ML18107A773
| ML18107A773 | |
| Person / Time | |
|---|---|
| Site: | 03039050 |
| Issue date: | 04/17/2018 |
| From: | Mark Shaffer Division of Nuclear Materials Safety IV |
| To: | Bauer J HSI Group |
| References | |
| EA-18-022 IR 2018001 | |
| Download: ML18107A773 (9) | |
See also: IR 05000201/1980001
Text
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
J. Bauer
1
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
Enclosures 1 and 3 contain Sensitive
Unclassified Non-Safeguards
Information. When separated from
Enclosures 1 and 3, this cover letter
and Enclosure 2 are decontrolled.
April 17, 2018
Jason Bauer
Radiation Safety Officer
HSI Group, Inc.
92-1164 Olani Street, Apartment 2
Kapolei, Hawaii 96707
SUBJECT: NRC INSPECTION REPORT 030-39050/2018-001 AND NOTICE OF VIOLATION
Dear Mr. Bauer:
This letter refers to the announced inspection conducted on February 8, 2018, at your facility in
Kapolei, Hawaii, and the unannounced inspection conducted on February 9, 2018, at a
temporary job site at the Island Energy Services refinery in Kapolei, Hawaii. The inspection
was an examination of activities conducted under your license as they relate to public health
and safety, to confirm compliance with the U.S. Nuclear Regulatory Commission (NRC) rules,
regulations, and with the conditions of your license. Within these areas, the inspection
consisted of a selected examination of procedures and representative records, observations of
activities, and interviews with personnel. The enclosed inspection report presents the results of
this inspection. The preliminary inspection findings were discussed with you on February 9,
2018. A final exit briefing was conducted telephonically with you and Mark Kazee, Manager of
Inspection Services, Mary Au, Manager of Hawaii Sites, and Bill Reynolds, Director of Refinery
Services, on April 10, 2018.
Based on the results of this inspection, apparent violations of NRC requirements were identified
and are being considered for escalated enforcement action in accordance with the NRC
Enforcement Policy. The current Enforcement Policy is included on the NRCs Web site at
http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. The apparent violations
involving NRC security requirements are discussed in the non-public Enclosure 3. The
circumstances surrounding these apparent violations, the significance of the issues, and the
need for lasting and effective corrective action were discussed with you on April 10, 2018.
Since the NRC has not made a final determination in this matter, a Notice of Violation is not
being issued for the apparent violations at this time. In addition, please be advised that the
number and characterization of apparent violations described in the Enclosure 3 may change as
a result of further NRC review.
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
J. Bauer
2
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Before the NRC makes its enforcement decision, we are providing you an opportunity to:
(1) respond to the apparent violations addressed in the inspection report within 30 days of the
date of this letter; or (2) request a predecisional enforcement conference (PEC). If a PEC is
held, the NRC will issue a meeting notice to announce the time and date of the conference;
however, the PEC will be closed to public observation since Security-Related Information will be
discussed. If you decide to participate in a PEC, please contact Mr. Michael C. Hay, Chief,
Materials Licensing and Inspection Branch, at 817-200-1455 within 10 days of the date of this
letter to notify the NRC of your intended response. A PEC should be held within 30 days of the
date of this letter.
If you choose to provide a written response, it should be clearly marked as a Response to an
Apparent Violation in NRC Inspection Report 030-39050/2018-001; EA-18-022 and should
include for each apparent violation: (1) the reason for the apparent violation or, if contested, the
basis for disputing the apparent violation; (2) the corrective steps that have been taken and the
results achieved; (3) the corrective steps that will be taken; and (4) the date when full
compliance will be achieved. Your response may reference or include previously docketed
correspondence, if the correspondence adequately addresses the required response.
Additionally, your response should be sent to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555 0001, with a copy to the Director, Division of
Nuclear Materials Safety, U.S. Nuclear Regulatory Commission, Region IV, 1600 E. Lamar
Blvd., Arlington, TX 76011-4511. If an adequate response is not received within the time
specified or an extension of time has not been granted by the NRC, the NRC will proceed with
its enforcement decision or schedule a PEC.
If you choose to request a PEC, the conference will afford you the opportunity to provide your
perspective on these matters and any other information that you believe the NRC should take
into consideration before making an enforcement decision. The decision to hold a PEC does
not mean that the NRC has determined that a violation has occurred or that enforcement action
will be taken. This conference would be conducted to obtain information to assist the NRC in
making an enforcement decision.
The topics discussed during the conference may include information to determine whether a
violation occurred, information to determine the significance of a violation, information related to
the identification of a violation, and information related to any corrective actions taken or
planned. In presenting your corrective actions, you should be aware that the promptness and
comprehensiveness of your actions will be considered in assessing any civil penalty for the
apparent violations. The guidance in NRC Information Notice 96-28, Suggested Guidance
Relating to Development and Implementation of Corrective Action, may be helpful. You can
find the Information Notice on the NRC Web site at
http://pbadupws.nrc.gov/docs/ML0612/ML061240509.pdf.
Additionally, based on the results of this inspection, the NRC has determined that one Severity
Level IV violation of NRC requirements occurred. This violation was evaluated in accordance
with the NRC Enforcement Policy. The violation involved NRC security requirements, and is
cited and described in the non-publicly available Notice of Violation (Notice) Enclosure 1. This
violation is being cited because it was identified by the NRC during the inspection.
The NRC has concluded that information regarding: (1) the reason for the violation; (2) the
corrective actions that have been taken and the results achieved; and (3) the date when full
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
J. Bauer
3
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compliance was achieved is already adequately addressed on the docket in NRC Inspection
Report 030-39050/2018-001, Enclosure 3. Therefore, you are not required to respond to the
Notice in Enclosure 1 unless the description therein 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 Agency Rules of Practice and Procedure,
a copy of this letter and Enclosure 2 will be made available electronically for public inspection in
the NRC Public Document Room or in the NRCs Agencywide Documents Access and
Management System (ADAMS), accessible from the NRC Web site at
http://www.nrc.gov/reading-rm/adams.html. However, Enclosures 1 and 3 contain
Security-Related Information in accordance with 10 CFR 2.390(d)(1) and there disclosure to
unauthorized individuals could present a security vulnerability. Therefore, Enclosures 1 and 3
will not be made available electronically for public inspection in the NRC Public Document
Room or from ADAMS.
If you choose to provide a response and Security-Related Information is necessary to provide
an acceptable response, please mark your entire response Security-Related Information -
Withhold from public disclosure under 10 CFR 2.390 in accordance with 10 CFR 2.390(b)(1)
and follow the instructions for withholding in 10 CFR 2.390(b)(1). In accordance with
10 CFR 2.390(b)(1)(ii), the NRC is waiving the affidavit requirements for your response.
If you have any questions concerning this matter, please contact Mr. Michael C. Hay of my staff
at 817-200-1455.
Sincerely,
/RA/
Mark R. Shaffer, Director
Division of Nuclear Materials Safety
Docket: 030-39050
License: 53-35428-01
Public Enclosure:
2. Health and Safety - NRC Inspection
Report 030-39050/2018-001
Non-Public Enclosures:
3. Security - NRC Inspection
Report 030-39050/2018-001
cc w/Enclosures:
L. Nakasone, State of Hawaii
Radiation Program Director
Ltr & Enclosures:
ADAMS:
Non-Publicly Available
Non-Sensitive
Keyword:
SUNSI Review By:
Yes No
Publicly Available
Sensitive _______MD 3.4 A.3
ADAMS ACCESSION NUMBER: ML18107A773
Cvr Ltr & Encl 2 Only:
ADAMS:
Non-Publicly Available
Non-Sensitive
Keyword:
SUNSI Review By:
Yes No
Publicly Available
Sensitive
OFFICE
DNMS:MLIB
C:MLIB
RIV:ACES
RC
D:DNMS
NAME
JEvonEhr
MCHay
GMVasquez
SKirkwood
MRShaffer
SIGNATURE
/RA/
/RA/
/RA/ JK for
/NLO / E
/RA/
DATE
3/29/18
4/11/18
4/13/18
4/16/18
04/1718
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Enclosure 2
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket:
030-39050
License:
53-35428-01
Report:
2018-001 (Health and Safety)
EA No:
Licensee:
HSI Group, Inc.
Location Inspected 91-505 Awakumoku Street, Bay K, Kapolei, HI
TJS at Island Energy Services Refinery,91-480 Malakole
Street, Kapolei HI
Inspection Dates:
February 8-9, 2018
Exit Meeting Date:
April 10, 2018
Inspector:
Jason E. vonEhr, Health Physicist
Materials Licensing and Inspection Branch
Division of Nuclear Materials Safety
Approved by:
Michael C. Hay, Chief
Materials Licensing and Inspection Branch
Division of Nuclear Materials Safety
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2
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EXECUTIVE SUMMARY
HSI Group, Inc.
NRC Inspection Report 030-39050/2018-001 (Health and Safety)
Program Overview
The HSI Group, Inc. is authorized under NRC Materials License Number 53-35428-01, to
possess and use byproduct material, including iridium-192, for industrial radiographic
operations. Licensed activities are authorized to be performed at the licensees facility located
in Hawaii, as well as at temporary job sites (TJS) in areas of NRC jurisdiction. The licensees
operations included the performance of industrial radiography at a TJS in Hawaii, an area of
NRC jurisdiction. (Enclosure 2, Section 1).
Inspection Findings
No violations were identified regarding NRC health and safety requirements. However, one or
more apparent violations were identified related to the NRCs security requirements. These
apparent violation(s) are described in the non-public enclosure. (Enclosure 3)
Corrective Actions
In the follow-up to the inspection, the licensee provided the inspector comprehensive corrective
actions that were implemented to restore compliance. The licensees corrective actions
involving NRC security requirements are described in the non-public enclosure. (Enclosure 3)
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3
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REPORT DETAILS - Health and Safety
1.
Program Overview (Inspection Procedure 87121)
1.1.
Program Scope
The HSI Group, Inc. (HSI) is authorized under NRC Materials License Number
53-35428-01, to possess and use byproduct material, including iridium-192, for industrial
radiographic operations. Licensed activities are authorized to be performed at the
licensees facility located in Hawaii, as well as at temporary job sites (TJS) in areas of
NRC jurisdiction. The licensees operations included the performance of industrial
radiography at a TJS in Hawaii, an area of NRC jurisdiction. HSI is a new radiography
licensee, whose license was issued on July 6, 2017.
1.2.
Observations and Findings
The inspector observed licensed activities at the licensees facility and TJS, reviewed
records, procedures, and documents maintained by the licensee, conducted
independent radiation measurements, and interviewed licensee personnel at the
licensed facility and at a TJS at an oil and gas processing facility in Kapolei.
Collectively, the activities observed, interviews conducted, and documents reviewed
described the licensees implementation of its radiation safety program.
2.
Inspection Findings (Inspection Procedure 87121)
2.1.
Inspection Scope
On February 8, 2018, the inspector conducted an announced inspection at the licensees
facility in Kapolei, Hawaii. The licensee stored records, licensed materials, and
radiography equipment at the facility, in addition to acting as an office-space to
personnel not participating in activities outside the site. On February 9, 2018, the
inspector conducted an unannounced inspection of the licensees TJS at the Island
Energy Services refinery in Kapolei, Hawaii. The licensee was on-site to perform
various non-destructive testing services, including industrial radiography, to support the
refinerys projects. The inspector observed licensed activities, which at the time of the
inspection consisted of the storage of an industrial radiographic device in a mobile
darkroom. The inspector reviewed records, procedures, and documents maintained by
the licensee at the trailer, conducted independent radiation measurements, and
interviewed licensee personnel.
2.2.
Observation and Findings
Licensed activities in Kapolei, Hawaii included the possession, use, and storage of
licensed radioactive materials related to the performance of industrial radiographic
activities. At the TJS, these radiographic activities were performed by HSI for a client,
Island Energy Services, to support the refinerys various quality control programs.
The inspector observed licensed activities at the licensees facility and TJS, reviewed
records, procedures, and documents maintained by the licensee, conducted
independent radiation measurements, and interviewed licensee personnel at the
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licensed facility and at a TJS at an oil and gas processing facility in Kapolei. Based on
the activities observed, interviews conducted, and documents reviewed, the inspector
determined that the licensee was adequately implementing its radiation safety program.
2.3.
Conclusions
The inspector reviewed the licensees radiation safety program and identified no
violations in areas concerning NRC health and safety requirements.
3.
Exit Meeting Summary
The inspector presented the preliminary inspection findings at the conclusion of the
onsite inspection on February 8, 2018, with Jason Bauer, Radiation Safety Officer, and
telephonically after the TJS inspection on February 9, 2018. On April 10, 2018, a final
telephonic exit meeting was conducted with Jason Bauer, Radiation Safety Officer, Mark
Kazee, Manager of Inspection Services, Mary Au, Manager of Hawaii Sites, and Bill
Reynolds, Director of Refinery Services. The licensee acknowledged the findings and
did not dispute any of the details presented during the exit call.
Supplemental Inspection Information - Health and Safety
PARTIAL LIST OF PERSONS CONTACTED
Jason Bauer, HSI Group RSO
Mark Kazee, HSI Group Manager of Inspection Services
Kyle Toyama, Island Energy Refinery
INSPECTION PROCEDURES USED
87121 Industrial Radiography Programs
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
None
Closed
None
Discussed
None
LIST OF ACRONYMS USED
Agencywide Documents Access and Management System
CFR
Code of Federal Regulations
NRC
Nuclear Regulatory Commission
PEC
Predecisional Enforcement Conference
Radiation Safety Officer
temporary job site