mr. Dale Todd and/or RSDI will now comply with applicable NRC requirements.

Enclosure 2

ACKNOWLEDGMENT I have read the proposed provisions which provide that Dale Todd and Roof Systems Design, Inc. will be prohibited from engaging in or supervising the conduct of licensed activities in areas of NRC jurisdiction for one year. Furthermore, Dale Todd and Roof Systems Design, Inc. will be required to notify the NRC of Dale Todd's and/or Roof Systems Design, Inc.'s intent to either engage in or supervise the conduct of licensed activities in areas of NRC jurisdiction for a five I year period following the one year period of prohibition. I understand the proposed provisions and consent to the issuance of an Order confirming these provisions. I further agree to waive my right and Roof Systems Design Inc.'s right to have a hearing on such an Order.

l l

Dale Todd i

l l

l Enclosure 3 l

l

PART 30 o RULES OF GENERAL APPLICABILITY TO DOMESTIC LICENSING- 3M 8 30.3 ActMties requiring license.

" Dentist" means an individual Except for Dersons exempt as pro-licensed by a State or Territory of the Medical use means the intentional I 3 vided in this part and Part 150 of this United States. the District of Columbia. internal or external administration of

• chapter, no person shall manufacture, or the Commonwealth of Puerto Rico to 0; t: byproduct material or the radiation

[ produce. transfer.. receive, acquire, practice dentistry. ,

y therefrom to patients or human research

, own, possess, or use byproduct materi- o Department"and " Depart. 6 subjects under the supervision of an o al except as authorised in a specific or general license issued pursuant to the ment of Energy" means the Depart- S authorized user as defined in 10 CFR ment of Energy established by the De- I  !

_ regulations in this chapter. partment of Energy Organization Act L Part 35' -.

. (Pub. L 95-91. 91 Stat. 565. 42 U.S.C. -

l 8 30.4 Definitions. . 7101 et seq.) to the extent that the De- " Microcurie" means that partment, or its duly authorized repre- s. mount of radioactive material which "Act" means the Atomic Energy sentatives, exercises functions former- disintegrates at the rate of 37 thou-Act cf 1954 (88 Stat. 919). Including ly vested in the U.S. Atomic Energy sand atoms per second; 8 any amendments thereto: Comminion. Its Chairman, members.

3 " Agreement State" means any -M1111 curie" means that amount officers and components and trans- of radioactive material which ciisinte-

' E state with which the Atomic Energy ferred to the U.S. Energy Research grates at the rate of 37 million atoms g Commission or the Nuclear Regula- and Development Administration and per second; tory Commission has entered into an to the Administrator thereof pursuant " Person" means: (1) Any individ-cffectiv2 agreement under subsection to sections 104 (b). (c) and (d) of the ual, corporation, partnership. firm, as-274b. gf the Act. **Non-agreement Energy Reorganization Act of 1974 sociation, trust, estate, public or prl-Ctate" means any other State; (Pub. L 93-438. 88 Stat.1233 at 1237 vate institution, group. Government <

"Al:rt" means eventa may occur. are 42 U.S.C. 5814) and retransferred to agency other than the Commission or l Im progress. or have occurnd that could the Secretary of Energy pursuant to the Department. except that the De-I lead 13 a release of radioactive material section soltas of the Department of partment shall be considered a person b t thtt the release is not expected to - Energy Organization Act (Pub. L 95- within the meaning of the regulations r: quire e response by offsite response 8 91. 91 Stat. 565 at 577-578. 42 U.S.C. in this part to the extent that its fa.

orginizations to protect persons offsite.  ! 7151). g cilities and activities are subject to the "Eyproduct material" means E " Effective dose equivalent" rneens the  ? licensing and related regulatory au.

radioactive material (except specia] 3 sum of the products of the dose - thority ommissi ursuan to the, g nuclear material) yielded in or made equivalent to the orgcn or tissue and the , .

radioactive by exposure to the radl. weighting factors applicable to each of m tion Act of 19'l4 (88 Stat.1244). ' any c.tlon incident to the process of pro. the body organs or tissues that are State or any political subdivision of or ducing er utilizing special nuclear ms. any political entity within a State, any irradiated. Weighting actors are: 0 25 for terial; .., fore'gn government or nation or any

. . , gonads. 0.15 for breast. 0.12 for red bone pohtical subdivision of any such gov-

" Commencement of construc- marrow. 0.12 for lungs. 0.03 for thyroid. ernment or nation, or other entity; tlin" means any clearing of land, exca-vttiin, or other substantial action that 0.03 for bone surface. and 0.06 for each and (2) any legal successor. represent- -

l wIuld cdversely affect the natural en. of the other five organs receivirig the ative, agent, or agency of the forego- i highest dose equiv61ent. ing; vir nmint of a site but does not in. -

Physician. means a rnedjcal cludi changes desirable for the tempo- " Government agency" means any rary use of the land for public recre- executive department, commiulon, in. doctor or doctor of osteopathy icense Etlinal uses, necessary borings to de- dependent establishment. corporation, by a State or Territory of the United termine site characteristics or other wholly or partly owned by the United States, the Distnet of Columbia, or the prec:nstruction monitoring t.o estab. States of America which is an instru- Commonwealth of Puerto Rico to j lish background information related to snentality of the United States, or any presenbe drugs in the practice of l the suitability of a site or to the pro- board, bureau. ci! vision service, offlee. medicine: '

tecti:n of environmental values. officer, authority, administration, or "Podiatnst" means an individual "CImmission" means the Nuclear ther establishment in the executive licensed by a State or Terntory of the Regulatory Commtulon and its duly branch of the Government; United States, the District of Columbia.

~~

cuthIrized representatives; or the Commonwealth of Puerto Rico to

" Curie" means that amount of ra. f- practice podiatry. j i dioactive material which disintesTates l -

l Ot th3 rate of 37 billion atoms per n .' License", except where other-l second;

- E wise specified means a license for by-E product material issued pursuant to 'The Department factitues a.nd activities

- as the regulations in this part and Parts identified in secuon 202 are:

,,) Defommiss/On means to remove a

• 31 through 36 and 39 of this chapter

• m Demonstrauen Lauld W tal Fast l Dreeder reactors when operated as part of facility or site safely from service and L_ the pown ununuon f aculues of an electric utuity system. or when operated in any reduce residual radioactivity to a level other manner for the purpose ci demon-l 5l that p rmits- strauna the suitabuity for commercial ap-Io pucauon of such a reactor.

l 8 . (1mlease of the property for cm) other demonstrauon nuclear reactors, l:c unrestricted use and termination of the except those in existence on January 19.

l "- lic1nst; or asis. when operated as part of the power

'U eccermuon fact!!Oes of an electric utt11ty (2) Release of the propeny under system. or when operated in any other restricted Conditions and termination of manner for the purpose of demonstrattne thejjCInse, the suitabuity for commercial appucauon of

- such a reactor.

(3) Esc 1110es used primarily for the recetpt and storage of high-level radioactive wastes resulting from 16 censed activ10eL H) Retrievable Surface Storage Fac111ues and other faculues authorized for the ex.

press purpose of subsequent lone term stor-age of hish-level radion.ctive waste generst.

ed by the DepaJtment, whjCh are not used for. or are part of, research and develop-j ment activides.

i r

l July 31,1997 30-2 Enclo$ure 4

^

3d.10(:) 30.10(c)

PART 30 e RULES OF GENERAL APPLICABILITY TO DOMESTIC LICENSING. . .

I 30.10 Deliberate misconduct. ,

$> (a) Any licensee, certificate of registration holder, applicant for a license or certificate of registration, empl;yee of a licensee, certificate of .

registration holder or applicant; or any contractor (inclsding a supplier or -

consultant), subcontractor, employee of a contractor or subcontractor of any licensee or certificate of registration h:Ider or applicant for a license or

' certificate of registration, who kn:wingly provides to any licensee, c pplicant, certificate holder, contractor, tr subcontractor, any components, equipment, materials, or other goods or services that relate to a licensee's, conificate holder's or applicant's activiti:s in this part, may not:

(1) Engage in deliberate misconduct that causes or would have caused, if not detected, a licensee, certificate of '

registration holder, or applicant to be in vi lation of any rule, regulation, or l cr: der; or any term, condition, or

" limit: tion of any license issued by the E Commission;or 2 (2) Deliberately submit to the NRC, a licensee, cenificate of registration h lder, an applicant, or a licensee's, certificate holder's or applicant's, contractor or subcontractor, information that the person submitting the' information knows to be incomplete or inaccurate in some respect material to the NRC.

(b) A person who violates paragraph (1)(1) or (a)(2) of this section may be subject to enforcement action in acc:rdance with the procedures in 20 CFR pan 2, subpan B.

(c) For the purposes of paragraph

(:)(1) cf this section, deliberate

. misconduct by a personTneans an

- intenti:nal act or omission that the person knows:

(1) Wruld cause a licensee, certificate cf registration holder or applicant to be in viclation of any rule, regulation, or erd:r: or any term, condition, or limitati:n, of any !! cense issued by the Commission; or (2) Constitutes a violation of a requirement, procedure, instruction.

contract, purchase order, or policy of a .

licensee, certificate of registration h:Ider, applicant, contractor, or subcontractor.

150.19(r) 15 0.2(-

PART 150 o EXEMPTIONS AND CONTINUED REGULATORY AUTHORITY ~

~

[Q 150.19 Submission to Commission of RECIPROCITY (1) Except as specified in paragraph

tritium reports. (c) of this section, shall, at least 3 days S! _ before engaging in each activit for the

$150.20 Recognition of Agreement State t mena nda a *

(a) ( Reservea ) ,

g R F m f,,, Report of Propose Activities in Non-a) Provided that the provisions of paragraph (b) of this section have been Agreement States, 4 copies ofits Agreement State specific license, and met, any person who holds a specific the appropriate fee as prescribed in g license from an Agreement State, where $170.31 cf this chapter with the y the licenses maintains an office for Regional Administrator of the U.S.

E (b) [reservedj directing the licensed activity and ulatory Commission g g retaining radiation safety records,is Regional O Reffice listed on th Nuclear

- granted a generallicense to conductthe 241 and in Appendix D of Part 20 of th E same activity in- ion in which the ement Sta es chapter Agreementfor thet Rekat issued the li

_ @ hNon .e y p. rol State (c) Except as specified in paragraph (d) ju sdiction within Agreement States: 1s t If a submittal cannot e filet an 3 of this section, each person who, pur, (il ) Offshore watem under reciprocity, ecause of an suant to an Agreement State license, is emergency or other reason, the Regione (2) The provisions of paragraph (a)(1) authorized to possess tritium shall report Administrator may waive the 3-day tirr of this section do not apply if the promptly to the appropriate NRC Re- specific Agreement State license limits uirement provided the licensee:

gional Office as shown in Appendix D of the authorized activity to a specific repi)Inf nns the Region by telephone Part 20 of this chapter by telephone and installation or location. a m le C 1oa er -

, g ,

telegraph, mailgram, or facsimile any m' information submitted on the initial cident in which an attempt has beerr -

@ NRC Form 241; made or is believed to have been made to $> (b) Notwithstanding any provision to -

(ii) Receives oral or written commit a theft or unlawful diversion of the contrary in any specific license E authorization for the activity from the more than 10 curies of such material at issued by an Agreement State to a g Re n:and any one time or 100 curies of such Person engaging in activities in a non- in a t' RC mM4 matenal in any one calendar year. The mitial report shall be followed within a k8j',e y a{a xchtsive copies of the Agreement State license, Agreement State, or in offshore waters and the fee syment.

, period of fifteen (15) days by a written under the general licenses provided in (2) Shall i e an amended NRC Form report submitted to the appropriate NRC this section, the general licenses 241 or letter and the appropriate fee as

( Regional Office which sets forth the provided in this section are subject to $

or Ptjer details of the incident and its conse- all the provisions of the Act,now or Qcn ona dm request opproval for changes in work quences. Copies of such written report hereafter in effect, and to all applicable locations, radioactive material, or work shall be sent to the Director. Office of g rules, regulations, and orders of the activities different from the informatf or Nuclear Material Safety and Safeguards g Cmnmission including the provisions of contained on the initial NRC Form 241 U.S. Nuclear Regu u a.SS30.14(d),30.34,30.41, 30.7 (a) through (f),30.9,30.10,-

and 30.51 to (3) Shall not, in any non-Agreement latory Commission, Washington, D.C. U 30.63, inclusive, of part 30 of this State,in an area of exclusive Federal 20555. Subsequent to the submission of jurisdiction within an Agreement State-chapter: $$ 40.7 (a) through (f),40.9, or in offshore waters, transfer or dispos the written report required by this para- 40.10,40.41,40.51,40.61,40.63 - of radioactive material possessed or graoh, each person subject to the pro, inclusive. 40.71 and 40.81 of part 40 of used under the generallicenses visions of this paragraph shall promptly this chapter; $$ 70.7 (a) through (f),70.9' provided in this section, except by inform the appropriate NRC Regional '

Office by means of a written report of h u iv[ 7d60 70 62 inc u v ,and ""f)'Sp$ca$yifc

(

P se[by the to the provisions of 10 CFR parts 19,20 Commission to receive this material; or any substantive additional information, and 71 and subparts C through H of part (ii) Exempt from the requirements for which becomes available to such person, 34, $$ 39.15 and 39.31 through 39.77,

• a license for matet al under $ 30.14 of concerning an attempted or apparent inclusive, of part 39 of this chapter. In this chapter.

theft or unlawful diversion of tritium, addition, any person engaging in (4) Shall not, under the general activities in non-Agreement States, in license concerning activities in non-areas of exclusive Federal jurisdiction . Agreement States or in areas of within Agreement States, or,in offshore exclusive Federal jurisdiction within i (d) The reports described in this sec- waters under the general licenses . Agreement States, possess or use l tion are not required for tritium pos- Provided in this section: radioactive materials, or engage in the I E sessed pursuant to a generallicense issued _ activities authorized in paragraph (a) of E pursuant to regulations of an Agreement this section, for more than 180 days in i State equivalent to Part 31 of this chapter

" or for tritium in spent fuel.

I i

150-7 May 30,1997 l Enclosure 6

.150.20(b) 150.31(b)

PART 150

• EXEMPTIONS AND CONTINUED REGULATORY AUTHORITY .

ENFORCEMENT Requiremonia f /

any calindar year, except that the t,,i50.31,,, ,,,,i,,gn ., e,y,,,,or

,, A,e.r**

,,,o ment ;

gen:ral license in paragraph (a) of this -

(a) Prior to November a.19et.in the section concerning activities in offshore i sso.3o woistena, licensing and regulation of byproduct wat rs authorizes that person to possess material, as defined in 1150.3(c)(2) of or use radioactive materials, or engage (a) The Commission may obtain an which results injuncti n r ther court order this in thePart, or ofofany production suchactivitbyproduct in thi cctivities authorized for an prevent a vi lati n f the provisions unlimit:d period of time. material.an Agreement State shall i 0 i require compliance with the j

h)The Atomic Energy Act of 1954. as requirements in Appendix A of10 CFR amended:

l g conditions (5) Shall W % Chapw M e e m l of thecomply with allterms specific license issued and (2) Title 11 of the Energy extent practicable.

I g by an Agreement State except such terms Reorganization Act of1974, as amended: (b) After November a,1est.in the or licensing and regulation of byproduct l g or conditions as are contrary to the (3) A regulat. ion or order issued requirements of this section. meterial as defined in $ 150.3(c)(2) of pursuant to those Acts. this Part. or of any activity which results (b) The Commission may obta.ma in the production of such byproduct (c) A person engaging in activities in , court order for the payment of a civil material, an Agreement State shall offsh:re waters under the general g penalty imposed under section 234 of the require:

l liccnse provided for that purpose in S Atomic Energy Act: - (1) Compliance with requirements in paragraph (a) of this section need not g (1) For violations of- g Appendix A of to CFR 40 of this Chapter fil) an NRC Form 241 with the ,, (i) Sections 53.57. 62.63.81. 82.101. $ established by the Commission C:mmission under paragraph (b)(1) of

• 103,104.107. or 109 of the Atomic E pertaining to ownership of such this section provided that: Energy Act of1954, as amended: e byproduct material and disposal sites (ii) Section 206 of the Energy for such material: and Reorganization Act: (2) Compliance with standards which (iii) Any rule, regulation. or order shall be adopted by the Agreement State (1) At least 3 days before engar.mg tn issued pursuant to the sections specified for the protection of the public beelth, each such activity the person notifies in paragraph (b)(1)(i) of this section: safety, and the environment from the Agrecreent State that issued the (iv) Any term, condition or limitation hatards associated with such material specific license about the activity. of any license issued under the sections which are equivalent, to the extent including in the notification (1) a specified in paragraph (b)(1)(i) of this practicable, or more stringent then.

discription of the activity. (ii) the section. standards in Appendix A of to CFR 40 i

i (2) For any violation for which a of this Chapter adopted and enforced by 1: cation. (iii) the dates scheduled. (iv) a the Commission for the same purposes, list ci the sealed sources. or devices license may be revoked under section 186 of the Atomic Energy Act of1954, as including requirements and standards cintuning sealed sources, which will be en p mu se ed

' y possIssId.used. installed. serviced.or -

amended. g sb e

, g

t

sted. and (v) a description of the type the Environmental Protection Agency g and quintity of radioactive material pursuant to the Uranium Mill Tailing

. contained in each sealed source of Radiation Control Act of 1978: and

• dIvice: and (2)The Agreement State (3) Compliance with procedusse .

that issued the specific license is listed which:

l in paragraph (d) of this section as (1)In the case of licenses. under State having entered into an agreement to law include:

per'ctm inspections and other functions (A) An opportunity, after public for th2 Commission, notice, for wntten comments and a public hearing with a transcript:

(d)The foDowing Agreernent State has ent; red into an agreement to perform insp;ctaens and other functions for the Ccmmission: Louisiana.

{ 150.21 Transportation of special nucl:ar material by aircraft.

g Except as specifically spproved by the 8 Cammission no shipment of special nu.

E clear material in excess of 20 grams or 20 i g curies whichever is less of plutonium or uranium-233 shall be made by a licensee of an Agreement State in passenger air-craf t.

~

l May 30,1997 (reset) 150-8 l

Roof Systems Design,Inc.

Distribution w/ enclosures:

PUBLIC Ril Docket Files, DNMS WTravers, EDO LChandler, OGC JGoldberg, OGC DCool, NMSS EJulian, SECY BKeeling, CA Enforcement Coordinators Rl, Rlli, RIV JLieberman, OE OE:EA File (BSummers) (2 letterhead)

Vbeaston, OE EHayden, OPA GCaputo, Of TMartin, AEOD l HBell, OlG CEvans, Ril ABoland, Ril KClark, Ril

\ DCollins, Rll

\ MLesser, Ril

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!, NAME D.Colg% A. Bdlagd, C. Evans y L Reyes J. Liebgan

{ DATE

.AV /98 y J2/p/98 12/ /98 QF ~ /98 12/ /98

LOPY? ( YES' NO /YES / NO (ES NO YEs NO LYES') NO YEs NO OFFICIAL RECORD COPY D4bOdlWlENT NAME

K\1980 PEN.ENF\98538RsD.DIR\PRVsil46.Ok i

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