ML18235A265
| ML18235A265 | |
| Person / Time | |
|---|---|
| Site: | 15000012 |
| Issue date: | 08/21/2018 |
| From: | Mankowski R, Meilman S Environmental Protection Industries |
| To: | Christine Lipa NRC/RGN-III |
| References | |
| EA-18-099 | |
| Download: ML18235A265 (3) | |
See also: IR 05000012/2018002
Text
ENVIRONMENTAL
PROTECTION
INDUSTRIES
August 21, 2018 Ms. Christine
A. Lipa, Acting Director Division of Nuclear Materials
Safety US NRC -Region III 2443 Warrenville
Road, Suite 210 Lisle, Illinois 60532 RE: Response to the Apparent Violation
in Report No. 15999912/2018(DNMS)
NRC Special Inspection
Report EA-18-009 Dear Ms. Lipa: Environmental
Protection
Industries (EPI) respectfully
submits this letter to document Corre ctive Actions and steps taken for the above referenced
Violation
of Title 10 CFR 150.20(b)(l).
Correc ti ve Actions we re taken immediately
upon notification
on Thursday, July 5 , 2018 , and EPI suspended
work (utilizing
a nuclear density gauge) in Indiana. EPI has not resumed any operations
involving
the use of a nuclear density gauge in the State of Indiana , and will not unt i l this matter is fully resolved.
The NRC Special Inspection
Report was posted outside of t he secure storage area a nd on the Employee Notice Board in the EPI l unch room o n the da y the NRC Special Inspection
Report was received. The reason for the violation , corrective
actions and compliance
date are outlined below. 1 Reason for Appar ent Violation
At the time of the Violation, EPI was unaware that Indiana is a " Non-Agreement
State." EPI was under an erroneous
assumption
that due to the licensure
from the State of Illinois , our actions fall under an umbrella of IEMA. 2 Corrective
Actions Use of the Nuclear Density Gauge in Indiana was suspended
immediately
upon notification
of the Title 10 CFR 150.20(b)(l) regulations
and violation, as per NRC phone call on Thursday, July 5;2018. EPI immediately
filed NRC Form 241 (July 9, 2018) for cale ndar year 2018 , which was hand-delivered
to NRC's office on Monday, July 9, 2018, along with an appropriate
fee for the above. EPI provided the NRC with all date s and locations
of unauthorized
portable nuclear density gauge use in Indiana in 2018. This information
was e-mailed to NRC on Monday, July 9 , 2018. EPI has identified
all nearby Non-Agreement
Sta tes, and the EPI RSO has researched , reviewed and studied the applicable
Title 10 Regulations
and Reciprocity.
E PI realizes that the noted form and fee are only applicable
to calendar year 2018. A new form will be filed , as necessary, in 2019. 3 Corrective
Steps The Corrective
Actions taken will prevent future violations. EPI realizes its mistake in licensure
agreement
assumption
w i th different
States. EPI had four telephone
conversations
with NRC representative, at which time our corrective
actions were outlined. En v ironmenta l Engineering
- A s sessment * Remediation
- Brownfield
Redevelopment
- Construction
Management
Corporate
Office 16650 South Cana l * South Holland , I L 60473 * tx 1.800.526.1788 * fax 1.708.225.1117 * office 1.708.225.1115 website: www.envlronmental-epi.com
E N V I RON ME NTA L PROTECTION
INDUSTRIES
4 Compliance
Date Monday, July 9, 2018. EPI apologizes
for any inconvenience
that our actions may have caused, and assures NRC that this will not happen aga in. Should you have any question, please do not hesitate to contact us. o eilman, PE, RSO irector of Operations
Vice President-Technical
Services Environmenta
l Engineering
- Assessment
- Remediation
- Brownfield
Redevelopment
- Construction
Management
Corporate
Office 16650 South Cana l * South Holland , IL 60473 * tx 1.800.526.1788 * fax 1.708.225.11 1 7 * office 1.708.225.1115 website: www.environmental-epi.com
R3 Reciprocity
From: Sent: Sergio Meilman <smeilman@environmental-ep
i.com> Wednesday, August 22 , 2018 1 :27 PM To: R3 Reciprocity
Cc: 'Robert Mankowski';
'Michael Musa' Subject: [External_Sender
] Environmental
Protection
Industries
-NRG Special Inspections
I nspection
report Attachments:
scanner@environmental-epi.com_20
1 80822_ 121250: pdf Dear Ms. Lipa and Mr. O'Dowd: As per our conversation, enclosed please find a letter of explanation
of an apparent violation. EPI deeply regrets this non-compliance.
Corrective
actions had been implemented
immediately
upon NRC's notification , and were discussed
in detail with NRC's representative.
EPI is l ooking forward to a full resolution
of this matter. Thank you again -please feel free to call me anytime if you have additional
questions
or comments. Thank you again Sergio Meilman, P.E., Ph.D., RSO Director of Operations
Environmental
Protection
Industries
16650 S Canal Street South Holland, IL 60473 Phone: 708-225-1115
Fax: 708-225-1117
Cell: 312-354-0627
smeilman@environmental-epi
.com www.environmental-epi.com
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