IR 015000033/1989001
| ML20245A380 | |
| Person / Time | |
|---|---|
| Site: | 015000033 |
| Issue date: | 04/04/1989 |
| From: | Powers D, Scovill V NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20245A363 | List: |
| References | |
| 15000033-89-01, 15000033-89-1, NUDOCS 8904250175 | |
| Download: ML20245A380 (7) | |
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U.S. NUCLEAR REGULATORY COMMISSION'
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REGION IV
p URANIUM RECOVERY FIELD OFFICE NRC Inspection Report No.:
15000033/89-01 License No. 33-16105-02 l
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Docket No.:
15000033 Licensee:
Basin Testing Laboratory, Inc.
dba Basin Services, Inc.
Highway 2 and 85 North P.O. Box'1854 Williston, North Dakota 58802-1854-Facility:
Williston, North Dakota Inspection At: Williston, North Dakota
' Inspection Conducted:
February 28, 1989
Inspector:
4d-
- w&W M-[-M Van R. Scovill
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Date Approved:
84Id2 W
Y-[-[f Dale A. Powers, Chief Date Nuclea'r Materials Inspection Section Region IV Inspection Summary Inspection Conducted on February 28, 1989 Areas Inspected: Management control systems; training and qualifications of.
personnel; licensee internal audits; inspection, maintenance, and use of materials, facilities and equipment; personnel monitoring; utilization log; quarterly inventories and survey records; transportation; and survey instrument calibrations.
Results: Within the nine areas inspected, two apparent violations within two areas were identified.
Basin Testing Laboratory (Basin) is licensed by the I
North Dakota State Department of Health, Radioactive Material License i
No. 33-16105-02, and the two apparent violations were identified at Basin's
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2 facility located in Williston, North Dakota; therefore, the two apparent violations identified during this inspection will be referred to the North Dakota State Department of Health for action. The apparent violations were:
1.
Shipment of an iridium-192 industrial radiography device without determining the level of non-fixed (removable) radioactive contamination prior to shipment.
2.
Failure to document on Form NRC-4, or on a clear and legible record containing all the information required on Form NRC-4, a radiographer assistant's previous occupational radiation dose history.
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DETAILS 1.
Persons Contacted
- William Cobban, President
- Richard Maxon, Radiographer, Radiation Safety Officer Terry Clear, Radiographer's Assistant
- Denotes those present at exit interview.
2.
Backaround Basin Testing Laboratory, Inc., is authorized by the North Dakota State Department of Health, Radioactive Material License No. 33-16105-02, which
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expires December 31, 1989, to use iridium-192, not to exceed 100 curies per source, in Tech-0ps Model No. 520 Exposure Device, and Tech-Ops Model No. 500 SU source changer fo' industrial radiography, at temporary job sites of the licensee anywhere in the State of North Dakota. This inspection was conducted to determine:
a) The effectiveness of corrective actions implemented as a result of inspections on September 1 and October 5-6, 1988, and documented in a " Notice of Violation and Proposed Imposition of Civil Penalty",' dated January 19, 1989; and b) to conduct an unannounced routine inspection of the licensee's activities.
As a result of a Confirmation of Action Letter (CAL 88-37), dated October 12, 1988, Basin Testing Laboratories, Inc., suspended, in areas of NRC jurisdiction, all activities involving radioactive material licensed by an Agreement State. The suspension of these activities continued until NRC released Basin Testing Laboratory, Inc., from this commitment by letter dated March 17, 1989. On November 10, 1988, an enforcement conference was held with Basin Testing Laboratory, Inc., to discuss the apparent violations, which were identified during the special, unannounced inspections, conducted on September 1, and October 5-6, 1988, of generally licensed operations conducted by Basin Testing Laboratories, Inc. A
" Notice of Violation and Proposed Imposition of Civil Denalty," was issued to Basin Testing Laboratories, Inc., requiring a written response including, for each alleged violation:
1) admission or denial of the alleged violations; 2) the reasons for the violation if admitted, 3) the corrective steps that have been taken and the results achieved, 4) the corrective actions that will be taken to avoid further violations, and 5) the date when full compliance will be achieved.
By letter dated February 22, 1989, Harms and Leier, Ltd., Attorneys at Law, submitted, on behalf of Basin Testing Laboratory, Inc., a reply to the " Notice of Violation" (NOV).
In the response, Basin admitted all five violations and provided proposed corrective actions.
On February 28, 1989, a special inspection was conducted at the licensee's facility in Williston, North Dakota.
During the entrance interview, the j
proposed correct ve actions were discussed with the President of Basin i
i Testing Laboratories, Inc. A discussion of the specific violations and their corrective action is provided in a following paragraph.
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3.
Management Control Systems The licensee's corporate headquarters is located in Williston, North Dakota. Temporary job site activities are to be conducted in accordance with the licensee's procedures, which are to accompany the radiographic source during radiographic operations. The corporate Radiation Safety
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Officer (RS0), who is located in Williston, North Dakota, conducts periodic audits at temporary job sites.
The licensee's management organization establishes, controls, and implements the radiation saiety program.
Information on radiation safety is disseminated through the radiation safety procedures.
During the entrance interview, the corrective action concerning Violation I-B of NOV dated January 19, 1989, was discussed.
The licensee's representative indicated that their proposed corrective action is to apply for a NRC Byproduct Material License to authorize industrial radiographic operations in non-agreement states. However, a license application has not yet been filed with the NRC; therefore, the licensee will not conduct industrial radiographic operation in non-agreement states until a Byproduct Material License authorizing such activities has been issued or upon filing of NRC Form 241. However, at the time of the inspection, the licensee had not yet resumed industrial radiographic operations in states where the NRC maintains jurisdiction.
Also discussed was Violation I-C of the NOV dated January 19, 1989.
The licensee representative stated that it was not their intent to provide inaccurate information, and a discussion was held with all Basin Testing Laboratory, Inc., employees to emphasize the importance of providing correct and accurate information to the NRC.
The licensee has also developed a form to utilize when describing the exact location of temporary job sites to avoid future confusion concerning the location (state) of temporary job sites.
No additional apparent violations were identified by the NRC inspector.
4.
Training and Qualifications The inspector reviewed the training and qualification documents for all radiographer and radiographer' assistants as well as the licensee's utilization log.
The licensee's records indicated that all industrial radiographic operations, conducted since September 1988, were conducted by a qualified radiographer.
The licensee's proposed corrective action, concerning Violation I-A of NOV dated January 19, 1989, is to prevent individuals not qualified as radiographer from performing industrial radiographic operations. This is an updated policy for utilization of radiographer' assistants during industrial radiographic operations.
However, the updated policy was only in draft form, and had not been submitted to the North Dakota Department of Health for review and approval.
No additional apparent violations were identified by the Ni inspector.
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5.
Licensee Internal Audits The inspector discussed the Basin Testing Laboratory internal audit program with the RSO.
The RSO indicated that periodic audits at temporary job sites were conducted. However, since July 1988 the only radiographer
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employed by Basin Testing Laboratory is also the RSO, no audits of temporary job sites were conducted.
No apparent violations were identified by the NRC inspector.
6.
Inspection, Maintenance, and Use of Materials, Facilities, and Equipment The inspector reviewed a representative sample of the records of daily radiographic equipment inspections and quarterly maintenance logs. The records indicated that daily inspections were being conducted and documented as required.
The inspector also reviewed records of leak tests for the source being utilized at the temporary job site. The leak tests appear to have been conducted as required. The exposure device, source tube, and guide tube appeared to be maintained and properly stored.
I No apparent violations were identified by the NRC inspector.
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7.
personnel Monitoring The inspector reviewed exposure records, which indicated that during the fourth quarter of 1988 one individual, that had not previously worked in the licensee's restricted area, received an accumulated radiation dose of 370 mrem, and the licensee failed to complete Form NRC-4, or a clear and legible record containing all the information required on Form NRC-4 as required by 10 CFR 20.102.
However, since all industrial radiographic operations conducted by the licensee were within North Dakota under the North Dakota Department of Health jurisdiction, this apparent violation will be referred to the North Dakota Department of Health for review.
One apparent violation was identified by the NRC inspector.
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Utilization Log A review of the licensee's available records indicated that all industrial radiographic operations, since October 1988 had been conducted at various temporary job sites in North Dakota.
k No apparent violations were identified by the NRC inspector.
9.
Quarterly Inventories and Survey Records l
A representative sample of quarterly inventories and survey records was
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reviewed and found to be in compliance with 10 CFR 34.26 and 34.43.
l No apparent violations were identified by the NRC inspector.
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10.
Transportation The inspector reviewed the packaging, package marking, labeling, placarding, and shipping papers associated with the transporting of radiographic exposure devices.
The licensee's corrective action concerning Violation II-A, of the NOV dated January 19, 1989, was reviewed by the inspector.
Upon request for shipping papers the inspector was presented a licensee form entitled
" Radiation Report." This was an updated form since the previous inspection.
The updated form contains all the required information; however, the proper shipping name, as shown in 49 CFR 172.101 was not listed.
The licensee shipping paper displays " Radio Active Material, Special Form, no's" rather than the required " Radioactive Material, Special Form, n.o.s."
The licensee indicated that the form will be corrected during the next printing.
I During the entrance interview, the licensee's representative indicated that Violation II-B of the NOV dated January 19, 1989, had not yet been corrected, but that it would be corrected prior to completion of the inspection. The inspector verified prior to completion of the inspection that package marking, for packages utilized in transport of the iridium-192 sources included the identification number, preceded by "UN" or "NA" as appropriate. This action completes the corrective action concerning Violation II-B.
During the review of the transportation records, the inspector observed that on December 9,1988, an iridium-192 industrial radiographic source, Serial Number 2053, was returned to the manufacturer while the last record of leak test was April 28, 1988.
This is an apparent violation of 49 CFR 173.443.
However, since this apparent violation occurred in North Dakota, under activities licensed by the North Dakota Department of Health, this apparent violation will be referred to the North Dakota Department of Health for review.
One apparent violation was identified by the NRC inspector.
11.
Survey Instrument Calibrations
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utilized at temporary job sites.
All appeared to have been adequately calibrated within one calendar quarter.
The survey instruments were determined to be adequate for use during industrial radiographic j
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operations.
No apparent violations were identified by the NRC inspector.
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Exit Interview An exit interview was held with those individuals indicated in paragraph 1 above. The inspector expressed concern that all violations from the previous inspections had not been corrected. The inspector briefly described the two apparent violations identified during this inspection.
I The licensee representatives indicated that corrective action would be taken.
The inspector emphasized the importance of timely implementation of corrective actions.
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