ML18198A239
| ML18198A239 | |
| Person / Time | |
|---|---|
| Site: | 15000017 |
| Issue date: | 07/17/2018 |
| From: | Troy Pruett Division of Nuclear Materials Safety IV |
| To: | Boudreaux D The NACHER Corporation |
| References | |
| EA-18-050 IR 2018001 | |
| Download: ML18198A239 (14) | |
See also: IR 015000017/2018001
Text
July 17, 2018
David J. Boudreaux
Radiation Safety Officer
The NACHER Corporation
108 Lois Road
Houma, Louisiana 70363
SUBJECT: NOTICE OF VIOLATION AND NRC INSPECTION REPORT 150-00017/2018-001
Dear Mr. Boudreaux:
This letter refers to the announced U.S. Nuclear Regulatory Commission (NRC) inspection
conducted on April 24, 2018, at your facility located in Houma, Louisiana. The inspection was
conducted in response to an event notification report (Event 53306) involving the malfunction of
a radiography exposure device, and the subsequent actions taken by two radiographers who
were not properly trained to perform source recovery activities.
The inspection focused on understanding the facts and corrective actions relative to the event,
to conduct interviews with involved personnel, perform time and motion studies related to the
doses received by those personnel, independently assess those dose estimates, and to review
and assess adherence to your Agreement State license conditions and procedures. The
enclosed report presents the results of this inspection. The inspector discussed the preliminary
inspection findings with you at the conclusion of the on-site portion of the inspection. A final exit
briefing was conducted with you on June 21, 2018.
Based on the results of this inspection, two apparent violations have been identified and are
being considered for escalated enforcement in accordance with the NRCs Enforcement Policy.
The current Enforcement Policy is included on the NRCs Web site at http://www.nrc.gov/about-
nrc/regulatory/enforcement/enforce-pol.html. The apparent violations involved: (1) the failure to
conduct an adequate equipment check, as required by Title 10 of the Code of Federal
Regulations (10 CFR) 34.31(a), which resulted in a radiography device guide tube disconnect
and an unshielded 77 curie iridium-192 source being stuck out of the exposure device; and (2)
the failure to follow emergency procedures, as required by 10 CFR 150.20(b)(5), resulting in a
hazardous source recovery operation by untrained individuals. The circumstances surrounding
the apparent violations, the significance of the issues, and the need for lasting and effective
corrective actions were discussed with you at the inspection exit meeting.
Since your facility has not been the subject of escalated enforcement actions within the last two
inspections, and based on our understanding of your corrective actions, a civil penalty may not
be warranted in accordance with Section 2.3.4 of the Enforcement Policy. The final decision will
be based on you confirming on the license docket that the corrective actions previously
described to the NRC staff have been or are being taken.
D. Boudreaux 2
Before the NRC makes its enforcement decision, we are providing you an opportunity to:
(1) respond, in writing, to the apparent violations addressed in this inspection report within
30 days of the date of this letter; or (2) request a predecisional enforcement conference (PEC).
If a PEC is held, it will be open for public observation and the NRC may issue a press release to
announce the time and date of the conference. If you decide to participate in a PEC please
contact Mr. Michael C. Hay, Chief, Materials Licensing and Inspection Branch, at 817-200-1455,
within 10 days of the date of this letter to notify us of your intentions. A PEC should be held
within 30 days of the date of this letter.
If you choose to provide a written response, it should be clearly marked as a Response to
Apparent Violations in NRC Inspection Report 150-00017/2018-001; EA-18-050 and should
include for each of the apparent violations: (1) the reason for the apparent violation or, if
contested, the basis for disputing the apparent violation; (2) the corrective steps that have been
taken and the results achieved; (3) the corrective steps that will be taken; and (4) the date when
full compliance will be achieved.
Your written response to the apparent violations may reference or include previously docketed
correspondence, if the correspondence adequately addresses the required response. Your
response should be sent to the U.S. Nuclear Regulatory Commission, ATTN: Document
Control Desk, Washington, DC 20555-0001, with a copy mailed to Mr. Troy Pruett, Director,
Division of Nuclear Materials Safety, U.S. Nuclear Regulatory Commission, Region IV,
1600 East Lamar Blvd., Arlington, TX 76011-4511 within 30 days of the date of this letter. If an
adequate response is not received within the time specified and an extension of time has not
been granted, the NRC will proceed with its enforcement decision or schedule a PEC.
If you choose to request a PEC, the conference will afford you the opportunity to provide your
perspective on these matters and any other information that you believe the NRC should take
into consideration before making an enforcement decision. The decision to hold a PEC does
not mean that the NRC has determined that a violation has occurred or that enforcement action
will be taken. The conference would be conducted to obtain information to assist the NRC in
making an enforcement decision. The topics discussed during the conference may include
information to determine whether a violation occurred, information to determine the significance
of a violation, information related to the identification of a violation, and information related to
any corrective actions taken or planned.
In presenting your corrective actions, you should be aware that the promptness and
comprehensiveness of your actions will be considered in assessing any civil penalty for the
apparent violations. The guidance in NRC Information Notice 96-28, Suggested Guidance
Relating to Development and Implementation of Corrective Action, may be helpful. You can
find an updated excerpt from NRC Information Notice 96-28 on the NRC Web site at
http://www.nrc.gov/docs/ML0612/ML061240509.pdf.
Please be advised that the number and characterization of the apparent violations described in
the enclosed report may change as a result of further NRC review. You will be advised by
separate correspondence of the results of our deliberations on this matter.
In addition, based on the results of this inspection, the NRC has determined that a Severity
Level IV violation of NRC requirements occurred. The violation was evaluated in accordance
with the NRC Enforcement Policy, and is cited in the Notice of Violation (Notice) included in
Enclosure 1 and the circumstances surrounding it are described in detail in the subject
inspection report. The violation is being cited because it was identified by the NRC during the
D. Boudreaux 3
inspection and it involved the failure to assign a deep-dose equivalent for the part of the body
receiving the highest exposure. You are required to respond to the Notice in Enclosure 1 and
should follow the instructions specified in the Notice when preparing your response. If you have
additional information that you believe the NRC should consider, you may provide it in your
response to the Notice. The NRC will use your response, in part, to determine whether further
enforcement action is necessary to ensure compliance with regulatory requirements.
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 (EA-18-050).
In accordance with 10 CFR 2.390, of the NRCs Agency Rules of Practice and Procedure, a
copy of this letter, its enclosures, and 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.
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. If personal privacy
or proprietary information is necessary to provide an acceptable response, please provide a
bracketed copy of your response that identifies the information that should be protected and a
redacted copy of your response that deletes such information. If you request withholding of
such information, you must specifically identify the portions of your response that you seek to
have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the
disclosure of information will create an unwarranted invasion of personal privacy or provide the
information required by 10 CFR 2.390(b) to support a request for withholding confidential
commercial or financial information).
If you have any questions concerning this matter, please contact Mr. Michael C. Hay of my staff
at 817-200-1455.
Sincerely,
/RA/
Troy Pruett, Director
Division of Nuclear Materials Safety
Docket: 150-00017
License: 10 CFR 150.20
Enclosures:
1. Notice of Violation
2. NRC Inspection Report 150-00017/2018-001
cc w/Enclosures:
Jeff Dauzat, Administrator
State of Louisiana Radiation Control Program
D. Boudreaux 4
NOTICE OF VIOLATION AND NRC INSPECTION REPORT 150-00017/2018-001 DATED
JULY 17, 2018
DISTRIBUTION:
RidsOeMailCenter Resource; RidsNmssOd Resource; RidsOgcMailCenter Resource;
RidsSecyMailCenter Resource; RidsOcaMailCenter Resource; RidsOigMailCenter Resource;
RidsEdoMailCenter Resource; EDO_Managers; RidsOcfoMailCenter Resource;
RidsOiMailCenter Resource; RidsRgn1MailCenter Resource; RidsRgn3MailCenter Resource;
RidsNsirOd Resource; R4DNMS_MLIB; DCylkowski, ORA
KKennedy, RA BMaier, ORA ABoland, OE
SMorris, DRA MHay, DNMS FPeduzzi, OE
TPruett, DNMS JKramer, ORA RSun, NMSS
CAlldredge, ORA LSreenivas, OE SHoliday, OE
KNorman, OE LHowell, DNMS JWeaver, ORA
RErickson, DNMS VDricks, ORA BTharakan, DNMS
JBowen, OEDO JWeil, CA MVasquez, ORA
MLayton, NSIR AMoreno, CA MHerrera, DRMA
S:\RAS\ACES\ENFORCEMENT\_EA CASES - OPEN\NACHER EA-18-050\CHLTR_EA-18-050_NACHER.docx
ADAMS ACCESSION NUMBER: ML18198A239
SUNSI Review: ADAMS: Non-Publicly Available Non-Sensitive Keyword:
By: JCD Yes No Publicly Available Sensitive
OFFICE HP:MLIB C:MLIB TL:ACES RC D:DNMS
NAME JDykert MHay GVasquez DCylkowski TPruett
SIGNATURE /RA/ /RA/ /RA/ /RA/ /RA/
DATE 7/17/18 7/17/18 07/12/18 07/16/18 7/17/18
OFFICAL RECORD COPY
NOTICE OF VIOLATION
The NACHER Corporation Docket No. 150-00017
Houma, Louisiana License No. 10 CFR 150.20
During an NRC inspection conducted on April 24, 2018, one violation of NRC requirements was
identified. In accordance with the NRC Enforcement Policy, the violation is listed below:
10 CFR 20.1201(c) requires, in part, that the assigned deep-dose equivalent must be for
the part of the body receiving the highest exposure. The deep-dose equivalent may be
assessed from surveys or other radiation measurements for the purpose of
demonstrating compliance with the occupational dose limits, if the individual monitoring
device was not in the region of highest potential exposure.
Contrary to the above, from March 31 through May 10, 2018, the licensee failed to
assign a deep-dose equivalent for the part of the body receiving the highest exposure.
The deep-dose equivalent was not assessed from surveys or other radiation
measurements for the purpose of demonstrating compliance with the occupational dose
limits when the individual monitoring device was not worn in the region of highest
potential exposure. Specifically, a radiographers dose monitoring device was worn near
the individuals hip during a source recovery operation; however, the individuals chest
and arm to the elbow were in the region of highest potential exposure and the licensee
failed to assign a deep-dose equivalent for those parts of the body.
This is a Severity Level IV violation (NRC Enforcement Policy Section 6.3.d).
Pursuant to the provisions of 10 CFR 2.201, The NACHER Corporation is hereby required to
submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001, with a copy to the Regional
Administrator, Region IV, 1600 E. Lamar Blvd. Arlington, Texas 76011, within 30 days of the
date of the letter transmitting this Notice of Violation (Notice).
This reply should be clearly marked as a Reply to a Notice of Violation; EA-18-050 and should
include for the violation: (1) the reason for the violation, or, if contested, the basis for disputing
the violation or severity level; (2) the corrective steps that have been taken and the results
achieved; (3) the corrective steps that will be taken; and (4) the date when full compliance will
be achieved. Your response may reference or include previous docketed correspondence, if
the correspondence adequately addresses the required response. If an adequate reply is not
received within the time specified in this Notice, an order or a Demand for Information may be
issued requiring information as to why the license should not be modified, suspended, or
revoked, or why such other action as may be proper should not be taken. Where good cause is
shown, consideration will be given to extending the response time.
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, United States Nuclear
Regulatory Commission, Washington, DC 20555-0001.
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
Enclosure 1
(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. If personal privacy
or proprietary information is necessary to provide an acceptable response, please provide a
bracketed copy of your response that identifies the information that should be protected and a
redacted copy of your response that deletes such information. If you request withholding of
such information, you must specifically identify the portions of your response that you seek to
have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the
disclosure of information will create an unwarranted invasion of personal privacy or provide the
information required by 10 CFR 2.390(b) to support a request for withholding confidential
commercial or financial information).
In accordance with 10 CFR 19.11, you may be required to post this Notice within 2 working days
of receipt.
Dated this 17th day of July 2018
2
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket: 150-00017
License: General License pursuant to 10 CFR 150.20
Report: 2018-001
Licensee: The NACHER Corporation
Location Inspected 108 Lois Road, Houma, Louisiana
Inspection Dates: April 24, 2018
Exit Meeting Date: June 21, 2018
Inspector: Jason Dykert, Health Physicist
Materials Licensing and Inspection Branch
Division of Nuclear Materials Safety
Observed by: John Fontenot, Environmental Scientist III
Office of Environmental Compliance
Assessment Division
Louisiana Department of Environmental Quality
Approved by: Michael C. Hay, Chief
Materials Licensing and Inspection Branch
Division of Nuclear Materials Safety
Attachment: Supplemental Inspection Information
Enclosure 2
EXECUTIVE SUMMARY
The NACHER Corporation
NRC Inspection Report 150-00017/2018-001
On April 24, 2018, the NRC conducted a special inspection at the licensees facility in Houma,
Louisiana in response to a hazardous radiography source recovery operation following the
malfunction of the radiography exposure device.
Program Overview
The NACHER Corporation (licensee) was authorized under reciprocity via Louisiana Agreement
State license LA-13065-LO1, to possess and use byproduct material, including iridium-192 (Ir-
192), for industrial radiographic operations in NRC jurisdiction. Licensed activities were
authorized to be performed at temporary job sites in the Gulf of Mexico.
Inspection Findings
Two apparent violations were identified regarding the licensees: (1) failure to perform an
adequate equipment check, as required by 10 CFR 34.31(a), which resulted in a guide tube
disconnect and an unshielded 77 curie Ir-192 radiography source being stuck out of the
exposure device; and (2) failure to follow emergency procedures, specifically to contact the
radiation safety officer in the event that a source cannot be fully retracted to the fully shielded
position, and only attempt source recovery operations after specific approval has been
authorized by the radiation safety officer.
A Severity Level IV violation was identified involving the licensees failure to assign a deep-dose
equivalent for the part of the body receiving the highest exposure. The licensee used an actual
dosimetry measurement, but the dosimeter was worn on the hip opposite the exposed source
while the radiographers shoulder and arm to the elbow nearest the source received the highest
exposure.
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.
Corrective Actions
The radiation safety officer immediately reported the event to the NRC on the same day that it
occurred. The licensee provided classroom training and hands-on in person coaching to the
radiographers involved in the event. A safety stand-down was held companywide. All
radiography personnel were sent a safety bulletin covering the importance of equipment
inspections, the definition of source recovery, the requirement to stop work and call the radiation
safety officer in the event of source recovery, and source recovery activities must be performed
only by trained and authorized individuals. The licensee also committed to put lead shot bags
and lead shielding sheets in every offshore darkroom such that a source could be immediately
shielded if needed.
2
REPORT DETAILS
1. Program Overview (Inspection Procedure 87121, 87137)
1.1. Program Scope
The NACHER Corporation was authorized to perform radiography in federal jurisdiction
through a reciprocity application pursuant to 10 CFR 150.20. Licensed activities were
authorized to be performed at temporary job sites in the Gulf of Mexico at various
offshore locations.
This inspection focused on licensed activities performed in federal jurisdiction under
reciprocity and the general license that involved Event 53306.
1.2. Inspection Scope
The NRC inspector conducted interviews with radiographers to understand the facts
relevant to the event, and assessed the causes and the corrective actions that the
licensee implemented or planned to implement relative to the event. The inspector
performed time and motion studies. The inspector also reviewed and assessed the
adherence to operating and emergency procedures, license conditions and federal
regulations. The inspector reviewed records and independently assessed the doses
received by the radiographers. A Louisiana Agreement State inspector accompanied to
observe the inspection.
2. Inspection Observations and Findings (Inspection Procedure 87121)
2.1. Observations
On April 24, 2018, the inspector conducted an announced inspection at the licensees
facility located in Houma, Louisiana. The event occurred on March 31, 2018, at the
bottom of an offshore platform near the risers that lift the platform out of the Gulf of
Mexico. The radiographers had reached the work location by boat, and were performing
riser inspections at various offshore platforms over the course of a few weeks. The
radiographers performed these inspections using various non-destructive testing
techniques that included industrial radiography.
The event occurred while performing radiography work approximately 10 feet above sea
level on a metal platform surrounding the offshore platform risers. Except for the
radiographers, no other individuals were in the vicinity of the radiography area. Prior to
conducting radiography activities the radiographers indicated on a utilization log that all
the equipment being used that day was inspected and in good working condition.
During the first exposure of the day, the radiographer realized that there was an
equipment malfunction because he had to turn the crank-out mechanism too many times
for the length of guide tube being used. He used a survey meter to verify that the source
was not fully retracted and visually identified that the guide tube was disconnected from
the exposure device with the quick connect coupling stuck on a lip of the metal platform.
The radiographer attempted to crank the source back into the fully locked and shielded
position, but was unsuccessful. The radiographer noted that the survey meter indicated
3
the source was partially shielded by the metal from the guide tubes quick connect
coupling and requested the assistant radiographer keep pressure on the crank so the
source assembly would move towards the shielded position. The radiographer lifted the
guide tube with three fingers on his right hand, approximately 1 foot away from the quick
connect coupling and freed it from the metal walkway. As the radiographer lifted the
stuck and misaligned guide tube, the source was retracted into the shielded position by
the assistant radiographer.
The re-enacted event to retrieve the source to the fully shielded position took
approximately 7 seconds to complete. The licensee found that the root cause of the
equipment failure was because of the dirty condition of the quick connector of the guide
tube.
During interviews with the inspector, the radiographer stated that quick connect coupling
was found dirty and gummy prior to using it on the day of the event, and that he should
have cleaned it prior to using it that day. The radiographer believed he had checked to
see if the quick connect coupling was engaged with the camera prior to using it that day.
The radiographer also stated that when he realized the equipment had malfunctioned he
did not think about what he was doing and improperly reacted to the situation in an
attempt to correct the equipment malfunction.
The licensees operating and emergency procedures address both equipment checks
and the inability to fully retract a source to the fully shielded position. However, the
radiographers lack of understanding about source recovery operations and inexperience
using radiographic exposure equipment led to the guide tube disconnect and his reaction
during the event.
The licensee immediately reported the event to the NRCs Headquarters Operations
Officers as required by 10 CFR 30.50(c)(1). The RSO provided classroom training and
hands-on in person coaching to the radiographers involved in the event to address the
apparent causes of the event. The licensee also required that a safety stand-down be
held companywide that included review of a bulletin sent to all radiography personnel.
The bulletin covered the importance of equipment inspections, defined source recovery
operations, reviewed the requirement to stop all work and call the RSO in the event that
a source cannot be fully retracted into the fully shielded position, and re-enforced that
those operations must only be performed by a trained individual.
Additionally, the licensee committed to providing lead shot bags and lead shielding
sheets in each offshore darkroom so that a source can be shielded temporarily by the
radiography crew immediately present. These corrective actions and licensee event
report are found under the NRCs Agencywide Documents Access and Management
System (ADAMS) Accessions ML18150A687 and ML18127A043.
The NRC inspectors independent calculated dose to the radiographers hand was in
agreement with the licensees dose assessment. The licensee and the NRC estimated
that the radiographers hand received approximately 630 millirem.
The licensee was using direct ion storage (DIS) dosimetry (instadose') to monitor the
radiographers whole body exposure. The dosimeter was worn on the radiographers
belt, and was immediately evaluated by a National Voluntary Laboratory Accreditation
Program (NVLAP) accredited processor after the event.
4
The licensee assigned a whole body dose of 7 millirem to the radiographer based upon
the actual measured exposure on the dosimeter. The dose measured by the DIS
dosimeter would have been accurate if the whole body had been the same distance
away from the source as the DIS dosimeter. However, because the arm to the elbow
was the closest part of the whole body to the unshielded source, and the radiographer
had worn the dosimeter on the hip on the opposite side of the exposed source, the NRC
questioned if this assigned dose was accurate. Subsequently the licensee provided an
updated whole body dose that was based on an evaluative survey for the part of the
body receiving the highest dose.
The deep-dose equivalent to the whole body calculated from that evaluative survey was
157.5 millirem. This value was also in agreement with the NRC inspectors dose
assessment to the whole body. Due to the limited amount of time spent near the source,
no dose limits were exceeded.
2.2. Findings
The inspector identified two apparent violations resulting from the event that involved
failures to: (1) perform adequate equipment checks ensuring equipment is in good
working condition before use, and (2) follow emergency procedures resulting in a
hazardous source recovery operation by individuals not properly trained to conduct
those activities.
Apparent Violation of 10 CFR 34.31(a)
Title 10 CFR 34.31(a) requires, in part, that the licensee shall perform visual and
operability checks on radiographic exposure devices and associated equipment before
use on each day the equipment is to be used to ensure that the equipment is in good
working condition. If equipment problems are found, the equipment must be removed
from service until repaired.
Contrary to the above, on March 31, 2018, the licensee failed to adequately perform
visual and operability checks on a radiographic exposure device and associated
equipment before use on that day to ensure that the equipment was in good working
condition. Specifically, a guide tube disconnect occurred because the licensees
operability check did not ensure that the grease, dirt, and grime was cleared from the
guide tubes connection to the exposure device, which ultimately resulted in the inability
to return the source to the shielded position. (150-00017/2018-001-01)
Apparent Violation of 10 CFR 150.20(b)(5)
Title 10 CFR 150.20(b)(5) requires, in part, that the licensee comply with all terms and
conditions of the specific license issued by an Agreement State except such terms or
conditions as are contrary to the requirements of 10 CFR 150.20.
License Condition 10 of Louisiana license LA-13066-L01, Amendment 36, states, in part,
that the licensee is authorized to do source retrieval in accordance with company
operating and emergency procedures.
5
Operating and Emergency Procedures, NTOPMI-031-NDT-OE, Section 7, Procedures
for Lay Barges & Offshore Platforms, Revision 4; Section 10.0, Emergency
Procedures, step 10.2 requires, in part, that radiographic personnel are to contact the
radiation safety officer (RSO) in the event a source cannot be fully retracted to the fully
shielded position. Only radiographers who have been specifically authorized by the
RSO may attempt source recovery operations, and then only after specific RSO
approval.
Contrary to the above, on March 31, 2018, the licensee engaged in activities in
Non-Agreement States under the general license provided in 10 CFR 150.20, and failed
to comply with all terms and conditions of the specific license issued by an Agreement
State. Specifically, radiographic personnel failed to contact the RSO when a source
could not be fully retracted to the fully shielded position. In addition, the radiographers
performed source recovery operations without having been properly trained and without
RSO approval. (150-00017/2018-001-02)
Severity Level IV Violation of 10 CFR 20.1201(c)
After reviewing the event, the inspector identified a Severity Level IV violation that
involved the licensees failure to assign a deep-dose equivalent for the part of the body
receiving the highest exposure.
Title 10 CFR 20.1201(c) requires, in part, that the assigned deep-dose equivalent must
be for the part of the body receiving the highest exposure. The deep-dose equivalent
may be assessed from surveys or other radiation measurements for the purpose of
demonstrating compliance with the occupational dose limits, if the individual monitoring
device was not in the region of highest potential exposure.
Contrary to the above, from March 31 through May 10, 2018, the licensee failed to
assign a deep-dose equivalent for the part of the body receiving the highest exposure.
The deep-dose equivalent was not assessed from surveys or other radiation
measurements for the purpose of demonstrating compliance with the occupational dose
limits when the individual monitoring device was not in the region of highest potential
exposure. Specifically, a radiographers dose monitoring device was worn near the
individuals hip during a source recovery operation, however the individuals chest and
arm to the elbow were in the region of highest potential exposure and the licensee failed
to assign a deep-dose equivalent for those parts of the body.
The licensees failure to assign a deep-dose equivalent for the part of the body receiving
the highest exposure was identified as a Severity Level IV violation
of 10 CFR 20.1201(c). (150-00017/2018-001-03)
The licensee corrected this violation on the same day that the inspector discussed the
deep-dose equivalent with the RSO. The licensee requested that Mirion assign a deep-
dose equivalent of 157.5 millirem to the radiographer. Corrective actions to prevent
recurrence in the future have not yet been specified by the licensee.
Use of Direct Ion Storage (DIS) Dosimetry
The inspector reviewed the licensees compliance with personnel dosimetry
requirements under 10 CFR 34.47 and determined that the licensee is using direct ion
6
storage (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-18-050).
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.
3. Exit Meeting Summary
On June 21, 2018, a final telephonic exit meeting was conducted with The NACHER
Corporation RSO and a Regional RSO from Mistras Group, Inc. to discuss the
inspection findings. The NRC representatives described the NRCs enforcement
process and the options for the licensee to respond in writing to this inspection report or
attend a pre-decisional enforcement conference with the NRC.
7
SUPPLEMENTAL INSPECTION INFORMATION
PARTIAL LIST OF PERSONS CONTACTED
David Boudreaux, Radiation Safety Officer, The NACHER Corporation
Kevin Brackens, Regional Radiation Safety Officer, Mistras Group, Inc.
Matt Kim, Corporate Radiation Safety Officer, Mistras Group, Inc.
INSPECTION PROCEDURES USED
87121 Industrial Radiography Programs
87137 10 CFR Part 37 Materials Security Programs
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
150-00017/2018-001-01 APV Failure to perform an adequate equipment check, before
use, to ensure equipment was in good working condition.
150-00017/2018-001-02 APV Failure to follow Emergency Procedures to contact the
RSO and obtain approval prior to source recovery
operations. (10 CFR 150.20(b)(5))
150-00017/2018-001-03 VIO Failure to assign a deep-dose equivalent for the part of the
body receiving the highest exposure. (10 CFR 20.1201(c))
Closed
None
Discussed
None
LIST OF ACRONYMS USED
ADAMS Agencywide Documents Access and Management System
CFR Code of Federal Regulations
DIS Direct Ion Storage
EGM Enforcement Guidance Memorandum
NRC U.S. Nuclear Regulatory Commission
NVLAP National Voluntary Laboratory Accreditation Program
PEC Predecisional Enforcement Conference
RSO Radiation Safety Officer
Attachment