IR 015000042/1985001

Discusses Radiation Safety Insp Repts 15000042/85-01 & 15000042/85-02 on 851113 & Forwards Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $2,500

ML20207H849
Person / Time
Site:	015000042
Issue date:	07/21/1986
From:	Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Gibson H H & G INSPECTION CO., INC.
Shared Package
ML20207H856	List: IR 015000042/1985001 ML20207H871
References
EA-86-104, NUDOCS 8607250120
Download: ML20207H849 (3)

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,g)L 211986 Docket No. 15000042 General License (10 CFR Part 150)

EA 86-104 H & G Inspection Company, In ATTN: Mr. Harry Gibson 9315 Summer Bell Houston, Texas 77074 Gentlemen:

SUBJECT: NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY (NRC INSPECTION REPORT NUMBERS 15000042/85-01 AND 15000042/85-02)

This refers to the special, unannounced radiation safety inspection conducted by Mr. L. Ricketson of this office on November 13, 1985, at your field site in the Shute Creek area of Wyoming and on November 21, 1985, at your office in Houston, Texas, of the activities conducted under reciprocit) granted under your Texas License No. 11-2181, and to the discussion of out findings held by the inspector with members of your staff at the conclusion of nie inspection. This also refers to the Enforcement Conference held in the Region IV office on December 13, 1985, between Messrs. Harry Gibson, Steve Steen, Bruce Bristow and staff members of our of fice to discuss the findings of the NRC inspectio The violations identified as a result of the inspection are described in the enclosed Notice. They included failure to perform surveys after each radiographic exposure and failure to follow operating procedures. As a result of these failures, a radiographer's assistant received a whole body dose of 3.4 rems in the fourth quarter of 1985. The violations are of significant concern because they indicate that adequate oversight and control was not exercised during radiography operations. In addition, the violations demonstrate the need for improvements in management control over activities to assure adherence to NRC requirements and safe performance of licensed activitie To emphasize the seriousness of these violations and the need to ensure implementation of effective management control over the radiation safety program, I have been authorized, after consultation with the Director, Office of Inspection and Enforcement, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty in the amount of Two Thousand Five Hundred Dollars ($2,500). In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1986) (Enforcement Policy), the violations have been categorized as a Severity Level III problem. The base value of a civil penalty for a Severity Level III violation or problem is $5,000. The Enforcement Policy allows for reduction of a civil penalty under certain circumstances. In CERTIFIED MAIL RETURN RECEIPT REQUESTED ([hI gg2mn**'"/ea  %

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H & G Inspection Company, In <  ;

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this. case, the' base civil penalty has been reduced by 50 percent because of your timely and comprehensive corrective actions, including initiation of a prograa  ;

to. deter violations of operating procedures, multiple internal inspections and the provision of alarming dosiesters for radiographer You are required to respond to this letter and should follow the instructions aspecified in the enclose,d Notice when preparing your response. In your response, '

you should document the specific actions taken and any additional actions you plan to prevent recurrence. After reviewing your response to this Notice, including your proposed corrective actions, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirement In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, l Title 10, Code.of Federal Regulations, a copy of this letter and its enclosure l will be placed in the NRC Public Document Roo !

The responses directed by this letter and the enclosed Notice are not subject i to the clearance procedures of the Office of Management and Budget as required I by the Paperwork Reduction Act of 1980, PL 96-51

Sincerely, ORIGINAL. SIGNED BY !

ROBERT D. MARTIN  !

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Robert D. Martin ,

Regional Administrator !

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Notice of Violation and Proposed Imposition l

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of Civil Penalty

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H & G Inspection Company, In JUL 211986 Distribution bec w/ enc 1:

SECY PDR CA Taylor, IE Axelrad, IE Goldsmith, IE Lieberman, OGC J. Sniezek, DED/ROGR Enforcement Officers RI, RII, RIII, RV F. Ingram, PA J. Crooks, AEOD B. Hayes, OI S. Connelly, OIA L. Cobb, IE V. Miller, NMSS D. Nussbaumer, OSP IE/ES file IE/EA file EDO Rdg file BSummers, IE (1tr bd)

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. RIV Distribution:

Regional Administrator, RMartin Division Director, DRSS Branch Chief, RS Section Chief, NMSS Inspector (2 copies)

CWisner (1tr hd)

RDoda DPowers RIV Files

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