IR 015000042/1992001
| ML20044H515 | |
| Person / Time | |
|---|---|
| Site: | 015000042 |
| Issue date: | 06/02/1993 |
| From: | Fisher W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20044H513 | List: |
| References | |
| 15000042-92-01, 15000042-92-1, NUDOCS 9306090136 | |
| Download: ML20044H515 (5) | |
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APPENDIX U.S. NUCLEAR REGULATORY COMMISSION
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REGION IV
NRC. Inspection Report:
15000042/92-01 License:
General License 150.20 Docket:
15000042 Licensee:
Panhandle N.D.T. & Inspection, Inc.
1203 Industrial Blvd.
Borger, Texas 79008
Inspection At:
Panhandle N.D.T. & Inspection, Inc.
Borger, Texas inspection Conducted:
April 23-24, 1992
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Inspector:
Selvan Rajendran, Radiation Specialist Nuclear Materials Licensing Section Accompanied By:
Daniel R. Gietl Office of Investigations
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William L. Fisher, Chief, Nuclear Materials Date Licensing Section i
Inspection Summary Inspection conducted April 23-24. 19sc (NRC Inspection Report 15000042/92-01)
L Areas inspected:
This was a special, unannounced, radiation safety inspection of a general licensee using byproduct material to conduct radiography in NRC jurisdiction.
The inspection included a review of organization-and-management, radiation protection, and instrumentation.
Results:
In the areas inspected, three apparent violations were identified:
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(1) f ailure to file for reciprocity during calendar year 1991 and during 1992 until March of that year (paragraph 4); (2) performing radiography without the radiographer and radiographer's assistant wearing an alarm ratemeter (paragraph 5); and (3) failure to calibrate survey instruments at 3-month'
intervals (paragraph 6),
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9306090136 930604 PDR STPRG ESGTX
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DETAILS 1.
Persons Contacted
- 0rvil Couch, President, Radiation Safety Officer
- Norman Reneau, Field Supervisor Jenaro Robles, Radiographer Steve Robles, Radiographer's Assistant J. C. Couch, Radiographer John K. Reynolds, Radiographer
- Indicates those present during exit interview.
2.
Follow-up on Previous Violations (0 pen) (15000035/90-01) Violation of 10 CFR 150.20(b) - Failure to file with the Nuclear Regulatory Commission a " Report of Proposed Activities in Non-Agreement States."
3.
Previous Histor_y On November 24, 1989, a Confirmation of Action Letter (CAL) was issued to-Panhandle N.D.T. & Inspection, Inc. (Panhandle) for failing to file reports with NRC in regard to radiographic operations in the state of Oklahoma. On
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January 18, 1990, a Notice of Violation (NOV) was issued for this' failure.
On January 25, 1990, Panhandle responded to the NOV. An acknowledgement letter
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was sent to the licensee on February 1, 1990.
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On June 20, 1990, Panhandle was granted reciprocity approval by telephone for
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work in Oklahoma on June 26-27, 1990. On July 3,1990, a letter was sent:to-Panhandle to acknowledge receipt of an NRC Form 241 covering thi-.
.ity.
On July 19, 1990, Panhandle was granted reciprocity approval by telephone for work in Oklahoma on July 25-26, 1990. On July 27,'1990, a letter was sent'to
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Panhandle to acknowledge receipt of a Form 241 covering this work.
Panhandle requested no more reciprocity until April 22, 1992, when it requested reciprocity for work in Oklahoma on April 29-30,-1992. On April 28, 1992, the Panhandle request was denied orally, based on the apparent findings of this inspection.
The denial was confirmed in a CAL issued that same. day.
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On May 4, 1992, a Form 241 and a $600 check covering this work were returned by mail to Panhandle.
iio apro. e.it violations were toentified.
4.
Licensed Program Panhandle is licensed by the state of Texas (License LO 2627) to perform industrial radiography using sealed sources of iridium-192.
Panhandle has worked in Texas, and in New Mexico during 1991, and Oklahoma during 1991.and 1992.
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At the time of this inspection, Panhandle employed nine radiographers and one helper.
Its radiation safety program was managed by Orvil Couch and Norman Reneau.
10 CFR 150.20(b) requires, in part, that Agreement State licensees desiring to operate in a Non-Agreement State shall, at least 3 days before engaging in each such activity, file four copies of Form-241 (revised), " Report of Proposed Activities in Non-Agreement States," and four copies of its Agreement State specific license with the Regional Administrator of the NRC Region in which the Agreement State which issued the license is located. During this
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inspection, Panhandle was determined to have worked in NRC jurisdiction (Oklahoma) on June 11 and December 12, 1991, and March 5, 16-17, and 18, 1992, without having obtained reciprocity from NRC.
This was identified as an apparent repeat violation of 10 CFR 150.20(b).
One apparent violation was identified.
5.
Radiation Protection
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Panhandle used a monthly film badge service, the results of which were reported on monthly exposure reports, which the Radiation Safety Officer (RS0)
stated that he reviewed. A review of dosimetry records for the periods that Panhandle worked in NRC jurisdiction indicated that the individuals involved in the activities had not exceeded quarterly exposure limits.
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The inspector observed that each individual was assigned a film badge and a pocket dosimeter.
Pocket dosimeter response was checked annually, as
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required.
Pocket dosimeter readings at the end of each shift were recorded on
the licensee's utilization logs.
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The general license granted under 10 CFR Part 150.20 requires, in part, that
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notwithstanding any provision to the contrary in any specific license issued
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by an Agreement State, activities conducted in the Non-Agreement State must comply with the provisions of Subpart B of-10 CFR Part 34.
Subpart B of 10 CFR Part 34 includes paragraph 34.33(a), which states that the licensee may not permit any individual to act as a radiographer or
radiographer's assistant unless, at all times during radiographic operations,
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the individual wears a direct reading pocket dosimeter, an alarm ratemeter, and either a film badge or a thermoluminescent dosimeter.
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Interviews with licensee personnel engaged in radiographic-operations in Oklahoma disclosed that the licensee had not provided tnem. alarm ratemeters.
Specifically, persons interviewed stated that alarm ratemeters had not been available or worn during radiographic operations conducted in Oklahoma by Panhandle on June 11 and December 12, 1991, and March 5, 16-17, and 18, 1992.
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Failure of personnel engaged in radiographic operations to wear alarm i
ratemeters was identified as an apparent violation of 10 CFR 34.33(a).
One apparent violation was identified.
6.
Survey Instruments The inspector noted that the licensee had provided an adequate number of
survey instruments to each radiography crew.
10 CFR 34.24 requires, in part, that radiation survey instruments used to perform radiation surveys as-required by Part 34 and Part 20 be calibrated at intervals not to exceed 3 months.
The inspector reviewed meter calibration records and noted that survey instruments were calibrated annually, as required by the' Texas regulations, rather than every 3 months.
Specifically, a Bicron survey meter (Serial No. A 789X) used on radiography jobs on March 16-17, and 18, 1992, had not been calibrated since November 11, 1991.
The failure to calibrate the survey instrument at 3-month intervals was identified as an apparent violation of 10 CFR 34.24.
One apparent violation was identified.
7.
Exit Interview The inspector met with licensee personnel (identified in Section 1) at the conclusion of the inspection to review the specific findings as presented in this report.
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SYN 0PSIS i
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On March 23, 1992, the Office of Investigations (01), Nuclear Regulatory Commission (NRC), Region IV, initiated an investigation to determine whether Panhandle N.D.T. & Inspection, Inc. (Pannandle), Borger, Texas, deliberately
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con' ducted radiographic operations in NRC's jurisdiction without submitting the recuired Form 241 to obtain reciprocity.
The 01 investigation substantiateo the allegation that Panhandle conducted
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radiographic operations in NRC jurisdiction in 1991 and 1992 without filing.
- the required Form 241 and obtaining reciprocity. The investigation determined that Panhandle, while fully aware of the requirement to file the Form 241 before doing radiographic work in NRC jurisdiction, deliberately decided not l
to file the Form 241.
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The investigation also determined that Panhandle deliberately had not
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purchased and therefore Panhandle radiographers had not used ratemeters while performing radiography within NRC's jurisoittion.
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Case No. 4-92-004
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