ML22006A254
| ML22006A254 | |
| Person / Time | |
|---|---|
| Site: | 15000046 |
| Issue date: | 01/07/2022 |
| From: | Mary Muessle Division of Nuclear Materials Safety IV |
| To: | Martin T NorthWest Inspection |
| Wardrobe L | |
| References | |
| EA-21-145 IR 2021001 | |
| Download: ML22006A254 (9) | |
See also: IR 015000046/2021001
Text
January 7, 2022
Mr. Tony Martin
President/Radiation Safety Officer
Northwest Inspection, Inc.
615 North Kellogg Street
Kennewick, WA 99336
SUBJECT: NRC INSPECTION REPORT 150-00046/2021-001
Dear Mr. Martin:
This letter refers to the unannounced reciprocity inspection conducted on July 15, 2021, at a
temporary jobsite location in Athol, Idaho, with continued in-office review through
December 6, 2021. This inspection examined activities conducted under a general license
pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 150.20 for your activities
performed in area of exclusive Federal jurisdiction, as they relate to public health and safety and
to confirm compliance with the U.S. Nuclear Regulatory Commission (NRC) rules and
regulations and with the conditions of your license. Within these areas, the inspection consisted
of selected examination of procedures and representative records, observations of activities,
and interviews with personnel. The inspector discussed the preliminary inspection findings with
Mr. Joshua Remme of your staff at the conclusion of the on-site portion of the inspection. A
final exit briefing was conducted telephonically with you on December 6, 2021. The enclosed
report presents the results of the inspection.
Based on the results of this inspection, one apparent violation was identified and is being
considered for escalated enforcement action in accordance with the NRC Enforcement Policy.
The current Enforcement Policy is included on the NRC website at http://www.nrc.gov/about-
nrc/regulatory/enforcement/enforce-pol.html. The apparent violation involved the failure of the
licensees radiographer assistant to wear all required personnel monitoring devices in
accordance with 10 CFR Section 34.47, Personnel monitoring. Specifically, a radiographers
assistant failed to wear a personnel dosimeter on the trunk of their body during radiographic
operations. The circumstances surrounding this apparent violation, the significance of the
issue, and the need for lasting and effective corrective action were discussed with you during
the telephonic exit meeting on December 6, 2021.
In addition, since your facility has not been the subject of an escalated enforcement action
within the last two inspections and based on our understanding of your corrective actions, a civil
penalty may not be warranted in accordance with Section 2.3.4 of the Enforcement Policy. The
final decision will be based on you confirming on the license docket that the corrective actions
previously described to the NRC staff have been or are being taken.
T. Martin -2-
Before the NRC makes its enforcement decision, we are providing you an opportunity to:
(1) respond to the apparent violation addressed in this inspection report within 30 days of the
date of this letter, or (2) request a predecisional enforcement conference (PEC). If a PEC is
held, it will be open for public observation and the NRC may issue a press release to announce
the time and date of the conference. If you decide to participate in a PEC, please contact
Ms. Lizette Roldán-Otero, PhD, at (817) 200-1455 or lizette.roldan-otero@nrc.gov within
10 days of the date of this letter. 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 150-00046/2021-001; EA-21-145 and should
include for the 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 mailed to Ms. Mary C.
Muessle, Director, Division of Nuclear Materials Safety, Region IV, 1600 East Lamar Boulevard,
Arlington, Texas, 76011, and emailed to R4Enforcement@nrc.gov within 30 days of the date of
this letter. 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 action, 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 in preparing
your response. You can find the Information Notice on the NRC website at:
https://www.nrc.gov/docs/ML0612/ML061240509.pdf.
Please be advised that the characterization of the apparent violation described in the enclosed
inspection report may change as a result of further NRC review. You will be advised by
separate correspondence of the results of our deliberations on this matter.
T. Martin -3-
In accordance with 10 CFR 2.390 of the NRCs Agency Rules of Practice and Procedure, a
copy of this letter, its enclosure, and your response, if you choose to provide one, will be made
available electronically for public inspection in the NRC Public Document Room and from the
NRCs Agencywide Documents Access and Management 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 or proprietary information so that it can be
made available to the public without redaction.
If you have any questions concerning this matter, please contact Dr. Lizette Roldán-Otero, of
my staff at (817) 200-1455.
Sincerely,
Signed by Muessle, Mary
on 01/07/22
Mary C. Muessle, Director
Division of Nuclear Materials Safety
Docket No. 150-00046
License No. General License pursuant to 10 CFR 150.20
Enclosure:
NRC Inspection Report 150-00046/2021-001
cc w/Enclosure:
Mark Dietrich, PE, State Liaison Officer
Idaho Department of Environmental Quality
1410 N. Hilton St.
Boise, ID 83706
Jill Dinehart Wood, Director
Office of Radiation Protection
Washington Department of Health
P.O. Box 47827
Olympia, WA 98504-7827
SUNSI Review: ADAMS: Non-Publicly Available Non-Sensitive Keyword:
By: ACR Yes No Publicly Available Sensitive EA-21-145
OFFICE MIB C:MIB TL:ACES RC D:DNMS
NAME LWardrobe LRoldanOtero JGroom DCylkowski MMuessle
SIGNATURE /RA/ E /RA/ E /RA/ E /RA/ E MCM
DATE 12/06/21 12/16/21 01/03/22 01/04/22 01/07/2022
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket No.: 150-00046
License No.: General License pursuant to 10 CFR 150.20 (WN-IR065-1)
Inspection Report No.: 150-00046/2021-001
Licensee: Northwest Inspection, Inc.
Location Inspected: 2244 E. Seasons Road
Athol, Idaho 83801
Inspection Dates: July 15, 2021, through December 6, 2021
Exit Meeting Date: December 6, 2021
Inspector: Leonardo Wardrobe, Health Physicist
Materials Inspection Branch
Division of Nuclear Materials Safety, Region IV
Approved By: Lizette Roldán-Otero, PhD, Chief
Materials Inspection Branch
Division of Nuclear Materials Safety, Region IV
Attachment: Supplemental Inspection Information
Enclosure
EXECUTIVE SUMMARY
Northwest Inspection, Inc.
NRC Inspection Report 150-00046/2021-001
On July 15, 2021, the U.S. Nuclear Regulatory Commission (NRC) performed an unannounced
inspection of Northwest Inspections, Inc. (Northwest), a State of Washington licensee, at a
temporary jobsite in Athol, Idaho, with in-office reviews through December 6, 2021. The
inspection included reviews of Northwest activities in exclusive Federal jurisdiction in Idaho
under reciprocity as they relate to the public health and safety and to confirm compliance with
the NRCs rules and regulations.
Program Overview
Northwest is authorized under the State of Washington license no. WN-IR065-01 to possess
and use byproduct material, including iridium-192 and selenium-75, in industrial radiographic
exposure devices. The licensee was working under a reciprocal agreement authorized by a
general license pursuant to 10 CFR 150.20 to perform these licensed activities at temporary
jobsites in areas of exclusive Federal jurisdiction. At the time of inspection, Northwest was
performing licensed activities in Athol, Idaho. (Section 1)
Inspection Findings
As a result of this inspection, one apparent violation was identified concerning the failure of a
radiographers assistant to wear, on the trunk of the body, a direct reading dosimeter, an
operating alarm ratemeter, and a personnel dosimeter at all times during radiographic
operations in accordance with 10 CFR 34.47(a). (Section 3)
Corrective Actions
The licensee immediately ceased radiographic operations on the day of the inspection and
provided additional radiation safety training to all employees. In addition, the licensee
incorporated into its procedures the requirement for radiographers to ensure their assistants
have all the required dosimetry.
2
REPORT DETAILS
1 Program Overview (Inspection Procedure (IP) 87121)
1.1 Program Scope
Northwest Inspections, Inc. (Northwest) is authorized under the State of Washington
WN-IR065-01 to possess and use byproduct material, including iridium-192 and
selenium-75, for use in industrial radiographic exposure devices. This licensee was
working under a reciprocal agreement authorized by a general license pursuant to 10
CFR 150.20 to perform these licensed activities at temporary jobsites in areas of
exclusive Federal jurisdiction. At the time of inspection, Northwest was performing
licensed activities in Athol, ID under reciprocity, and also during calendar year 2021.
1.2 Inspection Scope
The temporary jobsite inspection was performed on July 15, 2021 in Athol, Idaho. The
inspection continued with in-office review through December 6, 2021. The inspection
included reviews of activities, interviews with personnel and selected records review with
respect to Northwests work in exclusive Federal jurisdiction as they relate to public
health and safety, and to confirm compliance with the NRCs rules and regulations.
2 Background (IP 87121)
Northwest performs various types of nondestructive testing including radiographic
analysis on piping and pressure vessel welds. The inspector reviewed the licensees
Agreement State license and NRC Form 241 and confirmed that the licensee was
authorized to perform radiographic operations at a temporary jobsite in NRC jurisdiction
using iridium-192 and selenium-75 on July 15, 2021.
The inspector observed/reviewed radiographic operations at a temporary jobsite location
in NRC jurisdiction (Athol, Idaho).
3 Observations and Findings (IP 87121)
During an onsite inspection conducted on July 15, 2021, which continued remotely until
the date of the exit meeting on December 6, 2021, the inspector reviewed licensed
activities pertinent to industrial radiographic operations in Athol, Idaho. During this
review, one apparent violation of NRC requirements was identified.
3.1 Apparent Violation of 10 CFR 34.47(a)
Title 10 CFR 34.47(a), requires, in part, that the licensee may not permit any individual
to act as a radiographer or radiographers assistant unless, at all times during
radiographic operations, each individual wears, on the trunk of the body, a direct reading
dosimeter, an alarming ratemeter, and a personnel dosimeter.
Contrary to the above, on July 15, 2021, a radiographers assistant performed
radiographic operations and failed to wear, on the trunk of the body, a direct reading
dosimeter, an alarming ratemeter, and a personnel dosimeter. Specifically, a
3
radiographers assistant was performing radiographic operations in NRC jurisdiction and
failed to wear a personnel dosimeter.
The failure to wear a personnel dosimeter while performing radiographic operations in
NRC jurisdiction was identified as an apparent violation of 10 CFR 34.47(a).
(150-00046/2021-001-01)
4 Corrective Actions
The licensee immediately ceased radiographic operations, and on July 16, 2021, the
radiography assistant completed additional radiation safety training. On July 19, 2021,
the licensee had completed additional training with licensee personnel on The
Importance of Wearing Radiation Safety Equipment and issued an all-employees memo
on the above topic. The memo included that radiographers should ensure that their
radiographers assistant/trainee should be wearing all required personnel dosimetry. In
addition, Northwest updated its procedures to include a check box for a personal
dosimetry in the daily Radiation Safety Report, included a section in the annual
radiation training about the proper use of personal dosimetry, and will ensure use of
personnel dosimetry during the semi-annual field audits.
5 Exit Meeting Summary
On December 6, 2021, an exit meeting was held by telephone with Mr. Tony Martin,
Radiation Safety Officer. The inspector summarized the inspection findings and
observations, indicating that one apparent violation was identified and that a choice letter
will be transmitted.
4
Supplemental Inspection Information
PARTIAL LIST OF PERSONS CONTACTED
Joshua Remme, Radiographer
Wilbert Pedraza, Radiographers Assistant
- Tony Martin, Radiation Safety Officer
- Individuals present at exit meeting conducted by telephone on December 6, 2021
INSPECTION PROCEDURE USED
IP 87121 - Inspection of Industrial Radiography Programs
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
150-00046/2021-001-01 AV Failure to wear a personnel dosimeter
Closed
None.
Discussed
None.
LIST OF ACRONYMS USED
10 CFR Title 10 of the Code of Federal Regulations
ADAMS Agencywide Documents Access and Management System
AV Apparent Violation
IP Inspection Procedure
NRC U.S. Nuclear Regulatory Commission
PEC Predecisional Enforcement Conference
RSO Radiation Safety Officer
Attachment