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Skyview Testing, Inc., NRC Inspection Report 15000043/2018001, and Unresolved Item
	ML18109A565
Person / Time
Site:	15000043
Issue date:	05/01/2018
From:	Hay M; Division of Nuclear Materials Safety IV
To:	Mortensen J; SkyView Testing
	J. vonEhr
References
	IR 2018001
	Download: ML18109A565 (8)
	v • d • e

J. Mortens

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION IV

1600 E. LAMAR BLVD.

ARLINGTON, TX 76011-4511

May 1, 2018

Jared Mortensen

Radiation Safety Officer

Skyview Testing Inc.

4262 W 5600 S

Roy, Utah 84067

SUBJECT: NRC INSPECTION REPORT 150-00043/2018-001 AND UNRESOLVED ITEM

Dear Mr. Mortensen:

This letter refers to the unannounced inspection conducted by the U.S. Nuclear Regulatory

Commission, on April 4, 2018, at a temporary job site in Boise, Idaho. The inspection was

an examination of activities conducted under your general license, which was granted under

Title 10 of the Code of Federal Regulations (CFR) 150.20, Recognition of Agreement State

licenses, to ensure that activities were being performed in accordance with the NRC rules and

requirements and in a manner that ensured protection of public health and safety. Within these

areas, the inspection consisted of selected examination procedures and representative records,

observations of activities, and interviews with personnel. Skyview Testing Inc. was granted a

general license, as noted above, to conduct the same activities authorized under its State of

Utah license, in areas of exclusive Federal jurisdiction during Calendar Year 2018 for a period

not to exceed 180 days.

The inspector discussed the preliminary inspection findings with members of your staff at the

conclusion of the on-site portion of the inspection on April 4, 2018, and later with you on

April 5, 2018. A final telephonic exit briefing was conducted with you on April 18, 2018.

Based on the results of this inspection, the NRC identified one unresolved item regarding the

use of Direct Ion Storage dosimetry devices (Mirion Instadose) to satisfy the regulatory

requirements in 10 CFR Part 34 for personnel monitoring during radiographic operations. The

unresolved item is described in the enclosed Inspection Report. The NRC will continue to

review this unresolved item and you will be advised by separate correspondence of the results

of our deliberation on this matter. Please be advised that the number and characterization of

the issues described in the inspection report may change as a result of further NRC review.

Because this item remains under NRC review, you are not required to respond to this matter

at this time. However, if you choose to respond, and Security-Related Information is

necessary to provide an acceptable response, please mark your entire response Security-

Related Information in accordance with 10 CFR 2.390(d)(1) and follow the instructions for

withholding in 10 CFR 2.390(b)(1). In accordance with 10 CFR 2.390(b)(1)(ii), the NRC is

waiving the affidavit requirements for your response.

J. Mortensen 2

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, should you choose to provide one, 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. To the extent possible, your

response, should you choose to provide one, should not include any personal privacy or

proprietary information so that it can be made available to the Public without redaction.

Should you have any questions regarding this letter of the enclosed report, please contact

Jason vonEhr at 817-200-1186, or the undersigned at 817-200-1455

Sincerely,

/RA/

Michael C. Hay, Chief

Materials Licensing and Inspection Branch

Division of Nuclear Materials Safety

Docket: 150-00043

License: 10 CFR 150.20

Enclosure:

NRC Inspection Report 150-00043/2018-001

cc w/enclosure:

State of Idaho Radiation Program Director

State of Utah Radiation Program Director

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket: 150-00043

License: General License under 10 CFR 150.20

Report: 2018-001

EA No.: N/A

Licensee: Skyview Testing Inc.

Location Inspected: 8000 South Federal Way,

Boise, ID

Inspection Date: April 4, 2018

Exit Meeting Date: April 18, 2018

Inspector: Jason E. vonEhr, 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

Enclosure

EXECUTIVE SUMMARY

Skyview Testing Inc.

NRC Inspection Report No. 150-00043/2018-001

This was an unannounced inspection performed on April 4, 2018, with a State of Utah licensee

working under reciprocity at a temporary job site in Boise, Idaho. Skyview Testing Inc. is

authorized under a NRC general license, which was granted under Title 10 of the Code of

Federal Regulations (CFR) 150.20, Recognition of Agreement State licenses, to conduct the

same activities authorized under its State of Utah license in areas of exclusive Federal

jurisdiction during Calendar Year 2018 for a period not to exceed 180 days. The scope of the

inspection was limited to a review of the licensees implementation of its radiation safety

program and security program for the NRC licensed activities conducted at temporary job sites

in the NRC jurisdiction.

The inspection identified one unresolved item regarding the licensees use of Direct Ion Storage

dosimeter devices (Mirion Instadose) to satisfy the regulatory requirements of 10 CFR Part 34

for personnel monitoring during radiographic operations.

The unresolved item remains under NRC review.

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REPORT DETAILS

1. Program Overview (87121 & 87137)

1.1. Inspection Scope

This was an unannounced inspection of Skyview Testing Inc. The inspection

was performed at a temporary job site located at the Micron Plant in Boise, Idaho

at 8000 South Federal Way, on April 4, 2018. The licensee was authorized under a

NRC general license, which was granted under Title 10 of the Code of Federal

Regulations (CFR) 150.20, Recognition of Agreement State licenses, to conduct the

same activities authorized under its State of Utah license in areas of exclusive Federal

jurisdiction during Calendar Year 2018 for a period not to exceed 180 days. The State of

Utah license authorized the use of byproduct material for industrial radiography.

The licensees crew on the day of the inspection consisted of one radiographer and

two radiographers assistants, and utilized a single QSA 880 Delta radiography camera.

The scope of the inspection was limited to the NRC licensed activities occurring at the

temporary job site in Boise on April 5, 2018. The inspection consisted of interviews with

the radiography crew, a telephonic interview with the Radiation Safety Officer (RSO), a

selected examination of procedures and representative records, and observations of

industrial radiographic activities. The inspection also included a review of records and

activities related to the licensees compliance with access authorization and physical

security requirements in 10 CFR Part 37 for activities and personnel at the Boise, Idaho

temporary job site. No violations related to 10 CFR Part 37 were identified. One

inspection finding related to the NRCs health and safety requirements was identified as

an unresolved item and is discussed in Section 2.

2. Personnel Monitoring (87121)

2.1. Inspection Scope

On April 4, 2018, the inspector observed and reviewed the licensees use of personnel

monitoring devices at the Boise, Idaho temporary job site. The inspector interviewed the

on-site radiography crew and the RSO and examined a selection of representative

records related to the licensees use of personnel monitoring devices, which included

licensee procedures and records at the Boise, Idaho temporary job site.

2.2. Observations and Findings

Title 10 CFR 34.47(a) states, in part, that the licensee may not permit any individual to

act as a radiographer or a radiographers assistant unless, at all times during

radiographic operations, each individual wears, on the trunk of the body, a personnel

dosimeter that is processed and evaluated by an accredited National Voluntary

Laboratory Accreditation Program (NVLAP) processor.

The inspector found that the Skyview Testing Inc. radiographic crew at the Boise, Idaho

temporary job site did not utilize traditional Optically Stimulated Luminescence (OSL) or

Thermoluminescent Dosimeters (TLD), but were instead using another type of

dosimeter, called Direct Ion Storage (DIS) dosimeters. Specifically, these personnel

3

were using Mirion Instadose dosimeters. These dosimeters are designed such that the

individuals radiation exposure data from the dosimeter can be determined using a

software interface on a local computer rather than requiring that the dosimeter be

physically returned to a dosimetry processor to extract the data from the dosimeter. The

Skyview Testing Inc. personnel utilizing the Mirion Instadose dosimeters were based out

of the licensees facilities in Utah, and traveled to the Boise, Idaho temporary job site to

perform the NRC licensed activities.

The radiographic crew explained that each Instadose dosimeter was assigned to an

individual, and the dosimeters were read on a regular, usually monthly, basis. The

dosimeters are read by attaching the dosimeter to a USB port attached to the computer.

All readings are date and time stamped and maintained in each individuals dose history.

The radiation exposure data from the dosimeter was then used as the dose of record for

the monitored individuals. A self-diagnostic is performed on the dosimeter each time

that it is read and can identify errors or malfunctions.

At the conclusion of the onsite portion of the inspection, the inspector explained to the

radiographic crew and later to the RSO that the NRC was in the process of evaluating

DIS technology such as Mirion Instadose as it relates to compliance with the

requirements for personnel monitoring in 10 CFR Part 34. After this matter was

discussed with the RSO, the licensee decided that until the issue was resolved by the

NRC, traditional OSL or TLDs for dosimetry would be issued to any personnel who will

perform licensed activities in areas of the NRCs jurisdiction, such as Idaho. The use

of Mirion Instadose dosimeters relative to the NRCs regulatory requirements in

10 CFR Part 34 is an unresolved item, which remains under the NRC review.

2.3. Conclusions

The inspection identified one unresolved item regarding the licensees use of

DIS dosimeter devices (Mirion Instadose) to satisfy the regulatory requirements

in 10 CFR Part 34 for personnel monitoring during radiographic operations.

3. Exit Meeting Summary

The NRC inspector presented the preliminary inspection findings following the

conclusion of the onsite inspection on April 5, 2018. On April 18, 2018, a final telephonic

exit briefing that included a discussion of the unresolved item was conducted with

Mr. Jared Mortensen, RSO. The licensee acknowledged the findings and did not dispute

any of the details presented during the exit call.

4

SUPPLEMENTAL INSPECTION INFORMATION

PARTIAL LIST OF PERSONS CONTACTED

Jared Mortensen, Radiation Safety Officer

Matt Mueller, Radiographer

Wade Garn, Radiographers Assistant

Matt Corbett, Radiographers Assistant

Saul Revera, GBI (Skyview Testing Client) contact

INSPECTION PROCEDURES USED

87121 Industrial Radiography Programs

87137 10 CFR Part 37 Materials Security Programs

ITEMS OPENED, CLOSED, AND DISCUSSED

OPENED

None

CLOSED

None

DISCUSSED

150-00043/2018-001 Unresolved Item The use of Direct Ion Storage

Devices (Mirion Instadose) relative

to 10 CFR Part 34 is an unresolved

item, which remains under NRC

review.

LIST OF ACRONYMS AND ABBREVIATIONS USED

ADAMS Agencywide Document Access and Management System

CFR Code of Federal Regulations

DIS Direct Ion Storage

NRC Nuclear Regulatory Commission

NVLAP National Voluntary Laboratory Accreditation Program

OSL Optically Stimulated Luminescence

TLD Thermoluminescent dosimeter

RSO Radiation Safety Officer

ML18109A565

SUNSI Review ADAMS: Non-Publicly Available Non-Sensitive Keyword:

By: JEV Yes No Publicly Available Sensitive NRC-002

OFFICE DNMS:MLIB DNMS:C:MLIB

NAME JEvonEhr MCHay

SIGNATURE /RA/ /RA/

DATE 04/19/18 05/01/18