ML18199A584
| ML18199A584 | |
| Person / Time | |
|---|---|
| Site: | 03020982 |
| Issue date: | 07/13/2018 |
| From: | Burritt A L NRC Region 1 |
| To: | Shumway D Prime NDT Services |
| References | |
| EA-18-082 IR 2018001 | |
| Download: ML18199A584 (5) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 2100 RENAISSANCE BLVD. KING OF PRUSSIA, PA 19406-2713 EA-18-082 Don Shumway, PresidenURSO Prime NDT Services, Inc. 4345 Independence Drive Schnecksville, PA 18078 July 13, 2018
SUBJECT:
PRIME NDT SERVICES, INC. -NRC INSPECTION NO. 03020982/2018001 AND NOTICE OF VIOLATION
Dear Mr. Shumway:
On April 26, 2018; May 16, 23, and 24, 2018; and June 19, 2018; Steven Courtemanche of this office conducted a safety and a security inspection at the above address and a temporary job site near Mountain, WV of activities authorized by the listed NRC license. The inspection was an examination of your licensed activities as they relate to radiation safety and to compliance with the Commission's regulations and the license conditions.
The inspection consisted of observations by the inspector, interviews with personnel, and a selective examination of representative records. The inspector reviewed your compliance with personnel dosimetry requirements under 10 CFR 34.47 and determined that Prime NDT Services, Inc. is using direct ion storage (DIS) dosimetry designed for remote data evaluation to meet these requirements. The inspector reviewed the conditions described in NRC Enforcement Guidance Memorandum-18-001 (EGM-18-001) and found that: (1) the DIS dosimeters are being provided and dose data evaluated and reported for the dose of record by an NVLAP-accredited processor, (2) the licensee and NVLAP processor have implemented specified quality controls to ensure that the dosimeter is calibrated and/or replaced appropriately, and (3) the licensee has maintained the necessary documentation and records to demonstrate that the criteria of EGM-18-001 are being implemented.
The NRC has determined that the implementation of your instadose dosimetry system meets the criteria of EGM-18-001, dated May 11, 2018. Future inspections will review and determine whether the criteria of the EGM continue to be met. If the NRC identifies that such DIS dosimetry arrangements do not meet the criteria of the EGM, a violation of 10 CFR 34.47(a) and (a)(3) will be considered, as appropriate.
Such reviews will continue for as long as the EGM criteria remain in effect. The findings of the inspection were discussed telephonically on June 19, 2018, at the conclusion of the inspection.
Based on the results of this inspection, the NRC has determined that a 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 NRC's Web site at (https://www.nrc.gov/about-nrc/regulatory/enforcemenUenforce-pol.html).
The violation is cited in the enclosed Notice of Violation (Notice) because the violation was identified by the NRC.
D. Shumway 2 You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response.
If you have additional information that you believe the NRC should consider, you may provide it in your response to the Notice. The NRC review of your response to the Notice will also determine whether further enforcement action is necessary to ensure compliance with regulatory requirements.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response, will be made available electronically for public inspection in the NRC Public Document Room or from the NRC document system (ADAMS}, accessible from the NRC Web site 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 available to the Public without redaction.
If you have any questions regarding this matter, please contact Steven Courtemanche of my staff at (610) 337-5075 or via electronic mail at Steven.Courtemanche@nrc.gov.
Thank you for your cooperation.
DocketNo.03020982 License No. 37-23370-01
Enclosure:
Notice of Violation cc w/
Enclosure:
State of West Virginia State of Ohio Sinceri 1 *. ) /J+ I 1i}trU{vJI Arthbi L. Burritt, Chief Commercial, Industrial, R&D and Academic Branch Division of Nuclear Materials Safety Region I Commonwealth of Pennslyvania D. Shumway 3 PRIME NOT SERVICES, INC. -NRC INSPECTION NO. 03020982/2018001 AND NOTICE OF VIOLATION DATED .July l 3, 201 s DISTRIBUTION:
ADAMS (PARS) J Peralta, OE N Hasan, OE S Rodriguez, OE L Sreenivas, OE M Burgess, NMSS R Sun, NMSS S Holiday, NMSS J Trapp, DNMS, RI J Nick, DNMS, RI A Burritt, DNMS, RI S Courtemanche, RI B Klukan, RI R 1 Enforcement S Villar, RI Region I OE Files (with concurrences)
DOCUMENT NAME: G:\WordDocs\Current\lnsp Letter\L37-23370-01.2018-001.docx SUNSI Review Complete:
Steven R Courtemanche After declaring this document "An Official Agency Record" it will be released to the Public. To receive a co of this document, indicate in the box: "C" = Co w/o attach/encl "E" = Co w/ attach/encl "N" = No co OFFICE Rl:DNMS RI/ORA RI/DNMS NAME SCourtemanche CCrisden ABurritt DATE 7 n/ '/...,:> IS 113 1 OFFICIAL RECORD COPY Prime NDT Services, Inc. Schnecksville, PA NOTICE OF VIOLATION Docket No. 030-20982 License No. 37-23370-01 During an NRC inspection conducted on April 26, 2018; May 16, 23, and 24, 2018; and June 19, 2018; one violation of NRC requirements was identified.
In accordance with the NRC Enforcement Policy, the violation is listed below: 1 O CFR 71.5(a) requires, in part, that each licensee who transports licensed material outside the site of usage, as specified in the NRC license, or where transport is on public highways, comply with the applicable requirements of the DOT regulations in 49 CFR Parts 107, 171 through 180, and 390 through 397, appropriate to the mode of transport.
49 CFR 177 .817( e )(2) requires, in part, that a driver of a motor vehicle containing hazardous material ensure that the shipping paper required by this section is readily available to, and recognizable by, authorities in the event of an accident or inspection.
Specifically, the driver shall store the shipping paper as follows: (i) When the driver is at the vehicle's controls, the shipping paper shall be either readily visible to a person entering the driver's compartment or in a holder which is mounted to the inside of the door on the driver's side of the vehicle. (ii) When the driver is not at the vehicle's controls, the shipping paper shall be in a holder which is mounted to the inside of the door on the driver's side of the vehicle or on the driver's seat in the vehicle. Contrary to the above, on May 23, 2018, the licensee transported licensed material on public highways and the driver of the motor vehicle containing iridium 192, a hazardous material, did not ensure that the shipping paper required by this section is readily available to, and recognizable by, authorities in the event of an accident or inspection.
Specifically, the driver stored the shipping paper under the central storage area by the driver's seat, a method not permitted by the regulations.
This is a Severity Level IV violation (Enforcement Policy Section 6.8). Pursuant to the provisions of 10 CFR 2.201, Prime NDT Services, Inc. is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555, with a copy to the Regional Administrator, Region I, within 30 days of the date of the letter transmitting this Notice of Violation (Notice).
This reply should be clearly marked as a "Reply to a Notice of Violation" and should include for each violation:
(1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and ( 4) the date when full compliance will be achieved.
Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response.
If an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.
Notice of Violation Prime NDT Services 2 If you contest this enforcement action, you should also provide a copy of your response to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.
Under the authority of Section 182 of the Act, 42 U.S.C. 2232, any response which contests an enforcement action shall be submitted under oath or affirmation.
Your response will be placed in the NRC Public Document Room (PDR) and on the NRC Web site. To the extent possible, it should, therefore, not include any personal privacy, proprietary, or safeguards information so that it can be made publically available without redaction.
However, if you find it necessary to include such information, you should clearly indicate the specific information that you desire not to be placed in the PDR, and provide the legal basis to support your request for withholding the information from the public. In accordance with 10 CFR 19.11, you may be required to post this Notice within two working days of receipt. Dated This D day of July 2018