IR 015000017/1997002
| ML20199B320 | |
| Person / Time | |
|---|---|
| Site: | 015000017 |
| Issue date: | 11/10/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20199B301 | List: |
| References | |
| 15000017-97-02, 15000017-97-2, NUDOCS 9711180270 | |
| Download: ML20199B320 (9) | |
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. ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION' !
REGION IV
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Docket' No.: 150-00017
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. License No.: NA Report No.: 150 00017/97-02 <
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Licensee: Louisiana Licensee (Gulf Coast inspection, Inc.) i Facility: Gulf Coast inspection, In Houma, Louisiana i
Location: P.O. Box 4176 117 North 3th 227 Clendenning Road Houma, Louisiana Dates: July 1 through July 17,1997
Inspector: Richard A. Leonardi, J Radiation Specialist
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Approved By: Blair D. Spitzberg, Ph.D., Chief Nuclear Materials inspection and
. Fuel Cycle / Decommissioning Branch Attachments: Supplemental inspection information
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EXECUTIVE SUMMAFE '
Gulf Coast inspection, Inc., Houma, Louisiana-LNHC inspection Report -150-00017/97-01:
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-This inspection was conducted to' review licensed radiographic activities performed by.the -
licensee in areas under NRC jurisdiction in offshore Outer Continental Shelf (OCS) waters
. off thk coast of Louisiana. .
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Aircose of lnsoection and Licensee Proaram Overvien Le To review recent licensed activities performed by Gulf Coast inspection, Inc. (GCl),
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- a licensee of the State of Louisiana, in areas under the jurisdiction of the NRC in
- federal waters off the coast of Louisiana. The inspection' reviewed the scope of these activities and the equipment and safety procedures used (Section 1).
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Activities in Offshore OCS Federal Waters
- .The inspection disclosed that GCl had conducted radiographic operations in federal waters off the coast of Louisiana for the past 3 years under their Louisiana licens GCl had not applied for reciprocity from the NRC, nor had they notified the Louisiana Radiation Protection Divi:sfon of (DEQ) of their activities in federal water A determination of the proper authorization of GCl to conduct activities in offshore waters is considered unresolved pending further NRC review (Section 23 Badioorachic Exposure Devices Used By the Licensee in NRC Jurisdiction
- Based on interviews with GCl personnel and a review of GCl's radiography -
. utilization records, the inspector determined that GCI had conducted radiography in
- federal offshore waters using pipeliner type exposure devices which had been
- authorized'by the State of Louisiana but which did not meet NRC performance
, requirements. This issue is considered an unresolved item pending further review
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by the. NRC (Section 3).
Review of Newfield Oil Companv's Pioeline Lavbarae Operation -
' The inspector's review of GCI's use cf pipeliner devices on the Newfield Oil
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Company pipe laying job ~in federal offshore waters during the week of July 1316, L1997, determined that GCl appeared to have conducted the radiography operations in a safe manner, and in accordance with radiation safety requirements specified in
. the license and NRC regulations.(Section 4).
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.3-1Beoort Details 1 Purpose of Inspection and Licensee Program Overview (87100) _
Gulf Coast inspection, Inc., (GCl) is based in~ Houma, Louisiana and licensed by.the State of Louisiana to perform industrial radiography at temporary jobsites in
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- Louisiana under Louisiana Radioactive Material License LA 796-LO1. GCl does not hold an NRC license and had not previously notified the NRC of any proposed -
activities within the jurisdiction of the' NRC under reciprocity. This inspection was
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. conducted to determine whether licenscd activities had bec., conducted by GClin--
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.are'as under NRC jurisdiction, and whether such activities were coriducted safely ,
and in accordance with NRC requirement GClis authorized to use numerous radiographic exposure devices, including pipeliner type exposure devices that do not meet the NRC equipment performance requirements specified 10 CFR 34.20.-
GCl has been a Louisiana licensec for a' o out three years, with field offict s in New lberia, Louisiana and ingleside, Texas. GCl has a total work force of 115 personnel, with some 45 individuals working out of the Houma corporate _ office. GCI *
conducts 25 75 percent of its activities in federal waters performing radiography on laybarges and on offshore oilfield platforms. GCl's latest physical inventory listed a total of 32 exposure devices including 13 pipeliner type devices. The inspector noted that GCl had in the past used 45 full-time and part-time radiographers and approximately the same number of radiographer assistants and helper This inspection report cocuments the inspection of GCI's radiographic operations in federal waters. The scope of the inspection was limited to a review of activities at a specific temporary jobsite tnat had been_cenducted on a leybarge in federal water Activities in Offshore OCS Federal Waters (87100) Insocction Scope
. This portion of the inspection was to teview the extent to which GCI had conducted radiographic operations in federal waters under NRC jurisdiction, and to review the authorization requirements for conducting such activities.
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- Observations and Findinas -
- Based on interviews with GCl personnel and a review of GCI utilization records, the -
inspector determined that GCI had conducted radiographic operations in federal waters since the company was formed some three years ago. GCl's radiation safety officer (RSO) indicated that 25 75 percent of the company's radiographic operations were conducted in federal water W w, A,,
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One of two operation coordinators for GCl disclosed that a significant amount of work in federal waters was associated with both pipeline production radiography and pipe tie-in radiography on marine pipeline laybarges in the Gulf of Mexico. The majority of GCI's gulf activities were conducted off the states of Louisiar.a and Texa During discussions with GCI's RSO, the inspector determined that a majority of their work is in federal waters in connection with pipeline laybarge and spool up operations. The inspector was informed that GCl normally has two or more ongoing laybarge operations each week and these radiography operations on laybarges may last from two days to as many as three week During the review of licensee utilization logs, and as a result of subsequent discussions with a GCl operations coordinator, the inspet. tor determined that during the week of July 7,1997, GCl had three ongoing laybarge pipeline operations in federal waters on three separate laybarges. GCI was using (two) SPEC-CHECK ll pipeliner exposure devices and (one) Gamma Pipeliner i exposure device in conjunction with these operation A pipeline laybarge operation involves the use of a flat deck marine vessel that is specially designed and suited for laying and burying r.,ipelines, in most cases, simultaneously. The laybarges are capable of laying pipelines in several hundred feet of water. Each laybarge has deck storage for pipe and two or more deck cranes for pipe handling. The pipe lay system consist of storage racks, a hydraulically driven roller /line-up system, several work stations, tensioners, and a remote articulating stinger. The pipe burial system typically consist of high volume pumps and jet sleds. Most laybarges have crew quarters below deck for extended work period CFR 150.20 specifies the requirements for NRC recognition of agreement state licensees working in offshore waters under NRC jurisdiction. NRC recognition of State of Louisiana licensees could be acnieved through the process of notifying the NRC pursuant to 10 CFR 150.20(b)(l), or by notifying the Agreement State pursuant to 10 CFR 150.20(c)(1).10 CFR 150.20(b) specifies, in part, that persons conducting licensed activities in federal waters as gerual licensees are subject to all the provisions of the Act, applicable rules, regulations, and Orders of the Commissio During discussions with GCI's RSO regarding their work in offshore waters, the inspector inquired as to whose authority GCl was conducting radiographic operatims in waters that were beyond Louisiana's 3 mile limit. The RSO indicated that GCl was operating under their Louisiana license, and he was not aware that GCl needed any additional authorization to_ work offshore. GCI had r;ot filed a form NRC-241 witn the NRC nor had they notified the State of Louisiana in accordance with 10 Cl R 150.20. A determination of the proper authorization of GCl to
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. conduct activities in of fshore waters is considered unresolved pending further NRC review (URI 150-00017 01). Conclusions The inspection disclosed that GCl had conducted radiographic operations in federal waters off the coast of Louisiana for the past 3 years under their Louisiana licens GCI had not applied for eciprocity from the NRC, nor had they notified the Louisiana Radiation Protection Division of (DEQ) of their activities in federal water A determination of the proper authorization of GCI to conduct activities in offshore waters is considerad unresolved pending further NRC revie Use of Pipeliner Type Exposure Devices (83822, d7100) Lnmection Scopa
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This portion of the inspection focused on GCI's use of pipeliner type exposure devices in federal offshore water .2 Observations and Findings The use of pipeliner type exposure devices for conducting radiography on offsnore laybarge operatic,n.; had been approved by the State of Louisiana in areas under t.ouisiana jurisdiction, however such devices did not meet the NRC performance requiremersts specified in 10 CFR 34.20 for use in areas under NRC jurisdictio General Licensees performing industrial radiography under reciprocity in federal offshcre waters must ensure that radiography equipment they are using meets the requirements of 10 CFR 34.2 Based on interviews of GCI personnel and a review of GCI's radiography utilization records, the inspector determined that GCI had routinely used pipeliner type radiography equipment that did not meet the performance requirements of 10 CFR 34.20 in federal offshore waters off the coast of Louisiana, Texas, Mississippi, Alabari a. and Florida, in discussions with GCI's RSO, he indir ated that their use of pipeliner type radiographic equipment was based '.an the written authorization contained in tt.eir Louisiana license. The State of Louisiana had authorized the use of pipeliner type equipment ncluding i exposure davices manufactured by Gamma Industries (Model Nos. Pipeliner I, Pipeliner Model 201) and Source Production & Equipment Company (SPEC) Model SPEC CHECK 11. The State of Louisiana had issued GCl an amendment authorizing the use of pipeliner type exposure devices for offshore pipeline use only. The use of pipeliner type exposure devP in federal offshore waters was identified as an unresolved item pending futn.v. review by the NRC (URI 150-00017-02).
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3.3- Conclusions .
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- Based. on interviews with GCl personnel and a review of GC I 's radiography . .
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- utilization records, the inspector determined that GCl had conducted radiography _ in l federal offshore waters' using pipeliner type exposure devices which had bee'n': q
- authorized by the State of Louisiana but which did not rnest NRC performance - 1
= requirements. This issue is considered an unresolved item pending further review
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14 _ Review of Nowfield Pipeline ' Operation - (87100)
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, 14.1, insoection Scoo_g .
. lThis portion of the inspection focused on GCI's radiography operations on the
,- _ laybarge designated as Cajun Horizon and contracted by Newfield Oil Compan .
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' Observations and Findinas'
< , A review of _GCl's daily use records for the' two v.peliner exposure devices useo on
' . the Cajun.Herizon laybarge in federal offshore waters during the week of July 13-
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16,_1997, provided the inspector _the identification of all radiographic equipment _
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g used as well as personal safety equipment used by two radiographers. A review of ;
radiography camera No. 45 (SPEC-CHECK 1 ) utilization records showed that this-
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camera contained an iridium-192 source (Serial No.CH-0701) that had been leak
. tested at the required 6-month interva > The review disclosed that this camera had been properly inspected within the
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, required 3 months. The inspector determined that the two radiographers had used current film badges and pocket dosimeters that had been calibrated within the required 12-month interval. - Also the inspection disclosed that each radiographer-had used a properly calibrated alarm _ ratemeter. A review of the survey instrument
> ~ used (Serial No.13720) indicateo that it had been calibrated within the required ,
3-month interval. A review of the training records for the two radiographers that worked on the -
M, laybarge indicated that both had been properly trained and had been field audited ~ ,
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- within the required 3 month interva A review of the daily radiation reports for the period _of use indicated that the reports had been properly, completed with all necessary iniormation documented as
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T3' Conclusio'nst .
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The inspe:: tor's review of GCI's use of pipeliner devices lon the Newfield' Oil Company pipe laying job in federal offshore. waters during the week of ' July.13-16, -
1997, determined that GCl appeared to have conducted the radiography operations
'in a safe manner, and in accordance with radiation safety requirements specified in ~
the license and NRC regulation .' . Exit Meeting Summary The inspector conducted a telephonic briefing with GCl on July 17,1997, to discuss the preliminary inspection findings pending NRC management review.'.: A final telephonic exit briefing was conducted on November XX,1997. The license '
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idsr,tified no information reviewed during the inspection which should be considersd proprietary, it; o
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t ATTACHMENT PARTIAL LIST OF PERSONS CONTACTED Licensee A. Pierre, GCl Owner P. Pierre, GCl Operations Coordinator K. Gros, GCl RSOD D. Lacour, GCl Radiographer T. Benoit, GCI Radiographer H. Savin, GCl Radiographer Others C. Jones, B&l General Mg H. Rink, B&l Welder and Foreman G. Bourgeois, B&l Contract Welder B. Griffin, B&l Contract Welder M Spivey, B&l Contract Welder D. Agatha, Operations Suporvisor, Horizon Offshore Contractors M. Voisin, Onshore Superintendent, Horizon Offshore Contractors INSPECTION PROCEDURES USED 87100 Licensed Materials Programs 83822 Radiation Pr:;tection ITEMS OPENED CLOSED, AND DISCUSSED Opened 150 00017-01 URI Authorization of GCI to work in federal offshore water URI Use of pipeliner type exposure devices as authorized by the State of Louisiana in areas under NRC jurisdiction which do not meet NRC performance criteri Closeql none
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List of Acronyms Used B&l- B&l induttries -
DEO- Department of Environmental Quality
. GCl -Gulf Coast inspection, In '
NRC Nuclear Regulatory Commission NMSS Nuclear Material Safety And Safeguards-OCS Outer Continental Shelf RSO . radiation safety officer ?
SPEC Source Production & Equipment Company
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