IR 07100201/1980001
| ML18333A298 | |
| Person / Time | |
|---|---|
| Site: | 03028571, 07100201 |
| Issue date: | 11/28/2018 |
| From: | Aaron Mccraw NRC/RGN-III |
| To: | Cruickshank J Prein & Newhof |
| Harvey E | |
| References | |
| IR 2018001 | |
| Download: ML18333A298 (4) | |
Text
November 28, 2018
SUBJECT:
NRC SPECIAL REPORT NO. 03028571/2018001(DNMS) AND NOTICE OF VIOLATION - PREIN & NEWHOF
Dear Mr. Cruickshank:
On August 20, 2018, an inspector from the U.S. Nuclear Regulatory Commission (NRC)
conducted a special inspection at your facilities in Grand Rapids and Cadillac, Michigan, with continued in-office review through November 13, 2018. The purpose of the inspection was to assess the effectiveness of corrective actions that were implemented as a result of an escalated enforcement violation identified during the previous routine inspection. The in-office review included an evaluation of the license amendment request submitted to the NRC to add a new location of use to your NRC license. Mr. Ed Harvey of my staff conducted a final exit meeting by telephone with you on November 15, 2018 to discuss the inspection findings.
During this inspection, the NRC staff examined activities conducted under your license related to public health and safety. Additionally, the staff examined your compliance with the Commissions rules and regulations as well as the conditions of your license. Within these areas, the inspection consisted of selected examination of procedures and representative records, observations of activities, and interviews with personnel.
Based on the results of this inspection, the NRC has determined that one Severity Level IV violation of NRC requirements occurred. The violation was evaluated in accordance with the NRC Enforcement Policy. The current Enforcement Policy is included on the NRCs website at http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. The violation concerned the licensees failure to limit the possession of licensed material to those locations listed on the license, as required by Title 10 of the Code of Federal Regulations (CFR) 30.34(c) and License Condition 10 of NRC License No. 21-18663-02, Amendment No. 11. The violation is cited in the enclosed Notice of Violation (Notice). The NRC is citing the violation in the enclosed Notice because the inspector identified violation.
The inspector determined that the root cause of the violation was the licensees misunderstanding that licensed material could be moved prior to receiving NRC approval listing the new location of use on the license. As corrective action to restore compliance, the licensee filed for a license amendment on August 22, 2018, to have the new location of use listed on their NRC license. The amendment request was approved on November 8, 2018. As corrective action to prevent recurrence, the licensees Radiation Safety Officer informed licensee management that it is necessary to submit an amendment request to the NRC during the early stages of acquiring a new facility if portable gauges are to be stored there and that portable gauges may not be stored at any new permanent storage facility until it is approved on their NRC license.
The NRC has concluded that information regarding the reason for the violation, the corrective actions taken and planned to correct the violation and prevent recurrence, and the date when full compliance will be achieved is already adequately addressed on the docket in this letter.
Therefore, you are not required to respond to this letter unless the description herein does not accurately reflect your corrective actions or your position. In that case, or if you choose to provide additional information, you should follow the instructions specified in the enclosed Notice.
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response, if you choose to provide one, will be made available electronically for public inspection in the NRCs Public Document Room or from the NRCs Agencywide Documents Access and Management System (ADAMS), accessible from the NRCs website at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be made publicly available without redaction.
Please feel free to contact Mr. Harvey if you have any questions regarding this inspection.
Mr. Harvey can be reached at 630-829-9819.
Sincerely,
/RA/
Aaron T. McCraw, Chief Materials Inspection Branch Division of Nuclear Materials Safety
Docket No. 030-28571 License No. 21-18663-02
Enclosure:
cc w/encl: State of Michigan