ML20135F921

Ack Receipt of 970225 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 15000004/96-17

ML20135F921
Person / Time
Site:	15000004
Issue date:	03/11/1997
From:	Linda Howell NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Ballard R CONSTRUCTION TESTING ENGINEERS
References
EA-97-037, EA-97-37, NUDOCS 9703170145
Download: ML20135F921 (3)

See also: IR 015000004/1996017

Text

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March 11, 1997

EA 97 037

Mr. Rodney D. Ballard, Vice President

Construction Testing & Engineering, Inc.

2414 Vineyard Ave, Suite G

Escondido, California 92029

SUBJECT: RESPONSE TO NOTICE OF VIOLATION

(NRC INSPECTION REPORT 150-00004/96-17) ,

Dear Mr. Ballard:

Thank you for your letter dated February 25,1997,in response to our letter and Notice of

Violation dated February 11,1997. We have reviewed your reply and find it responsive to

the concerns raised in our Notice of Violation. We will review the implementation of your

corrective actions during a future inspection to determine that full compliance has been

achieved and will be maintained.  ;

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We will respond to the information provided during the predecisional enforcement

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conference held on February 26,1997, regarding the apparent violations described in the '

subject inspection report by separate correspondence.

Sincerely,

.

Linda L. Howell, Chief

Nuclear Materials inspection

and Fuel Cycle / Decommissioning Branch

Docket: 150-00004

License: California 5309-80

cc: California Radiation Control Program Director

9703170145 970311

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ONSTRUCTION DTING & ENGINEERING,INC.

I.f SAN DIEGO, CA RIVERSIDE, CA . VFNTURA, CA . MODESTo,CA IANCAfrER,CA IAS VEGAS,NV SEATTIA WA

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February 25,1997 h'h,Ik

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UNITED STATES NUCLEAR -

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REGULATORY COMMISSION .

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ATT.: Document Control Desk '

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Washington, DC 20555 '

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SUBJECT: Reply to Notice of Violation ,

Docket No: 150-800004

License W. CA 5309-80

To Whom It May Concern:

The following is Construction Testing and Engineering's response to the noted violations during an

NRC Inspection conducted on December 11,1996.

The violation noted consists of, as CTE understands it, the requirement to provide Hazmat Training ,

to all employees who transport licensed material on public highways or who deliver licensed l

material in accordance with 49CFR 172. l

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1. Reason for the Violation. i

Our response to the violation is that CTE was not in compliance with the requirements and j

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were unaware of the extensive Hazmat training that was required for CTE personnel. All

CTE personnel who have transported licensed material have taken an 8-hour course on

nuclear gauge safety which included safety instruction, labeling and notification

requirements when transporting the licensed materials.

213. Corrective Stens That Have Been Taken. l

Upon notification of the violation CTE's Radiation Safety Officer researched the

requirements and based on his review the following is required to comply with 49CFR172:

Each Hazmat Employer must:

. Train and test; l

. Certify: and

. Develop and retain records of current training for each Hazmat employee.  !

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GEOTECIINICAL AND CONSTRUCTION ENGINEERING TESTING AND INSPECTION

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U.S. Nuclear Regulatory Commission

Subject: Reply to Notice of Violation

February,25,1997 Page 2

Hazmat Training must include:

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General Awareness / Familiarization

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Function specific

. Safety

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Driver Training

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Frequency of Training:

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Initial training must be completed within 90 days.

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Retraining every two years.

To fulfill the requirements as set forth above, CTE has ordered and obtained a copy of l

" Awareness for Initial Response to Hazardous Materials" from the Department of

Transportation. These materials will satisfy the general awareness / familiarization

requirements. To fulfill the remainder of the requirements, the Radiation Safety Officer, I

(Mr. Ramzi Jamma) will attend a Department of Transportation course " Instruction Training l

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Hazardous Materials Transportation" The next course is scheduled for May 20-22,1997.

At the completion of the course Mr. Jamma will be given the DOT Hazardous Materials i

Transportation Training Modules. These modules will be used by Mr. Jamma to train all

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other employees. i

4. Reouired Period to Brine Firm into Comoliance.

CTE will begin training immediately by requiring all affected employees to view DOT's

" Awareness for Initial Response to Hazardous Materials" and will conduct training to fulfill l

the function specific, safety and driver training requirements. Each employee will be tested l

and certified within a period of 60 days. l

In addition. upon Mr. Jamma's completion of the DOT training in May all affected l

employees will be required to view and be tested on the DOT Hazardous Materials

Transportation Training Modules. It is expected that this additional training will be

completed 30 days after completion of the course.

Respectfully submitted,

CONSTRUCTION TESTING & ENGINEERING, INC.

Acknowledged by:

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Ramzi)arnm,a

Radiation Safety Officer 4<-

Rod Bahard

Vice President

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U.S. Nuclear Regulatory Commission

Subject: Reply to Notice ~of Violation

February,25,1997 Page 3 -

'cc: Regional Administration Region IV

611 Ryan Plaza Drive, Suite 400

Arlington, TX 76011

Region IV Walnut Creek Field Office

1450 Maria Lane

Walnut Creek, CA 94596 -

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