ML20059B957
| ML20059B957 | |
| Person / Time | |
|---|---|
| Issue date: | 12/21/1993 |
| From: | Dan Collins NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Atwater R AFFILIATION NOT ASSIGNED |
| References | |
| REF-QA-99990001-931221 NUDOCS 9401040304 | |
| Download: ML20059B957 (1) | |
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Q{[(jlRi(MO(@Y DEC 211993 Docket No. 99990001 License No. Alabama 1022 (Agreement State)
Ground Engineering and Testing Service, Inc.
ATTN: Mr. Ralph Atwater Branch Manager 4814 Commercial Drive Huntsville, Alabama 35816 Gentlemen:
SUBJECT:
NRC INSPECTION REPORT NO. Alabama 1022 (Agreement State)/93-12 Thank you for your response of December 3,1993, to our Notice of Violation, 1
issued on November 8, 1993, concerning activities conducted under the general licensee authorized bu 10 CFR Part 150. We have evaluated your response and i
found that it meets the requirements of 10 CFR 2.201. We will examine the implementation of your corrective actions during future inspections.
We appreciate your cooperation in this matter.
Sincerely, Original signed by E. J. McAlpine j
Douglas M. Collins, Chief Nuclear Materials Safety and Safeguards Branch Division of Radiation Safety and Safeguards I
cc:
State of Alabama Commonwealth of Pennsylvania 9401040304 931221 REG 2 3A999 EEC*****
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_j# GAQUND ENGINEEAING AND TESTING SERVICE, INC.
December 3,1993 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention:
Document Control Desk
Subject:
" Reply to a Notice of Violation" NRC Inspection Report No. 99990001/93-012 Docket No. 99990001 License No. Alabama 1022 Gentlemen:
This letter is our written response to the subject " Notice of Violation" dated November 8, 1993. The violation was detected on August 31,1993 during an NRC inspection. The inspection took place at the Bradford Towne Plaza construction job site in Wysox, Pennsylvania. Ground Engineering and Testing Service, Inc. was performing construction testing services for the general contractor, F. R. Hoar, Inc. using a portable nuclear moisture / density gauge. The inspection was a result of our notification of the NRC, the State of Alabama (agreement state), and Pennsylvania State Police that a robbery had occurred at the site and that the gauge was stolen. All ettempts to recover the gauge including advertising, rewards, newspaper articles, visits to dumpsters, pawn shops and police stations have failed.
Reason for Violation Ground Engineering and Testing Service, Inc. failed to notify the NRC offices that the gauge was moved within the State of Pennsylvania from the originallocation of Whitehall, i'ennsylvania. Ground Engineering and Testing Service, Inc. had paid the appropriate 1ee and had been granted recognition of reciprocity
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4B14 COMMERCI AL DRIVE N.W.
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Ground Engineering and Testing Service, Inc. was awarded a contract by our same client to run concurrent with the Whitehall project in Wysox, Pennsylvania about 90 miles away.
Subsequently, the gauge was moved between the projects.
This violation occurred because of our failure to understand the NRC's regulation requiring notification if moved from site to site within a non-agreement state. This was not an intentional violation. Our state (Alabama) is an agreement state and we are free to move from site to site. We would have anticipated notification and submission of a fee if we were entering another state.
Corrective Steps Taken and Results Corrective steps taken as a result of this violation include:
1)
Notificat:in on August 31,1993 to our technicians (2) operating in the non agreement state of Pennsylvania that gauges could not be moved from site to site within the state without first obtaining approval from the Region i NRC.
2)
Immediate review by the RSO of the recognition of reciprocity acknowledgement letter, including 10 CFR Part 2, Appendix C 10CFR Part 19,30,71,150,170, and the NRC Form 241 including instructions, filed by Ground Engineering and Testing Service, Inc.
3)
Conversations by Ground Engineering and Testing Service, Inc. personnel with representatives from the NRC Region I and Region 11 offices regarding clarification of correct procedures in non agreement states.
The results of these corrective steps are an understanding by Ground Engineering and Testing Service, Inc. personnel of the requirements for multi site usage by the NRC for non agreement states.
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Corrective Steps Taken to Avoid Further Violations 1)
A notice was posted in each gauge file to carefully review the details of any recognition of reciprocity agreement and reinstruct the technicians working in that particular state accordingly.
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Full compliance is believed to have been achieved after receiving, reviewing and respondirig in writing via this report to your written Notice of Violation, dated November 8,1993. Also on December 3,1993 a meeting was held by the Huntsville Branch RSO regarding general gauge license requirements, safety, and transportation requirements including within non agreement states.
l We hope that you will review our response favorably. If you have any further questions regarding this issue, please contact us.
i Very truly yours, i
GROUND ENGINEERING AND TESTING SERVICE,INC.
l J. David Mandel Technician Manager Department Manager A M ?t w Step en'. Freeman 1
Officer adiatiyn Safe y3 hY' J
Iphy. Atwater, P.E.
Branch Manager / Principal JDM:SRF: RWA:bsp cc:
NRC Regional Administrator Region 11 t
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