IR 015000004/1993010
| ML20057C615 | |
| Person / Time | |
|---|---|
| Site: | 015000004 |
| Issue date: | 08/13/1993 |
| From: | Troy Pruett, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20057C613 | List: |
| References | |
| EA-93-201, NUDOCS 9309290177 | |
| Preceding documents: |
|
| Download: ML20057C615 (9) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION V
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93-10
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License No. 0373-70 (California)
Docket No.
15000004 i
Licensee:
Richardson X-Ray Inc.
12707 Rives Avenue, Suite F Downey, California 90242 Inspection Conducted:
July 29-30,1993 3h
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Inspector:
7Foy W. Pruett, Radiation Specialist Date Signed Approved:
b. b k.0s f(3143 Gregory
'has, Chief, Radioactive Date $igned
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Materia afety Branch Areas Inspected: This was an unannounced inspection to examine the licensee's implementation of their radiation safety program during radiographic operations performed under reciprocity at Vandenburg Air Force Base in California. The areas examined included: training; internal audits; material receipt and transfer; use of materials; radiation surveys; personnel monitoring; sealed source leak tests; survey instruments and calibration; posting and labeling; and independent measurements.
Results: The licensee's radiation safety program v.>as not being adequately implemented during the radiography operations observed by the inspector. The radiographer terminated the field operations when advised by the inspector of the safety concerns.
Six apparent violations were identified during the inspection and are summarized below.
Five of the violations were similar to those identified during a previous inspection conducted on April 9-10, 1992, at the Marine Corps Air Ground Combat Center, Twentynine Palms, California and the licensee's office.
The inspection report was subsequently referred to the State of California because the site was determined not to be under exclusive federal jurisdiction. The State of California Department of Health Services issued a Notice of Violation (N0V) dated April 24, 1992, to the licensee after a follow-up inspection conducted on April 22, 1992, at the licensee's facility in Downey, California. The following apparent violations were identified:
1.
Failure to maintain constant surveillance of the high radiation and restricted areas as required by 10 CFR 34.41 and Section II, Item 2.3 of the licensee's Operating and Emergency Procedures. This is similar to Violation C of the NOV dated April 24, 1992, which states in part, that licensee personnel were not positioned to prevent access to a high
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9309290177 930813 PDR STPRG ESGCA PDR
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radiation area.
This is an apparent repeat violation (Section 4)
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2.
Failure to perform a survey of the exposure device and source guide tube after each exposure as required by 10 CFR 34.43(b) and Section II, Item
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4.1.2(b) of the licensee's Operating and Emergency Procedures. This is similar to Violation B of the NOV dated April 24, 1992, which states the licensee's radiographer failed to conduct an adequate survey in two
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instances and to survey the circumference of the projector and the guide
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tube after radiographic exposures. This is an apparent repeat
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l violation (Section 5) (93-01-02).
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3.
Failure of radiographic personnel to wear an alarm ratemeter as required by 10 CFR 34.33(a). This is similar to Violation A of the NOV dated April 24, 1992, which states in part, that the radiographer's assistant did not wear his film badge. This is an apparent repeat violation (Section 6) (93-01-03).
4.
Failure to post the boundary of the high radiation area as required by 10 CFR 20.203(c)(1) and Section II, Items 2.2 and 9.1 of the licensee's Operating and L ergency Procedures. This is similar to a violation identified in NRC Inspection Report No. 92-05, Section 4A.(2), paragraph 2.
This is an apparent repeat violation (Section 7) (93-01-04).
5.
Failure to post the radiation area boundary area as required by 10 CFR 20.203(b) and Section II, Items 2.1 and 9.3 of the licensee's Operating and Emergency Procedures. This is similar to a violation identified in
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NRC Inspection Report, Sections 4A.(1), paragraph 1, and 4A.(2),
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paragraph 2.
This is an apparent repeat violation (Section 7)
(93-01-05) and 6.
Failure to block and brace radioactive material during transport as required by 49 CFR 177.842(d) (Section 10) (93-01-06).
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e DETAILS 1.
Persons Contacted
- Gail Flagor, President
- Clifton Johnson, Radiation Safety Officer Terry Molloy, Radiation Safety Monitor / Radiographer
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Robert Kehley, Radiographer's Helper
- Indicates present at exit meeting.
2.
Background The licensee was last inspected on April 9-10, 1992, at the Marine Corps Air Ground Combat Center, Twentynine Palms, California. The results of the inspection were forwarded to the State of California since the surveyor's records indicated the work was performed under California
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jurisdiction. The California Department of Health Services issued a
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Notice of Violation dated April 24, 1992, and conducted an Enforcement
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Conference on May 4,1992, based on the NRC's inspection and a-follow-up
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inspection conducted by the State at the licensee's facility on April 22, 1992. As part of the licensee's corrective actions, a consulting i
firm, EMAR Enterprises, was hired to perform training for and conduct independent audits of the licensee's radiographers and radiographer's assistants.
Richardson X-Ray, Inc. (California Licensee) was contracted by McDonnell Douglas to perform radiography on high pressure helium piping at the SLC No. 2 Launch Pad at Vandenburg Air Force Base. The company notified NRC on July 26, 1993, of their intent to perform radiographic operations on this project between July 29 and 30,1993. Arrangements were made by
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the Region V office to perform an inspection of the radiographic
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operation performed on July 29, 1993.
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The radiographer observed at the field site was also Richardson X-Ray's Radiation Safety Monitor.
The Radiation Safety Monitor is appointed by the RSO and is responsible for performing "any/or" all parts of the
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Radiation Safety Program.
The President indicated that the radiographer's appointment to Radiation Safety Monitor was based on the individual's past performance with the company, prior experience as a Radiation Safety Officer with McDonnell Douglas, and his knowledge of the company's radiation safety procedures.
3.
Audits The inspector reviewed the records of quarterly audits and maintenance requirements for radiographic personnel and devices which were observed at the field location. Records indicated that all required audits and l
maintenance checks had been performed. The President and RSO stated I
that quarterly audits of radiographers emphasized surveillance of the
restricted and high radiation areas, surveys, and postings. No apparent
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violations or deviations were identified during the review of this part of the licensee's program.
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4.
Use of Materials
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On July 29, 1993, at about 10:30 am the inspector. approached the launch
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area where radiography was scheduled to be performed. The pipe being radiographed was located on a paved area out-of-doors, bounded by sand dunes. A posted radiation area (restricted area) had been established using barrier tape located about one foot above the pavement and
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spanning an arc of about 170 degrees.
Inside the. restricted area the
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inspector could see several large metal containers and the radiographer's truck, but not the radiographer or the radioactive source-
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or pipe being examined.
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Section II, Item 2.3 of the licensee's Operating and Emergency Procedures requires-the radiographer to maintain constant surveillance
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of the restricted area.
10 CFR 34.41 requires the licensee to maintain a direct surveillance of the operation to protect against entry into a high radiation area.
The inspector entered the restricted area, wearing personal dosimetry
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and an alarming ratemeter, while performing a radiation survey with a
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hand-held survey instrument. No one challenged the inspector nor took any action to preclude his entry into the restricted area. As the
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inspector came around a large red metal storage container, the radiation
dose rate increased _to about 10 mrem /hr and the source camera,. guide i
tube, and. pipe being radiographed were clearly visible about 15 feet away. The radiographer and his assistant were located about 120 feet
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from the source and no action was taken by them to protect against entry
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into the high radiation area produced by the 91-curie iridium-192 (
source. The inspector immediately retreated behind the metal container;
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the dose rate dropped to about I mrem /hr and then within about 30 seconds, dropped to natural background levels.
The failure to maintain constant surveillance of the high radiation area
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and restricted area during the radiographic operations indicates a
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significant reduction in the safety precautions necessary to protect
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persons who might enter these areas. This is similar to Violation C in i
the State of California NOV dated April 24, 1992, and is an apparent
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repeat violation from the inspection performed on April 9-10, 1992 (93-
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01-01).
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5.
Surveys
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10 CFR 34.43(b) and Section II, Item 4.1.2(b) of the licensee's i
Operating and Emergency Procedures require that a survey be made after j
each exposure to. determine that the sealed source has returned to its l
shielded position. The entire circumference of the radiographic j
exposure device and the source guide tube must be surveyed.
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When the dose rate dropped to natural background the inspector emerged
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from behind the metal container and observed the radiographer as he retracted the sealed source into the shielded camera. After the source
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was retracted, the radiographer approached and locked the exposure i
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device without a survey instrument, and commenced removing the film from the weld location. The inspector observed that while the radiographer was removing the film, his helper, who was performing the functions of a radiographer's assistant, approached the device with a GS-2000 survey instrument. The instrument was placed six to ten inches to the right side of the SPEC-2T exposure device. No circumferential survey of the device or survey of the guide tube was performed by the radiographer or the radiographer's helper.
The inspector approached the radiographer after the first exposure, but did not identify himself as an NRC representative. The inspector perforced a survey of the exposure device and guide tube and determined that the source had been returned to the shielded position. The inspector observed the radiographer and his helper prepare for and take the second exposure.
(The licensee did not question the inspector's presence at the job site, and allowed the inspector to remain inside the restricted area during the second exposure.) After retracting the sealed source, the inspector observed the radiographer approach and lock the exposure device without a survey instrument.
The inspector identified himself as an NRC inspector, and suggested to the radiographer that he suspend the remaining radiographic work due to the safety significance of failing to perform surveys of the exposure device after each exposure. The inspector requested the radiographer to perform a survey of the exposure device and guide tube.
The results of the survey indicated that the source had returned to the fully shielded
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position.
The inspector asked tne helper what the requirements were for performing a survey after retracting the source. The helper stated that only the exposure device needed to be surveyed. The radiographer stated that the
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entire exposure device and guide tube must be surveyed after each retraction of the source. The radiographer also stated that he had no explanation for why he failed to ensure that radiation surveys were performed as required after the completion of each exposure.
Section II, Item 4.1.4 of the licensee's operating procedures requires that the exterior surfaces of the transport vehicle be less than two mr/hr at all times. The inspector requested that the licensee survey
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the exterior surfaces of the truck used to transport the exposure device with the source stored for transit. The right rear corner of the truck indicated 4.5 mr/hr using the licensee's GS-2000 survey instrument. The licensee stated that the truck was new and did not have the blocking and
bracing devices used in the other trucks. Therefore, the device was placed in a cabinet in the right rear corner of the truck which resulted in the high exposure readings on the exterior surface. The inspector requested that the licensee place a lead sheet between the exposure
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device and the exterior wall of the truck. After placement of the lead.
shielding the exposure rate on the exterior surface was 1.8 mr/hr. This item is not being cited because the NRC does not require the exterior surface of the transport vehicle to be less than 2 mr/hr at all times.
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The failure of the radiographer and his helper to perform a radiation survey including the circumference of the exposure device and the guide
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tube prior to changing the film indicates a significant reduction in the personal safety afforded them and those personnel present at the field site. This violation is similar to Violation B of the State of -
California NOV dated April 24, 1992. The failure to perform surveys is an apparent repeat violation from the inspection performed on April 9-10, 1992 (93-01-02).
6.
Personnel Monitoring 10 CFR 34.33(a) requires that radiographers and assistant radiographers wear a direct reading pocket dosimeter, film badge or TLD, and an alarm ratemeter. On July 29, 1993, the inspector observed that the i
radiographer's helper, who was performing the functions of a radiographer's assistant, was not wearing an alarm ratemeter while i
working inside the restricted area during radiographic operations. The
helper was performing surveys for the radiographer with a GS-2000 survey instrument within the restricted area and thus under the definitions in 10 CFR 34.2 was acting as a radiographer's assistant. The helper indicated that the alarm ratemeter was in the back of the truck. The radiographer stated that the helper was not wearing the alarm ratemeter because he was not wearing a belt to which it could attached.
The radiographer also stated that alarm ratemeters were required to be worn
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while working under NRC jurisdiction and that Vandenburg Air Force Base was under NRC jurisdiction. After the helper donned the alarm
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ratemeter, the inspector observed that the device had not been turned The inspector asked the helper whether the device was turned on and on.
how he knew the device was on. The helper stated that he had turned on the device, but did not know how you could tell if the device was on.
The inspector then turned on the helper's alarm ratemeter and
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demonstrated how to check the proper operation of the device.
t The radiographer's failure to ensure that his helper was wearing an alarm ratemeter during radiographic operations indicates a significant reduction in the level of personal safety provided the worker. This violation is similar to Violation A of the State of California NOV dated April 24, 1992, which states in part, that a. licensee radiographer's assisttnt did not wear a film badge during radiographic operations.
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This is an apparent repeat violation from the inspection performed on April 9-10, 1992 (93-01-03).
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7.
Posting 10 CFR 34.42 requires that no} withstanding the provisions in 20.204(c),
areas in which radiography are being performed be conspicuously posted as required by 10 CFR 203(b) and (c)(1).
10 CFR 20.203(b) requires each radiation area to be posted with a sign or signs bearing the caution symbol and the words, " Caution Radiation Area."Section II, Item 9.2 of the licensee's Operating and Emergency Procedures indicates that the restricted area boundary will be posted as the radiation area boundary.
Section II, Items 2.1 and 9.3 require the licensee to post all
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restricted areas with warning signs bearing the words, " Caution Radiation Area-Do Not Enter," at the two mr/hr boundary. The inspector observed after the second exposure that approximately two thirds of the restricted area was not posted. The radiographer stated that the area had not been completely posted because there was insufficient barrier tape to encircle the perimeter. The inspector noted that additional radiation signs were in the truck, and that the radiographer had the ability to post the remaining two thirds of unposted restricted area.
This is similar to a violation identified in the NRC Inspection Report No. 92-05, Sections 4A.(1) and (2). This is an apparent repeat violation from the inspection performed on April 9-10, 1992 (93-01-05).
10 CFR 20.203(c)(1) and Section II, Item 2.2 and 9.1 of the licensee's
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Operating and Emergency Procedures require that each high radiation area be posted with the radiation caution symbol and the words " Caution High Radiation Area." On July 29, 1993, the inspector observed after the second exposure that the high radiation area was not posted. The radiographer indicated that he did not think the area needed to be posted and that there was insufficient material to hang the high
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radiation signs.
The inspector noted that high radiation area signs were available in the truck and that the signs could have been hung on the stanchions supporting the piping being radiographed. The failure to post the high radiation area could have contributed to an individual unknowingly approaching an exposed source (See Section 4). This is similar to a violation identified in NRC Inspection Report No. 92-05, Section 4A.(2). This is an apparent repeat violation from the
inspection performed on April 9-10, 1992 (93-01-04).
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Survey Instruments and Calibration
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The inspector reviewed the calibration records for the survey instruments present at the field site (Survey instruments: GS-2000 and Radector 500D-SR; Alarm ratemeters: NDS Model RA-500).- All instruments present at the job site had been calibrated as required by 10 CFR Part 34. No apparent violations or deviations were identified during the review of this part of the licensee's program.
9.
Sealed Source Leak Testing and Inventory The inspector reviewed the leak testing and inventory records for the device used at the field site. No apparent violations or deviations were identified during the review of this part of the licensee's
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program.
10.
Receipt and Transfer of Radioactive Material The inspector reviewed the receipt and transfer records for the exposure device used at the field site. No discrepancies with the records associated with the exposure device were identified.
49 CFR 177.842(d) requires that each shipment of radioactive material be blocked and braced so it cannot change position during conditions
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normally incident to transportation. On July 29, 1993, the licensee transported a 91-curie iridium-192 source in a Spec-2T exposure device
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without securing the device from movement during transport. The radiographer indicated that he was using a new truck and that the truck had not been equipped with devices for blocking and bracing exposure devices. This is an apparent violation (93-01-06).
11.
Training The inspector reviewed the training records for personnel recently hired
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by the licensee and personnel at the field site. No records of
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radiation safety training were maintained for two individuals recently hired by the licensee. The RSO indicated that he personally provided radiation safety training to these individuals and that in the future he
would ensure that documentation of radiation safety training for each individual was maintained.
After the inspection of April 9-10 and 22, 1992, the licensee hired a contractor to provide nine hours of radiation safety training to all radiographic personnel. Training records indicated that the
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radiographer present at the field site attended this training session.
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The agenda for the training included a discussion of the violations identified during the inspection, survey requirements, posting of areas, and surveillance techniques.
Additionally, the President and RSO demonstrated how an inadequate survey of the exposure device could
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result in an exposure to the radiographer. During the demonstration an iridium-192 source was placed 1/4 of an inch outside of the exposure
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device. The demonstration confirmed that the only means to detect the exposed source was to survey the front end of the device.
Based on the discussions with the President and RSO, and a review of training records, it appears that the radiographer was knowledgeable of the requirements to perform radiation surveys after retracting the sealed source.
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12.
Utilization Logs
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Section II, Item 3.4 of the licensee's Operating and Emergency procedures requires that the radiographer record pocket dosimeter readings at the beginning of each shift on the utilization log. On July
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29, 1993, the inspector observed that the beginning of shift reading for pocket dosimeters used by the radiographer and his helper had not been recorded on the utilization log. This item.is not being cited since the utilization logs were completed prior to leaving the job site.
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13.
Independent Measurements The inspector conducted surveys of the exposure device, transport vehicle, and posted restricted area using an Xetex Model 305-B (NRC serial No. 008327 last calibrated on July 4,1993). The maximum radiation level on the exposure device was 56 mr/hr on contact and 14.5 mr/hr at six inches. The maximum radiation level on the transport vehicle was 6.5 mr/hr. The maximum radiation level at the posted
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restricted area boundary was 0.8 mr/hr.
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Exit Meetina i
An exit meeting was held on July 30, 1993, with the President and RSO of Richardson X-Ray to discuss the initial inspection findings. The inspector discussed the apparent violations and lack of concern for personal safety demonstrated by the licensee's Radiation Safety Monitor / radiographer. The inspector discussed the potential enforcement actions based on the NRC Enforcement Policy. The inspector noted that five of the violations were repeated from the last inspection performed on April 9-10 and 22,1992. The licensee indicated that all of the
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apparent violations had been stressed during training and quarterly audits of radiographers by both the RSO and the President.
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