ML25219A270
| ML25219A270 | |
| Person / Time | |
|---|---|
| Site: | 99990003 |
| Issue date: | 08/12/2025 |
| From: | Rhex Edwards NRC/RGN-III/DRSS/MIB |
| To: | Palm L R.L. Adams Plastics |
| References | |
| EA-25-0155, EN 57723, NMED 250199 (Closed) IR 2025001 | |
| Download: ML25219A270 (1) | |
Text
EA-25-0155 EN 57723 NMED No. 250199 (Closed)
Leigha Acuna Palm Safety & Training Coordinator R.L. Adams Plastics, Inc.
5955 Crossroads Commerce Pkwy SW Wyoming, MI 49519
SUBJECT:
NRC NON-ROUTINE INSPECTION REPORT NO. 99990003/2025001(DRSS)
AND NOTICE OF VIOLATION-R.L. ADAMS PLASTICS, INC.
Dear Leigha Acuna Palm:
Between May 20, 2025, and July 29, 2025, inspectors from the U.S. Nuclear Regulatory Commission (NRC) conducted an in-office review of the circumstances surrounding the loss of two generally licensed tritium (H-3) exit signs (Isolite Model SLX-60, Serial Number H56081 and H56088) at your facility in Wyoming, Michigan. The NRC initiated this review after R.L. Adams Plastics, Inc. contacted the NRC Operations Center on May 20, 2025, to report the loss of the H-3 signs and followed that telephone notification with a written report on June 17, 2025. An electronic copy of the written report can be found in the NRCs Agencywide Documents Access and Management System (ADAMS) under Accession Number ML25178A322.
During this in-office review, the NRC staff examined activities conducted under your general license related to public health and safety. Additionally, the staff examined your compliance with the Commissions rules and regulations. The in-office review consisted of interviews with personnel and an examination of information provided by you to the NRC.
Based on the results of our review and the information you provided, the NRC has determined that a Severity Level IV violation of NRC requirements occurred involving the loss of two generally licensed tritium exit signs. The violation was evaluated in accordance with the NRC Enforcement Policy. The current Enforcement Policy is included on the NRCs website at https://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. The violation involved the failure to properly dispose of or transfer radioactive material from a generally licensed device, contrary to Title 10 of the Code of Federal Regulations (CFR) 31.5(c)(8)(i). The NRC assessed this violation at Severity Level IV (very low safety significance) because the material was contained in a generally licensed device that is not required to be registered under 10 CFR 31.5(c)(13).
The NRC inspectors reviewed your written report, dated June 17, 2025, and agreed with your determination that the root cause of the violation was attributed to the signs, after becoming detached from their mounting chains, being placed in a storage room and then discarded as August 12, 2025
L. Palm 2
standard waste. The inspectors also agreed with your assessment of the safety significance of the event documented in your written report, given that the material had decayed to 4.6 curies per sign at the time of loss. The NRC has concluded that, given that no additional attempts will be made to recover the missing material, its loss does not present an undue hazard to public health and safety. To prevent a similar violation, the remaining six signs owned by R.L. Adams Plastics, Inc. were returned to Isolite for proper disposal and R.L. Adams Plastics, Inc. has committed to discontinuing the use of any products containing radioactive materials.
The violation is cited in the enclosed Notice of Violation (Notice). The violation is being cited because it was revealed through an event (lost nuclear material Event Notification57723).
The NRC has concluded that information regarding the reason for the violation and the corrective actions taken to prevent recurrence are already adequately addressed on the docket in this letter. You are not required to respond to this letter unless the description herein does not accurately reflect your corrective actions or your position. In that case, or if you contest this action, you should provide your response, with the basis for your denial, to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region III, 2056 Westings Ave, Suite 400, Naperville, IL 60563-2657.
In accordance with 10 CFR 2.390 of the NRCs Agency Rules of Practice and Procedure, a copy of this letter will be available electronically for public inspection in the NRCs Public Document Room or from the NRCs Agencywide Documents Access and Management System (ADAMS), accessible from the NRCs website at http://www.nrc.gov/reading-rm/adams.html.
Please feel free to contact Laura Dresen of my staff if you have any questions regarding this correspondence. Laura Dresen can be reached at 630-829-9554 or Laura.Dresen@nrc.gov.
Sincerely, Rhex A. Edwards, Chief Materials Inspection Branch Division of Radiological Safety and Security Docket No. 9999-0003 License No. General
Enclosure:
Notice of Violation cc (w/encl):
State of Michigan Signed by Edwards, Rhex on 08/12/25
L. Palm 3
Letter to L. Palm from R. Edwards, dated August 12, 2025.
SUBJECT:
NRC NON-ROUTINE INSPECTION REPORT NO. 99990003/2025001(DRSS)
AND NOTICE OF VIOLATION-R.L. ADAMS PLASTICS, INC.
DISTRIBUTION w/encl:
Jack Giessner Mohammed Shuaibi Jared Heck Diana Betancourt-Roldan Geoffrey Edwards Jason Draper MIB Inspectors ADAMS Accession Number: ML25219A270 OFFICE RIII-DRSS RIII-EICS RIII-DRSS NAME LDresen:mh DBetancourt-Roldan REdwards DATE 08/07/2025 08/11/2025 08/12/2025 OFFICIAL RECORD COPY
Enclosure NOTICE OF VIOLATION R.L. Adams Plastics, Inc.
License No. General Licensee Wyoming, MI Docket No. 9999-0003 EA-25-0155 During an NRC in-office review conducted May 20, 2025, through July 29, 2025, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below:
Title 10 of the Code of Federal Regulations (CFR) 31.5(c)(8)(i) requires, in part, that any person who acquires, receives, possesses, uses or transfers byproduct material in a device pursuant to a general license shall, except as provided in 10 CFR 31.5(c)(9),
transfer or dispose of the device containing byproduct material only by transfer to persons holding a specific license pursuant to 10 CFR Parts 30 and 32 or from an Agreement State to receive the device.
Contrary to the above, before April 24, 2025, the license disposed of two Isolite SLX-60 exit signs with SN H56081 and SN H56088, each originally containing 7.59 Ci of hydrogen-3 byproduct material, and the disposal was not made to a person holding a specific license pursuant to 10 CFR Parts 30 and 32 or from an Agreement Sate to receive the device, and the exceptions in 10 CFR 31.5(c)(9) did not apply. Specifically, the devices are assumed to have been disposed of in a standard waste receptacle and subsequently transported to a local landfill for disposal.
This is a Severity Level IV violation (NRC Enforcement Policy Section 6.3).
The NRC has concluded that information regarding the reason for the violation, the corrective actions taken to correct the violation and prevent recurrence, and the date when full compliance was achieved, is already adequately addressed on the docket in this letter. However, you are required to submit a written statement or explanation pursuant to 10 CFR 2.201 if the description therein does not accurately reflect your corrective actions or your position. In that case, or if you choose to respond, clearly mark your response as a "Reply to a Notice of Violation, IR 99990003/2025-001(DRSS)" and send it to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001 with a copy to the Regional Administrator, Region III, within 30 days of the date of the letter transmitting this Notice.
If you choose to respond, your response will be made available electronically for public inspection in the NRC Public Document Room or from the NRC's Agencywide Documents Access and Management System (ADAMS), accessible from the NRC web site at http://www.nrc.gov/reading-rm/adams.html. Therefore, to the extent possible, the 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 contest this enforcement action, you should also provide a copy of your response, with the basis for your denial, to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001.
2 In accordance with 10 CFR 19.11, you may be required to post this Notice within two working days of receipt.
Dated this 12th day of August 2025.