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STS Consultants Ltd.Consulting Engineers

3306 N. Green River RoadEvansville, Indiana 47715

(812) 476-30o7 January 20, 1986

Mr. D. G. Wiedeman, Chief -

Nuclear Materials Safety-Section IUnited States Nuclear Regulatory CommissionRegion II799 Roosevelt RoadGlen Ellyn, IL 60137

Dear Mr. Wieden3n:

This letter is in response to your letter dated December 27,1985 outlining the procedures we should follow with regardsto correcting the discrepancies of our Radiation SafetyProgram. Pursuant to the provisions of 10 CFP 2.201, we areenclosing our corrective action program for each violation.

If we can be of further service, please do not hesitate tocontact us.

Respectfully,

STS CONSULTANTS, LTD.

NV Cl % c[ s A431 chard N. BarrArea ManagerRadiation Safety Officer

Attachments (6)

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[ATTACHMENT

TO: D. G. Wiedeman, ChiefNuclear Regulatory Commission

FROM: STS Consultants, Ltd.

DATE: January 11, 1986

VIOLATION 1: Corrective Action and Results AchievedImmediately sent for leak test kits for allTroxler Machines. The Campbell Pacific andSoiltest Machines leak test kits have beensent for and will be used for leak testingimmediately after we receive them.

VIOLATION 2: Corrective Action and Results AchievedTransportation packages that had defective ormissing lock and hasps are in the process ofbeing repaired. Additionally, we are keepingan inventory of spare locks and hinges forimmediate disposition should the need arise.

VIOLATION 3: Corrective Action and Results AchievedImmediately after violation #3 was brought toour attention, a copy of our radiation safetyand emergency procedures program, shipping andtransportation papers and leak testcertificates have been included in eachTroxler transportation package.

VIOLATION 4: Corrective Action and ResultsWe have instituted a program whereby thelicensee will sign out for the machine and theRadiation Safety Officer will inspect themachine and transportation package on a weeklybasis. The sign out sheet will contain themachine Model No. the date signed out and thedate signed in and will be used for inventorypurposes. Any machine that leaves this officefor a period longer than 24 hours will bedocumented.

We expect full compliance will be achieved by March 1, 1986.Our weekly inspection of the machine and transportationpackages should enable us to detect any faulty items andimmediately proceed with the necessary corrective measures.

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Page 2ATTACHMENT

We hope we have taken the action necessary to correct theitems we have violated. If you have any questions regardingthis information please do not hesitate to contact us.

Respectfully,

STS Consultants, Ltd.

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Richard N. rrArea ManagerRadiation Safety Officer

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UNITED STATES/j>a at ?g NUCLEAR REf,ULATORY COMMISSION+

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CLEN ELLYN ILLINOIS 60137

'DEC 2 71985

STS Consultants, Ltd. License No. 13-18990-01ATTN: Mr. Richard Barr3306 North Greenriver RoadEvansville, IN 47715

Gentlemen:

This refers to the routine safety inspection conducted by Mr. M. A. Kunowskiof this office on December 10-18, 1985, of activities authorized by NRCByproduct Material License No. 13-18990-01 and to the telephone discussionwith you at the conclusion of the inspection on December 18, 1985.

The inspection was an examination of activities conducted under your licenseas they relate to radiation safety and to compliance with the Commission'srules and regulations and with the conditions of your license. The inspectionconsisted of a selective examination of procedures and representative records,observations, independent measurements, and interviews with personnel.

During this inspection, certain of your activities appeared to be in violationof NRC requirements, as specified in the enclosed Notice. A written responseis required.

The responses directed by this letter and the accompanying Notice are notsubject to the clearance procedures of the Office of Management and Budgetas required by the Paperwork Reduction Act of 1980, PL 96-511.

We will gladly discuss any questions you have concerning this inspection.

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D. G. Wiedeman, ChiefNuclear Materials Safety

Section 1

Enclosure: Notice of Violation

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NOTICE OF VIOLATION

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STS Consultants, Ltd. License No. 13-18990-01

As a result of the inspection conducted on December 10-18, 1985, and inaccordance with the " General Policy and Procedures for NRC EnforcementActions," 10 CFR Part 2, Appendix C (1985), the following violations wereidentified:

1. License Condition 13.A.(1) requires that sealed sources containingbyproduct material be tested for leakage and/or contamination atintervals not to exceed six months.

Contrary to the above, the interval between tests for leakage of yourCampbell Pacific Nuclear gauge and your four Troxler gauges exceeded sixmonths in 1985. In addition, leak tests of your Soiltest, Incorporatedgauge were not performed in 1984 and 1985.

This is a Severity Level IV violation (Supplement VI).

2. 10 CFR 71.5(a)(1)(i) requires each licensee who transports licensedmaterial outside of the confines of its plant to comply with theapplicable requirements of the Department of Transportation in49 CFR 173.

49 CFR 173.475(b) and (c) requires that before each shipment of anyradioactive materials package, the shipper shall ensure that thepackaging is in unimpaired physical condition and each closure deviceof the packaging is properly installed.

Contrary to the above, packages used for transport of radioactivematerial did not have all of the required closures. In addition, anotherpackage used for transport of radioactive material had a section ofplastic wall missing.

This is a Severity Level IV violation (Supplement V).

3. 10 CFR 71.5(a)(2)(iv) requires each licensee who transports licensedmaterial outside of the confines of its plant to comply with theapplicable requirements of the Department of Transportation in49 CFR 177.

49 CFR 177.817(a) requires that a carrier may not transport a hazardousmaterial unless it is accompanied by a shipping paper.

Contrary to the above, a licensee representative stated that a shippingpaper did not accompany hazardous (radioactive) material transportedoutside of the confines of your licensed facility.

This is a Severity Level IV violation (Supplement V).

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4. License Condition 17 requires that the licensee shall conduct a physicalinventory every six months to account for all licensed material receivedand possessed under the license.

Contrary to the above, a licensee representative stated that an inventoryhas never been conducted.

This is a Severity Level IV violation (Supplement VI).

Pursuant to the provisions of 10 CFR 2.201, you are required to submit to thisoffice within thirty days of the date of this Notice a written statement orexplanation in reply, including for each violation: (1) corrective actiontaken and the results achieved; (2) corrective action to be taken to avoidfurther violations; and (3) the date when full compliance will be achieved.Consideration may be given to extending your response time for good c use shown.

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DEC 2 71985 ,$a,.

Dated D.43.' Wiedeman, ChiefNuclear Materials Safety

Section 1

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CERTIFICATE OFRADIOACTIVITY WIPE / LEAK TEST.

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HEALTH PHYSICS AS$OCI ATES LTD. CONSULTANTS IN RADIATION SAFETYe

3304 COMMERC4AL AVENUE i NORTH 5 ROOK. IL 60o62 i PHONES. 312,564 333o i CMCAGO n 273-2525

Name STS Consultants Test Due, on/or Before

13-18890-01NRC License #Address 3306 N. Greenriver RoadExpiration Date 9/30/85

City Evansville State IN zip State License # 7019747715

|Expiration Date

Equipment Manufacturer Troxler Model No. " 3411-B Serial No. 8777

Cs 137 8.1 40-5998isotope Am 241/Be Curiage 40 mci Date 9/15/82 Source Serial No. 47-5113

Individual performing test I $M_ M,/ u f p,c;Dategm

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This test was performed in accordance with li P. Associates instructions included in this Lit, No. b6

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(To be filled out by licalth Physics Associates)

}1//6) f Db DATE SAMPLE PROCESSED |2 3/ k6DATE SAMPLE RECEIVED

TEST DATASample CPM (Net) Microcuries |

CPM -Counts Per Minuteh4 )gh DetectedI

$\ $2

3 M - Less than 0.0001

/lo0|_ D,/ DStandard 1 | 7._ L 1 ,

Q' {0l-{ C) {-k 6 * C07 Yt

CONCLUSION:

Results of this test do not indicate the presence of reportable removabl radioac:ivity. In accordance with prevail-ing regulations, this test should be performed again before b' / b !f> b

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CERTIFICATE OFK1DIOACTIVITY WIPE / LEAK TEST,

HEALTH PHYSICS ASSOCI ATES LTD. CONSULTANTS IN RADIATION SAFETYr

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3304 COMMERCIAL AVENUE i NORTHBROOK, R.,60062 i PHONES: 312/564-3330 i CteCAGO #: 2734525

Name STS Consultants Test Due, on/or Before

13-18890-01NRC License #Address 3306 N. Greenriver RoadExpiration Date 9/30/85

Evansville State IN ZjP 47715City State License # 70197

Expiration Date

Equipment Manufacturer Troxler Model No. 3411-B Serial No. 8712Cs 137 8.1 40-5998

Isotope Am 241/Be Curiage 40 mci Date 9/15/82 Source Serial No. 47-5113

Individual performir2g test. d%M Date \1/ \ \ /q3C,

6~ l iThis test was performed in accordance with H.P. Associates instructions included in this kit, No. _[ 8 7 E

1rkh(Signa ure o ividual l'erforming Test)

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(To be idled out by IIcalth Physics Associates)

DATE SAMPLE RECEIVED |k | 3 8[ DATE SAMPLE PROCESSED | Q g cg 8[

TEST DATASample CPM (Net) Microcuries j

CPM - Counts Per Minute1 N (\/\ Detected

2 N3 b M - Less than 0.0001

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, Standard -Y\ _ II #I 3\ 9 O l'A (

3 G~7 69 9 GCj j O.O I46CCONCLUSION:

Results of this test do not indicate the presence of reportable removable rad [oactivity. In accordance with prevail-ing regulations, this test should be performed again before b ll INb

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CERTIFICATE OF RAplOACTMTY H7PE/ LEAK TESTw

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HEALTH PHYSICS ASSOCI ATES LTD. CONSULTANTS IN RADIATION SAFETY ,

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3304 COMMERCIAL AVENUE i NORTHOROOK.14 Soo62 # PHONES: 312?564 3330 i CHICAGO # 273 2525

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Ntme STS Consultants Test Duc, on/or Before

13-18890-01NRC License #Address 3306 N. Greenriver Road

Expiration Date 9/30/8547715City Evansville State IN zip State License # 70197

Expiration Date

Equipment hianufacturer Troxler Model No. 3411-B serial No. 8329

Cs 137 8.1 474691Isotope Am 241/Be Curiage 40 Date 8/6/82 Source Serial No. 405569

DatIndividual performing test e 6, t, , y,%)gu e

& >This test was performed in accordance with II.P. Associates instructions included in this kit, No. 6 Er 7[

NA l~C2.M(Signature of Individual Performing Test)

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(To be filled out by licalth Physics Associates)

1 -DATE SAMPLE RECEIVED }Q f[ DATE SAMPLE PROCESSED }3h t9, 25

TEST DATASample CPM (Net) Microcuries ,

CPM - Counts Per Minute.

1 | Detected

2 N [O

3 N M - Less than 0.0001"

kM b M 01 C.Oci0 C 'Standard,

pl TM \ Q4 bel j O. l 3 c)CONCLUSION:Results of this test do not indicate the presence of reportable removable radioactivity. In accordance with prevail.

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CERTIFICATE OFRADIOACTIVITY WIPE / LEAK TESTw

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HEALTH PHYSICS ASSOCIATES LTD. CONSULTANTS IN RADIATION SAFETY'.

3304 COMMERC4AL AVENUE I NORTHSROOK. L Soo62 i PHONES: 312/564-3330

Name b k f$shh/)l h/b fj ,./fb Test Due, onfor Defore |$/ $M/MW88M I #f Mt//4 M, m ucense #

Address/ [OExpiration Date

State zs/ zip W99/SCity /t/iftflSV12/A State License a

,Expiration Date

gcf/[Equipment Manufacturer 8/2[8 Model No. jf // [/ Serial No.

+!dm Ce' CC 33%/[[f[ Source Serial No. d9,9 JR9cF/Isotope (q /g [py ge//CuriageJpmgc* Date 4

Individual performing test [g////M [[g # Date / /gj//[-

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This test was performed in accordance with H.P. Associates instructions included in this Lit No. l fGS

f//k//f| $N//(Signature of Individual Performing Test)

(To be filled out by IIcalth Physics Associates)

DATE SAMPLE RECEIVED k Q \_9 [( DATE SAMPLE PROCESSED }Q \3) [

TEST DATASample CPM (Net) Microcuries ,

! CPM - Counts Per MinuteI b D\ ; Detected

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3 Il\ M - Less than 0.0001#

Q$ bl|6$k O, c '| g ( |Standard

CONCLUSION:

Results of this test do not indicate the presence of reportable removable ,'adioa[tivity. In accordance with prevail-b lb iYbing reFulations, this test should be performed again before

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