ML18212A022
| ML18212A022 | |
| Person / Time | |
|---|---|
| Site: | 03037434 |
| Issue date: | 06/18/2018 |
| From: | Ryan Craffey NRC/RGN-III |
| To: | Dillingham J Nordlund & Associates, West Michigan Testing |
| References | |
| IR 2018001 | |
| Download: ML18212A022 (2) | |
Text
NRC FORM 591M PART 1 U.S. NUCLEAR REGULATORY COMMISSION (07-2012) 1 0CFR 2-2 01 SAFETY INSPECTION REPORT AND COMPLIANCE INSPECTION
- 1. LICENSEE/LOCATION INSPECTED:
Nordlund & Associates, Inc. dba West Michigan Testing, Inc. 815 East Ludington A venue Ludington, Ml 49431 REPORT NUMBER(S) 2018001 2. NRG/REGIONAL OFFICE Region III U. S. Nuclear Regulatory Commission 2443 Warrenville Road, Suite 210 Lisle, IL 60532-4352
- 3. DOCKET NUMBER(S}
- 4. LICENSE NUMBER($)
- 5. DATE(S) OF INSPECTION 030-37434 21-26281-02 June 18, 2018 LICENSEE:
The inspection was an examination of the activities conducted under your license as they relate to radiation safety and to compliance with the Nuclear Regulatory Commission (NRC) rules and regulations and the conditions of your license. The inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspector.
The inspection findings are as follows: D 1. D 2. 0 3. D 4. Based on the inspection findings, no violations were identified.
Previous violation(s) closed. The violations(s), specifically described to you by the inspector as non-cited violations, are not being cited because they were self-identified, non-repetitive, and corrective action was or is being taken, and the remaining criteria in the NRC Enforcement Policy, to exercise discretion, were satisfied.
One Non-cited violation(s) were discussed involving the following requirement(s):
Condition 13.A ofNRC License 21-26281-02 states, in part, that sealed sources shall be tested for leakage and/ or contamination at intervals not to exceed those specified in the certificate ofregistration issued by the U.S. Nuclear Regulatory Commission under 10 CFR 32.210 or by an Agreement State. Certificate of Registration No. NR-0587-0-104-S states that the leak test frequency for a Seaman C-200 portable gauge is 6 months. Contrary to the above, the licensee tested an in-use Seaman C-200 portable gauge for leakage on June 22, 2015, October 31, 2016, October 31, 2017, and June 14, 2018, which represent intervals that exceeded 6 months. During this inspection, certain of your activities, as described below and/or attached, were in violation of NRC requirements and are being cited in accordance with NRC Enforcement Policy. This form is a NOTICE OF VIOLATION, which may be subject to posting in accordance with 10CFR 19.11. (Violations and Corrective Actions) Statement of Corrective Actions I hereby state that, within 30 days, the actions described by me to the Inspector will be taken to correct the violations identified.
This statement of corrective actions is made in accordance with the requirements of 10 CFR 2.201 (corrective steps already taken, corrective steps which will be taken, date when full compliance will be achieved).
I understand that no further written response to NRC will be required, unless specifically requested.
TITLE LICENSEE'S REPRESENTATIVE NRC INSPECTOR Ryan Craffey BRANCH CHIEF Aaron Mccraw NRC FORM 591M PART 1 (07-2012)
PRINTED NAME SIGNATURE DATE 07/23/2018 07/30/2018 NRC FORM 591M PART 3 U.S. NUCLEAR REGULATORY COMMISSION (07-2012) 10 CFR 2.201 Docket File Information SAFETY INSPECTION REPORT AND COMPLIANCE INSPECTION
- 1. LICENSEE/LOCATION INSPECTED:
- 2. NRG/REGIONAL OFFICE Nordlund & Associates, Inc. dba West Michigan Testing, Inc. 815 East Ludington A venue Region III U.S. Nuclear Regulatory Commission 2443 Warrenville Road, Suite 210 Lisle, IL 60532-4352 Ludington, Ml 49431 REPORT NUMBER(S) 2018001 3. DOCKET NUMBER(S) 030-37434
- 6. INSPECTION PROCEDURES USED 87124 4. LICENSE NUMBER(S) 21-26281-02
- 7. INSPECTION FOCUS AREAS All 5. DATE(S) OF INSPECTION June 18, 2018 SUPPLEMENTAL INSPECTION INFORMATION
- 1. PROGRAM CODE(S) 03121 2. PRIORITY 5 [{] Main Office Inspection D Field Office Inspection D Temporary Job Site Inspection
- 3. LICENSEE CONTACT 4. TELEPHONE NUMBER James Dillingham
-RSO (231) 843-3485 Next Inspection Date: 06/18/2023
~-------------------~
PROGRAM SCOPE This was an unannounced routine inspection of a engineering and surveying firm authorized to store portable moisture density gauges containing byproduct material at its office in Ludington, Michigan, and to use them at temporary job sites in NRC jurisdiction.
At the time of the inspection, the licensee had one Troxler 3400 series gauge, one Seaman C-100 gauge (out of service);
and three Seaman C-200 gauges (two of which were out of service), and two active authorized users. PERFORMANCE OBSERVATIONS The inspector toured the facility in Ludington to evaluate the licensee's measures for materials security, hazard communication, and exposure control. The inspector conducted independent surveys of the facility alongside confirmatory surveys by the licensee, and found that exposures in publicly accessible areas were below regulatory limits. The inspector was unable to observe the conduct of any licensed activities, as none were in progress or scheduled at the time of the inspection.
Instead, the inspector interviewed the licensee's staff to discuss gauge use, transportation, emergency response, and program oversight.
The inspector also reviewed a selection of records, including documentation of leak tests, utilization logs, hazardous materials transportation training.
During a review ofleak test documentation, the inspector noted a SLIV violation of Condition 13.A ofNRC License 21-26281-02 for the licensee's self-identified failure to perform leak tests on its sole in-use Seaman gauge at the required frequency.
The licensee determined that the root cause was an oversight.
As corrective action, on June 14, 2018, the licensee collected leak tests of both in-service gauges and submitted them for analysis.
On July 3, 2018, the licensee forwarded copies of the results (both negative) to the inspector, and committed to track due dates for future leak tests on an existing calendar for tracking technician certifications and equipment calibrations.
Since this violation was self-identified, non-repetitive, not willful, and since corrective action had already been taken to restore compliance and to address the potential for recurrence, the violation was characterized as an NCV. The inspector conducted an exit meeting with the licensee on July 18, 2018, following receipt of corrective action documentation.
NRC FORM 591M PART 3 (07-2012)