ML18198A420
| ML18198A420 | |
| Person / Time | |
|---|---|
| Site: | 15000042 |
| Issue date: | 07/17/2018 |
| From: | Hay M Division of Nuclear Materials Safety IV |
| To: | Manahan E NQS Inspection, LTD |
| References | |
| EA-18-087 IR 2018001 | |
| Download: ML18198A420 (10) | |
See also: IR 015000042/2018001
Text
July 17, 2018
Mr. Eric Manahan
President
NQS Inspection, Ltd.
730B Diamond Cut Rd
Corpus Christi, TX 78409
SUBJECT: NOTICE OF VIOLATION AND NRC INSPECTION REPORT 150-00042/2018-001
Dear Mr. Manahan:
This letter refers to an unannounced inspection conducted on May 23, 2018, at a temporary job
site at the Naval Air Station - Corpus Christi, Corpus Christi, Texas. The purpose of the
inspection was to examine activities performed under a U.S. Nuclear Regulatory Commissions
(NRCs) 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.
NQS Inspection, Ltd. (NQS) 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 your staff at the conclusion of the onsite inspection on May 23, 2018. A final exit
briefing was conducted telephonically with you on June 29, 2018. The enclosed report presents
the results of this inspection.
Based on the results of this inspection, the NRC has determined that one violation of NRC
requirements occurred. The violation was evaluated in accordance with the NRC Enforcement
Policy, which can be found on the NRCs Web site at www.nrc.gov/about-
nrc/regulatory/enforcement/enforce-pol.html. The violation involved the failure to conspicuously
post all areas in which industrial radiography is performed, as required by 10 CFR 34.53,
Posting, and 10 CFR 20.1902(b), Posting of high radiation areas. This violation is
categorized as a Severity Level IV violation in accordance with the NRC Enforcement Policy
and is cited and described in the enclosed Notice of Violation (Notice). The violation is being
cited in the enclosed Notice because it was identified by the NRC during the inspection.
The NRC has concluded that information regarding: (1) the reason for the violation, (2) the
corrective actions that have been taken and the results achieved, and (3) the date when full
compliance will be achieved was adequately addressed during the inspection. Therefore, you
are not required to respond to this letter unless the description herein does not accurately reflect
E. Manahan 2
your corrective actions or your position. In that case, or if you choose to provide additional
information, you should follow the instructions specified in the enclosed Notice.
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-18-087).
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice and Procedure, a copy of
this letter, its enclosures, and your response, if you choose to provide one, 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. 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.
Should you have any questions regarding this letter or the enclosed report, please contact
Ms. Latischa Hanson at 817-200-1286, 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
Enclosures:
1. Notice of Violation
2. NRC Inspection
Report 150-00042/2018-001
cc w/enclosures:
C. Sullivan, Manager
State of Texas Radiation Control Program
E. Manahan 3
NOTICE OF VIOLATION AND NRC INSPECTION REPORT 150-00042/2018-001 - DATED
July 17, 2018.
DISTRIBUTION:
S. Morris
T. Pruett
L. Howell
R4DNMS_MLIB
R. Erickson
B. Tharakan
S:\DNMS\Lynn DOC\IR NOV NQS Ltd.docx
ADAMS ACCESSION NUMBER: ML18198A420
SUNSI Review: ADAMS: Non-Publicly Available Non-Sensitive Keyword:
By: LMH Yes No Publicly Available Sensitive
OFFICE SHP:MLIB TL:ACES C:MLIB
NAME LMHanson GMVasquez MCHay
SIGNATURE /RA/ /RA/ /RA/
DATE 6/29/18 7/2/18 7/17/18
OFFICAL RECORD COPY
NOTICE OF VIOLATION
NQS Inspection, Ltd. Docket: 150-00042
Corpus Christi, Texas License: 10 CFR 150.20
During an NRC inspection conducted on May 23, 2018, one violation of NRC requirements was
identified. In accordance with the NRC Enforcement Policy, the violation is listed below:
10 CFR 34.53 requires, in part, that all areas in which industrial radiography is being
performed be conspicuously posted as required by 10 CFR 20.1902.
10 CFR 20.1902(b) requires, in part, that the licensee shall post each high radiation area
with a conspicuous sign or signs bearing the radiation symbol and the words CAUTION,
HIGH RADIATION AREA, or DANGER, HIGH RADIATION AREA.
Contrary to the above, on May 23, 2018, during industrial radiography performed at a
temporary job site at the Naval Air Station - Corpus Christi, the licensee failed to post a
high radiation area with a conspicuous sign or signs bearing the radiation symbol and
the words CAUTION, HIGH RADIATION AREA or DANGER, HIGH RADIATION
AREA.
This is a Severity Level IV Violation (Section 6.7.d).
The NRC has concluded that information regarding: (1) the reason for the violation, (2) the
corrective actions that have been taken and the results achieved, and (3) the date when full
compliance will be achieved is already adequately addressed on the docket in Inspection Report
No. 150-00042/2018-001. 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, (EA-18-087), 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, U.S. Nuclear Regulatory Commission, Region IV, 1600 E.
Lamar Blvd., Arlington, TX 76011-4511, within 30 days of the date of the letter transmitting this
Notice of Violation (Notice).
If you choose to respond, your response will be made available electronically for public
inspection in the NRC Public Document Room or in the NRCs 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.
In accordance with 10 CFR 19.11, you may be required to post this Notice within two working
days of receipt.
Dated this 17th day of July 2018
Enclosure 1
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket: 150-00042
License: 10 CFR 150.20
Report: 2018-001
Licensee: NQS Inspection, Ltd.
Location Inspected: Temporary Job Site
Naval Air Station - Corpus Christi (NASCC)
Corpus Christi, Texas
Inspection Date: May 23, 2018
Exit Meeting Date: June 29, 2018 (telephonic)
Inspector: Latischa M. Hanson, 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 2
EXECUTIVE SUMMARY
NQS Inspection, Ltd.
NRC Inspection Report No. 150-00042/2018-001
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 the Naval Air Station -
Corpus Christi. 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.
During the inspection, the inspector identified a violation regarding the licensees failure to
conspicuously post all areas in which industrial radiography is performed, as required by
10 CFR 20.1902(b), Posting of high radiation areas, in accordance with the regulatory
requirements in 10 CFR 34.53, Posting.
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-18-087).
No other violations were identified during this temporary job site inspection.
2
REPORT DETAILS
1 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 the Naval
Air Station - Corpus Christi (NASCC). NQS Inspection, Ltd. (NQS) is authorized by
State of Texas License L06262 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 NASCC Tank 2 using iridium-192 in a SPEC
150 radiography camera.
The inspector used Inspection Procedure 87121, Industrial Radiography Programs, to
perform the inspection. The inspection was limited to the observation of licensed
activities and review of required documentation at temporary job sites.
2 Personnel Monitoring (87121)
2.1. Inspection Scope
On May 23, 2018, the inspector reviewed the licensees use of personnel monitoring
devices while performing industrial radiography at NASCC. The inspector conducted
interviews with the radiographer, assistant radiographer, and the onsite
trainer/operations manager 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 NQS radiographer described the days initial temporary job site radiography set up,
inclusive of the posting of the radiation areas, in accordance with the regulatory
requirements of 10 CFR Part 34 and the licensees operating and emergency
procedures.
Title 10 CFR 34.53 requires, in part, that all areas in which industrial radiography is
being performed be conspicuously posted as required by 10 CFR 20.1902.
Title 10 CFR 20.1902(b) requires, in part, that the licensee shall post each high radiation
area with a conspicuous sign or signs bearing the radiation symbol and the words
CAUTION, HIGH RADIATION AREA, or DANGER, HIGH RADIATION AREA.
Contrary to the above, the licensees radiography crew failed to post a high radiation
area created during radiographic operations. Following the inspector identifying the
violation and conducting discussions with the licensees staff regarding the regulatory
requirements and the licensees operating and emergency procedures, the licensee
implemented immediate corrective actions. The licensees immediate corrective actions
entailed stopping operations until the licensees radiation safety officer brought the
appropriate postings out to the temporary job location. Additionally, the licensee stated
3
all staff will be immediately re-trained on the licensees operating and emergency
procedures. (150-00042/2018-001-01)
The inspector noted during the inspection that the radiographers were using direct ion
storage (DIS) dosimeters to monitor their occupational radiation exposure. 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-18-087).
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
Based on the results of this inspection, the inspector determined that a violation of NRC
requirements occurred. The inspector identified that the violation involved the failure to
conspicuously post high radiation areas in which industrial radiography is performed as
required by 10 CFR 20.1902(b), Posting of high radiation areas. This violation is
categorized as a Severity Level IV violation in accordance with the NRC Enforcement
Policy, Section 6.7.d.
3 Other Areas Inspected (87121)
3.1. Inspection Scope
On May 23, 2018, the inspector performed an inspection of a reciprocity licensees
performance of industrial radiographic operations at a temporary job site at NASCC.
The inspection included observations of ongoing licensed activities, interviews of the
radiographer, radiographers assistant, and the trainer/operations manager present at
the job site, and a review of the records required to be maintained at temporary job sites.
3.2. Observations and Findings
On the day of inspection, NQS was conducting radiography inside a tank located in an
enclosed and gated-access area at NASCC. The licensee was performing
nondestructive testing using a SPEC 150 radiography camera (serial number 1376)
containing 70 curies of iridium-192. The radiography crew included a radiographer, a
radiographers assistant, and a trainer/operations manager that provided direct, visual
4
surveillance of the work area. The licensed material was in the possession and direct
observation of the radiography crew at all times during the inspection.
NQSs main office was approximately 15 minutes away from this temporary job site, in
the Agreement State of Texas (Corpus Christi). The inspector reviewed NQSs Daily
Radiation Survey, Dosimeter, and Source Utilization Report that had been partially filled
out that morning, which contained information, such as personnel monitoring, individual
pocket dosimeter readings and calibrations, equipment description, survey meter
calibrations, daily equipment inspection, rate alarm checks, and the radiographers
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.
4 Exit Meeting Summary
The NRC inspector presented the preliminary inspection finding at the conclusion of the
onsite inspection on May 23, 2018, with the staff and the RSO. A final telephonic exit
briefing was held with the President and the 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.
5
SUPPLEMENTAL INSPECTION INFORMATION
PARTIAL LIST OF PERSONS CONTACTED
Eric Manahan, President
Ricardo Morano, Radiation Safety Officer/Trainer
Saul Avila, Radiographer Trainer
Enrique Salinas, Radiographers Assistant
Tom Ward, Trainer/Operations Manager
Lieutenant Cori Wallace, Construction Manager, NASCC
Michael Pond, Safety, Pond
Keith Wilson, Goshawk, LLC
INSPECTION PROCEDURES USED
87121 Industrial Radiography Programs
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
150-00042/2018-001-01 VIO Failure to conspicuously post a high
radiation area
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
Attachment