IR 015000042/2018003
| ML18192B107 | |
| Person / Time | |
|---|---|
| Site: | 15000042, 015000042 |
| Issue date: | 07/17/2018 |
| From: | Hay M Division of Nuclear Materials Safety IV |
| To: | Martinez V BRL NDT Consultants |
| References | |
| IR 2018003 | |
| Download: ML18192B107 (8) | |
Text
July 17, 2018
SUBJECT:
NRC INSPECTION REPORT 150-00042/2018-003
Dear Mr. Martinez:
This letter refers to an unannounced inspection conducted on May 4, 2018, at a temporary job site on Lackland Air Force Base in San Antonio, Texas. The purpose of the inspection was to examine activities performed under a U.S. Nuclear Regulatory Commission (NRC) general license, which was granted under Title 10 of the Code of Federal Regulations (10 CFR) 150.20, Recognition of Agreement State Licenses, to ensure that activities were performed in accordance with NRC requirements.
BRL NDT Consultants, Inc. (BRL) was granted a general license to conduct the same activities authorized under its State of Texas license, in areas of exclusive Federal jurisdiction during calendar year 2018. Within these areas, the inspection consisted of examinations of selected procedures and representative records, observations of licensed activities, independent radiation measurements, and interviews with personnel. A preliminary exit briefing was conducted with you at the conclusion of the onsite inspection on May 4, 2018. A final exit briefing was conducted telephonically with you on June 29, 2018. The enclosed report presents the results of this inspection. Within the scope of this inspection, no violations were identified.
The NRC determined that the licensee is monitoring personnel radiation dose by the use of direct ion storage dosimetry and that the licensee has met the criteria in NRC Enforcement Guidance Memorandum 18-001, Interim Guidance for Dispositioning Apparent Violations of 10 CFR Parts 34, 36 and 39 Requirements Resulting from the use of Direct Ion Storage Dosimetry During Licensed Activities, dated May 11, 2018, for the use of direct ion storage dosimetry (EA-18-083).
In accordance with 10 CFR 2.390 of the NRCs Agency Rules of Practice and Procedure, a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the NRCs Agencywide Document Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. Should you have any questions regarding this letter or the enclosed report, please contact Mr. James Thompson at 817-200-1538, or the undersigned at 817-200-1455.
Sincerely,
/RA/
Michael C. Hay, Chief
Materials Licensing and Inspection Branch
Division of Nuclear Materials Safety
Docket: 150-00042 License: 10 CFR 150.20
Enclosure:
NRC Inspection Report 150-00042/2018-003
REGION IV==
Docket:
150-00042
License:
Report:
2018-003
Licensee:
BRL NDT Consultants, Inc.
Location Inspected:
Temporary job site
Lackland Air Force Base San Antonio, Texas
Inspection Date:
May 4, 2018
Exit Meeting Date:
June 29, 2018 (telephonic)
Inspector:
James L. Thompson, Senior Health Physicist
Materials Licensing and Inspection Branch Division of Nuclear Materials Safety
Approved By:
Michael C. Hay, Chief Materials Licensing and Inspection Branch Division of Nuclear Materials Safety
Attachment:
Supplemental Inspection Information
EXECUTIVE SUMMARY
BRL NDT Consultants, Inc.
NRC Inspection Report No. 150-00042/2018-003
This was an inspection of a State of Texas licensee working under reciprocal recognition under a general license pursuant to 10 CFR 150.20, at a temporary job site at Lackland Air Force Base. The inspection included a review of the records and activities at this temporary job site in NRC jurisdiction, as well as observation of licensed activities and interviews with personnel present at the temporary job site. This report describes the results of the inspection.
The NRC determined that the licensee is monitoring personnel radiation dose by the use of direct ion storage dosimetry and that the licensee has met the criteria in NRC Enforcement Guidance Memorandum 18-001, Interim Guidance for Dispositioning Apparent Violations of 10 CFR Parts 34, 36 and 39 Requirements Resulting from the use of Direct Ion Storage Dosimetry During Licensed Activities, dated May 11, 2018, for the use of direct ion storage dosimetry (EA-18-083).
No violations were identified during this temporary job site inspection.
REPORT DETAILS
Program Overview (87121)
1.1.
Inspection Scope
This was an inspection of a State of Texas licensee working under reciprocal recognition under a general license pursuant to 10 CFR 150.20, at a temporary job site at Lackland Air Force Base (AFB). BRL NDT Services, Inc. (BRL) is authorized by State of Texas License L06860 to use byproduct material for industrial radiography in the State of Texas, and a general license pursuant to 10 CFR 150.20 to perform the same activities in areas of NRC jurisdiction. The general licensee was conducting industrial radiographic operations at the Lackland AFB fuel tank farm using iridium-192.
The NRC inspector used Inspection Procedure 87121, Industrial Radiography Programs.
The inspection was limited to the observation of licensed activities and review of required documentation at temporary job sites.
Personnel Monitoring (87121)
2.1.
Inspection Scope
On May 4, 2018, the inspector reviewed the licensees use of personnel monitoring devices while performing industrial radiography at Lackland AFB. The inspector conducted interviews with the radiographer and assistant radiographer regarding the use of required dosimetry at the temporary job site, and inspected the functionality of alarming rate meters and pocket dosimeters by visual inspection.
2.2.
Observations and Findings
The BRLs lead radiographer, who was also the radiation safety officer, stated that they had been using direct ion storage (DIS) dosimeters since receiving their license from the State of Texas in June 2017, and that the DIS dosimeters are approved for use in the State of Texas where BRL obtained their license. The inspector reviewed the licensees compliance with personnel dosimetry requirements under 10 CFR 34.47 and determined that the licensee is using DIS dosimetry designed for remote data evaluation to meet this requirement. The inspector reviewed the conditions described in NRC Enforcement Guidance Memorandum (EGM) 18-001, Interim Guidance for Dispositioning Apparent Violations of 10 CFR Parts 34, 36 and 39 Requirements Resulting from the use of Direct Ion Storage Dosimetry During Licensed Activities, dated May 11, 2018 (EA-18-083).
The inspector determined that: (1) the DIS dosimeters are being provided and dose data evaluated and reported for the dose of record by a National Voluntary Laboratory Accreditation Program (NVLAP) accredited processor; (2) the licensee and NVLAP processor have implemented specified quality controls to ensure that the dosimeter is calibrated and/or replaced appropriately; and (3) the licensee has maintained the necessary documentation and records to demonstrate that the criteria of EGM-18-001 are being implemented.
Future inspections will review and determine whether the criteria of EGM-18-001 continue to be met. If the NRC identifies that DIS dosimetry arrangements do not meet
the criteria of EGM-18-001, a violation of 10 CFR 34.47(a) and (a)(3) will be considered.
Such reviews will continue for as long as EGM-18-001 criteria remain in effect.
2.3.
Conclusions
The inspector reviewed the licensees use of DIS dosimeters and observed no violations in this additional areas.
Other Areas Inspected (87121)
3.1.
Inspection Scope
On May 4, 2018, the inspector performed an inspection of a reciprocity licensees performance of industrial radiographic operations at a temporary job site at Lackland AFB. The inspection included observations of ongoing licensed activities, interviews of the radiographer and radiographers assistant present at the job site, and a review of the daily radiation report and other records required to be maintained at temporary job sites.
3.2.
Observations and Findings
On the day of inspection, BRL was operating on a fuel tank farm on Lackland AFB, performing nondestructive testing with a radiography camera containing 91 curies of iridium-192. The radiography crew included a radiographer, who was also the companys President and radiation safety officer.
The licensed material was in the possession and direct observation of the radiography crew at all times during the inspection. The BRLs main office was approximately 10 minutes away from this temporary job site, in the Agreement State of Texas (San Antonio). The inspector reviewed BRLs daily radiation report, which had been partially filled out that morning, and it contained information such as beginning pocket dosimeter readings, area radiation survey of the restricted area, and the radiographers and assistants dosimetry and survey meter calibrations.
The radiographers had two survey meters, and both had been calibrated within the past 6 months. Their pocket dosimeters had been recharged at the beginning of the work shift, and their alarming rate meters were functional, as demonstrated to the inspector by the radiographers. Additionally, the radiographers used the survey meters to perform a radiation survey after each exposure, as required.
3.3.
Conclusions
The inspector reviewed various areas of the licensees radiation safety program at the temporary job site, and observed no violations in these additional areas.
Exit Meeting Summary
The NRC inspector presented the preliminary inspection findings at the conclusion of the onsite inspection on May 4, 2018, with the radiation safety officer, to include a discussion regarding their personal dosimeters. A final telephonic exit briefing was held with the President/radiation safety officer on June 29, 2018. The licensee acknowledged the findings and did not dispute any of the details presented during the exit call.
Attachment SUPPLEMENTAL INSPECTION INFORMATION
PARTIAL LIST OF PERSONS CONTACTED
Virgil Martinez, President and Radiation Safety Officer Chris Volker, Radiographers Assistant
INSPECTION PROCEDURES USED
87121 Industrial Radiography Programs
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened/Closed
None
Discussed
None
LIST OF ACRONYMS AND ABBREVIATIONS USED
ADAMS Agencywide Document Access and Management System CFR
Code of Federal Regulations NRC
Nuclear Regulatory Commission NVLAP National Voluntary Laboratory Accreditation Program VIO
Violation DIS
Direct Ion Storage