ML18319A285
| ML18319A285 | |
| Person / Time | |
|---|---|
| Site: | 15000012 |
| Issue date: | 10/26/2018 |
| From: | O'Dowd D NRC/RGN-III |
| To: | Meilman S Environmental Protection Industries |
| References | |
| IR 2018001 | |
| Download: ML18319A285 (3) | |
See also: IR 015000012/2018001
Text
NRC FORM 591M PART 1
U.S. NUCLEAR REGULATORY COMMISSION
(07-2012)
SAFETY INSPECTION REPORT AND COMPLIANCE INSPECTION
1. LICENSEE/LOCATION INSPECTED:
Environmental Protection Industries, Inc.
16650 S. Canal Street
South Holland, IL 60473
REPORT NUMBER(S) 2018001
3. DOCKET NUMBER(S)
150-00012
LICENSEE:
2. NRG/REGIONAL OFFICE
Region III
U.S. Nuclear Regulatory Commission
2443 Warrenville Road, Suite 210
Lisle, IL 60532-4352
4. LICENSE NUMBER($)
5. DATE(S) OF INSPECTION
IL-02294-01
October 26, 2018
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:
[Z] 1.
Based on the inspection findings, no violations were identified.
[Z] 2.
Previous violation(s) closed.
D 3.
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.
Non-cited violation(s) were discussed involving the following requirement(s):
D 4.
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 10 CFR 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
PRINTED NAME
SIGNATURE
LICENSEE'S
REPRESENTATIVE
NRC INSPECTOR
Dennis P. O'Dowd
BRANCH CHIEF
Aaron T. McCraw
NRC FORM 591M PART 1 (07-2012)
f
'
NRC FORM 591M PART 3
(07-2012)
U.S. NUCLEAR REGULATORY COMMISSION
Docket File Information
SAFETY INSPECTION REPORT AND COMPLIANCE INSPECTION
1. LICENSEE/LOCATION INSPECTED:
Environmental Protection Industries, Inc.
16650 S. Canal Street
South Holland, IL 60473
REPORT NUMBER(S) 2018001
3. DOCKET NUMBER($)
150-00012
6. INSPECTION PROCEDURES USED
87124
2. NRG/REGIONAL OFFICE
4. LICENSE NUMBER($)
IL-02294-0 I
Region III
U.S. Nuclear Regulatory Commission
2443 Warrenville Road, Suite 210
Lisle, IL 60532-4352
5. DATE(S) OF INSPECTION
October 26, 2018
7. INSPECTION FOCUS AREAS
03.01 - 03.07
SUPPLEMENTAL INSPECTION INFORMATION
1 . PROGRAM CODE(S)
03121
2. PRIORITY
5
D Main Office Inspection
3. LICENSEE CONTACT
4. TELEPHONE NUMBER
Sergio Meilman, Ops Director/RSO
(312) 354-0627
Next Inspection Date:
NA
D Field Office Inspection
Conducted in South Holland, IL for activities
[ZJ Temporary Job Site Inspection conducted at job sites in East Chicago, IN
PROGRAM SCOPE
This was an unannounced, special inspection of an environmental consulting, remediation, and engineering company
located in South Holland, Illinois, which had, on certain dates from the period beginning on September 25, 2018, and
ending on October 23, 2018, conducted licensed activities under reciprocity within NRC jurisdiction. Specifically, during
that period, the licensee possessed and used a portable nuclear gauge containing millicurie quantities of Cs-137 and
Am-241 for performing measurements of moisture/density of materials at various temporary job site locations at an
environmental remediation project in East Chicago, Indiana. This licensee had been subject to escalated enforcement
(EA-18-099; IR15000012/2018002), with a Notice of Violation dated September IO, 2018, (ML18254A425) and issued
a Severity Level III violation for failure to file for reciprocity with the NRC prior to possessing and using licensed
material in NRC jurisdiction (10 CFR 150.20), specifically, within the State oflndiana on several occasions between
June 11, 2018, and July 5, 2018. The licensee provided its corrective actions in letter dated August 21, 2018
(MLI 8235A265), which included immediately suspending its possession and use of licens<:?d material in Indiana upon
notification by the NRC, promptly filing for reciprocity with the NRC, providing to the NRC the listing of dates and
locations of unauthorized gauge use in Indiana, and reviewing the pertinent regulations regarding reciprocity and NRC
regulations.
PERFORMANCE OBSERVATIONS
During a telephone conversation with the licensee's RSO on October 26, 2018, the inspector was informed that the
licensee had ceased its use of the gauge at the project site in Indiana for 2018, as of October 23, 2018. This was earlier
than the licensee's expectation, and as per the direction of the environmental remediation project management. Because a
temporary job site inspection was not possible, the inspector conducted an inspection of the licensee's activities
conducted previously at the job sites in East Chicago, IN, at the licensee's corporate office located in South Holland,
Illinois. The inspector met with the RSO and discussed the licensee's methods for adequately securing the gauge while in
NRC jurisdiction using at least two independent physical controls when the gauge was unattended. The inspector
(cont'd. on next page)
NRC FORM 591 M PART 3 (07-2012)
NRC FORM 591M PART 3
(07-2012)
U.S. NUCLEAR REGULATORY COMMISSION
Docket File Information
SAFETY INSPECTION REPORT AND COMPLIANCE INSPECTION
1. LICENSEE/LOCATION INSPECTED:
2. NRG/REGIONAL OFFICE
Region III
Environmental Protection Industries, Inc.
16650 S. Canal Street
South Holland, IL 60473
U.S. Nuclear Regulatory Commission
2443 Warrenville Road, Suite 210
Lisle, IL 60532-4352
REPORT NUMBER(S) 2018001
3. DOCKET NUMBER($)
150-00012
6. INSPECTION PROCEDURES USED
87124
4. LICENSE NUMBER($)
IL-02294-01
7. INSPECTION FOCUS AREAS
03.01 - 03.07
SUPPLEMENTAL INSPECTION INFORMATION
5. DATE(S) OF INSPECTION
October 26, 2018
1. PROGRAM CODE(S)
03121
2. PRIORITY
5
3. LICENSEE CONTACT
4. TELEPHONE NUMBER
Sergio Meilman, Ops Director/RSO
(312) 354-0627
D Main Office Inspection
Next Inspection Date:
D Field Office Inspection
Conducted in South Holland, IL for activities
[ZJ Temporary Job Site Inspection conducted at job sites in East Chicago, IN
PROGRAM SCOPE
(cont'd. from previous page)
NA
also discussed the following with the RSO: gauge user training, gauge use, leak tests, gauge maintenance, and
emergency response relative to gauges while in NRC jurisdiction. Based on these discussions with the RSO, the
inspector determined that the RSO had sufficient understanding of radiation safety principles with respect to the use of
portable gauges, and of pertinent NRC regulations and requirements. The inspector reviewed written records and
documentation relative to licensed activities conducted in NRC jurisdiction, including utilization logs ( confirming dates
and locations of use in NRC jurisdiction were as stated in the licensee's reciprocity notifications), leak test records,
shipping papers, and training certificates (including DOT hazmat), and dosimetry. No issues or concerns were noted.
With respect to the enforcement follow-up aspect of this inspection, the inspector determined that corrective actions
were completed as described by the licensee in its response, and that the violation had not recurred. Based on this, the
previous violation involving 10 CFR 150.20 is considered closed.
No violations ofNRC requirements were identified during this inspection.
NRC FORM 591M PART 3 (07-2012)