Information Notice 1988-66, Industrial Radiography Inspection and Enforcement

Industrial Radiography Inspection and Enforcement

ML031150170
Person / Time
Site:	Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Kewaunee, Catawba, Harris, Wolf Creek, Saint Lucie, Point Beach, Oyster Creek, Watts Bar, Hope Creek, Grand Gulf, Cooper, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Three Mile Island, Braidwood, Susquehanna, Summer, Prairie Island, Columbia, Seabrook, Brunswick, Surry, Limerick, North Anna, Turkey Point, River Bend, Vermont Yankee, Crystal River, Haddam Neck, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Duane Arnold, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Yankee Rowe, Maine Yankee, Quad Cities, Humboldt Bay, La Crosse, Big Rock Point, Rancho Seco, Zion, Midland, Bellefonte, Fort Calhoun, FitzPatrick, McGuire, LaSalle, 05000000, Zimmer, Fort Saint Vrain, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant
Issue date:	08/22/1986
From:	Cunningham R NRC/NMSS/IMNS
To:
References
IN-88-066, NUDOCS 8808160392
Download: ML031150170 (8)

I

UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICI O[ NUCLEAR MATERIAL SAFETY AND SAFEGUARDS

WASHINGTON, D.C. 20555 August 22, 1988 NRC INFORMATIlON NOTICE No. 88-66: INDUSTRIAL RADIOGRAPHY INSPECTION AND

ENFORCEMENT

Addressees

All NRC industriel raoiography licensees.

Purpose

This irnformation notice is being provided to emphasize the importance of compli- ance with NRC regulations ir all aspects of industrial radiography. Recipients

should review the information for applicability to their operations to ensure

that all radiography personnel are fully trained anc qualified and that they

conduct operations in accordance with all applicable requirements. It is ex- pected that licensees will review this notice, distribute it to responsible

radiation staff, and consider actions, as appropriate, to avoid similar problems.

However, suggestions contained in this information notice do not constitute any

new NRC requirements and no written response is required.

Description of Circumstances

In August 1987, the NRC received allegations that Finlay Testing Laboratories, Inc. ?FTL) of Aiea, Pavieii, was improperly transporting radiographic exposure

devices containing radioactive sources on passenoier-carrying aircraft. The NRC

Region V office conducted an inspection, and the Office of Investigations (01)

investigated possible wrongdoing. These efforts revealed numerous instances

where FIL personnel concealed radiographic exposure aevices containing radio- active naterial, so as to transport them on passenger-carrying civilian and

military flights. These actions, which violated NRC and U.S. Department of

Transportation (DOT) regulations, apparently were taken to avoid the inconvenience

of shipping devices cortaining radioactive material in the required manner.

Additional inspection findings revealed: (1) failures to survey devices to ensure

that the sources were in the shielded position; (2) individuals acting as radio- graphers and radiographers' assistants without required Part 34 training; (3)

violations of radiation safety programs requirements for posting of radiation

areas, surveillance of restricted areas, and locking of radiographic exposure

devices; (4) use of partially discharged dosimeters; and (C) failures to maintain

required records.

As a result of these findings, the NRC suspended FTL's license and subsequently

issued an order to show cause why the license should not be revoked. In

accordance with a set tlement between the NRC and the licersee, the licerse was

terminated and Gordon Finlay, owner of the licensee, agreed not to perform

80816039/2

IN 88-66 August 22, 1988 certain functions in radiographic operations until September 1990. Mr.

also acreed to provide written notice to the NRC or any Agreement State Firilay

before

performing duties related to any licensed activities for a similar period. I

addition, the matter has been referred to the U.S. Department of Justice

for

investigation of possible criminal wrongdoing.

Discussion:

Licensees are responsibile for ensuring the safe performance of licensed

activities in accordance with NRC regulations and the terms of their licenses.

In so doing, licensees should not only use trained individuals, provide

procedures and maintain accurate records, but should also exercise close adequate

supervision over their employees to ensure compliance with procedures and

NRC and any other applicable requirements. Licensees are also responsible with

for ensuring that an employee's prior experience, if any, has been satisfactory

and complies with regulatory requirements.

Transportation of radiographic material, with its potential for impact

on the

public health and safety, is a matter of significant regulatory concern.

case highlights the need to ensure that material is packaged and shipped This

in ap- proved ways to avoid potential exposure to the public.

Moreover, the NRC will not excuse licensee employee violations in radiography

operations because management was unaware of-the yiolations-;becauste

eyployees were-notitrainea to recognize applicable regulatory requirements;.

or

because compliance with the applicable regulations would have been inconvenient.

Similarly, violations ot NRC requirements caused by inattention to detail

unacceptable and may result in substantial civil enforcement action. In are

addition, violations caused by intentional acts may subject wrongdoers to criminal

prosecution. As evidenced by the cases described in Intormation Notice

'Criminal Prosecution of a former Radiation Safety Officer who Willfully 86-54, Directed an Unqualified Individual to Perform Radiography," and Information

Notice 87-64, "Conviction for Falsification of Security Trairing Records,"

criminal sanctions may include a fine and/or imprisonment.

No written response is required by this information notice. If you have

any

questions about this matter, please call the technical contact listed below

or the appropriate NRC Regional Office.

Richard E. Cunningham, Director

Division of Industrial and

Medical Nuclear Safety, NMSS

M. Lamastra, NMSS

(301) 492-3416 Attachment: List of Recently Issued NRC Information Notices

1 e

Attachment

IN 88-66 August 22, 3986 Page 1 ot 1 LIST OF RECENTLY ISSUED

NPC INFORMATION NOTICES

Infortiation Date of

Notice No. Subject Issuance Issued to

88-65 Inadvertent Drainages of 8/18/88 All holders of OLs

Spent Fuel Pcols or CPs for ruclear

power reactors and

fuel storage facilities.

88-64 Reporting Fires in Nuclear 8/18/88 All holders of GLs

Process Systems at Nuclear or CPs for nuclear

Power Plants power reactors.

88-63 High Radiation Hazards 8/15/88 All holders of OLs

from Irradiated Incore or CPs for nuclear

Detectors and Cables power reactors, research reactors

and test reactors.

88-62 Recent Findings Concerning 8/12/88 All holders of NRC

Implementation of Quality quality assurance

Assurance Programs by program approval

Suppliers of Transpcrt for radioactive

Packages material packages.

68-61 Control Room Habitability - F/11/88 All holders of OLs

Recent Reviews of Operating or CPs for nuclear

Experience power reactors. .

Inadequate Desigr. ard 8/11/82 All holders of OI.s

Installation of Watertight or CPs for nuclear

Penetration Seals power reactors.

88-04, !nadequate Qual ificatiorn 8/9/88 All holders of OLs

Supplexpert I and Documentation of Fire or CPs for nuclear

Earrier Penetration Seals power reactors.

88-59 Main Stean, Isolation Valve 8/9/68 All holders of OLs

Guide Pail Failure at or CPs for nuclear

Waterford Unit a power reactors.

88-5c Potential Problems with 6/8/88 All holders of OLs

ASFA Brown Beveri IlE-511t or CPs for nuclear

Time-Overcurrent Relays power reactors.

OL = Operaterin License

CP = Construction Permit

IN 88-66 August 22, 1988 certain functions in radiographic operations until September 1990. Mr. Finlay

also agreed to provide written notice to the NRC or any Agreement State before

performing duties related to any licensed activities for a similar period. In

addition, the matter has been referred to the U.S. Department of Justice for

investigation of possible criminal wrongdoing.

Discussion:

Licensees are responsibile for ensuring the safe performance of licensed

activities in accordance with NRC regulations and the terms of their licenses.

In so doing, licensees should not only use trained individuals, provide adequate

procedures and maintain accurate records, but should also exercise close

supervision over their employees to ensure compliance with procedures and with

NRC and any other applicable requirements. Licensees are also responsible

for ensuring that an employee's prior experience, if any, has been satisfactory

and complies with regulatory requirements.

Transportation of radiographic material, with its potential for impact on the

public health and safety, is a matter of significant regulatory concern. This

case highlights the need to ensure that material is packaged and shipped in ap- proved ways to avoid potential exposure to the public.

Moreover, the NRC will not excuse licensee employee violations in radiography

operations because management was unaware of the violations; because the

employees were not trained to recognize applicable regulatory requirements; or

because compliance with the applicable regulations would have been inconvenient.

Similarly, violations of NRC requirements caused by inattention to detail are

unacceptable and may result in substantial civil enforcement action. In addition, violations caused by intentional acts may subject wrongdoers to criminal

prosecution. As evidenced by the cases described in Information Notice 86-54,

"Criminal Prosecution of a former Radiation Safety Officer who Willfully

Directed an Unqualified Individual to Perform Radiography," and Information

Notice 87-64, "Conviction for Falsification of Security Training Records,"

criminal sanctions may include a fine and/or imprisonment.

No written response is required by this information notice. If you have any

questions about this matter, please call the technical contact listed below

or the appropriate NRC Regional Office. IS

Richard E. Cunningham, Director

Division of Industrial and

Medical Nuclear Safety, NMSS

M. Lamastra, NMSS

(301) 492-3416 Attachment: List of Recently Issued NRC Information Notices

MKing *EKraus 8/2/88 *SEE PREVIOUS CONCURRENCE

OFC: *IMAB *IMOB *IMAB *IMOB *IMOB *OE *OGC *IMNS IMNS

_-__-__-_-_-_______________-___-_-__-______-________________-_______

NAME: MLamastra JMetzger VMiller DACool JHickey JLieberman SLewis RHall RECunningham

DATE: 8/03/88 8/03/88 8/03/ 8/15/88 8/05/88 (1/7/88

IN 88- Date: As a result of these findings, the NRC suspended FTL's license and subsequently

issued an order to show cause why the license should not be revoked. In

accordance with a settlement between the NRC and the licensee, the license was

terminated and Gordon Finlay, owner of the licensee, agreed not to perform

certain functions in radiographic operations until September 1990. Mr. Finlay

also agreed to provide written notice to the NRC or any Agreement State before

performing duties related to any licensed activities for a similar period.

In addition, the matter has been referred to the U.S. Department of Justice for

investigation of possible criminal wrongdoing.

Discussion:

Licensees are responsibile for ensuring the safe performance of licensed

activities in accordance with NRC regulations and the terms of their licenses.

In so doing, licensees should not only use trained individuals, provide adequate

procedures and maintain accurate records, but should also exercise close

supervision over their employees to ensure compliance with procedures and with

NRC and any other applicable requirements. Licensees are also responsible

for ensuring that an employee's prior experience, if any, has been satisfactory

and complies with regulatory requirements.

Transportation of radiographic material, with its potential for impact on the

public health and safety, is a matter of significant regulatory concern. This

case highlights the need to ensure that material is packaged and shipped in

approved ways to avoid potential exposure to the public.

Moreover, the NRC will not excuse licensee employee violations in radiography

operations because management was unaware of the violations; because the

employees were not trained to recognize applicable regulatory requirements; or

because compliance with the applicable regulations would have been inconvenient.

Similarly, violations of NRC requirements caused by inattention to detail are

unacceptable and may result in substantial civil enforcement action. In addition, violations caused by intentional acts may subject wrongdoers to criminal

prosecution. As evidenced by the cases described in Information Notice 86-54,

"Criminal Prosecution of a former Radiation Safety Officer who Willfully

Directed an Unqualified Individual to Perform Radiography," and Information

Notice 87-64, "Conviction for Falsification of Security Training Records,"

criminal sanctions may include a fine and/or imprisonment.

No written response is required by this Information Notice. If you have any

questions about this matter, please call the technical contact listed below

or the appropriate NRC Regional Office.

Richard E. Cunningham, Director

Division of Industrial and

Medical Nuclear Safety, NMSS

M. Lamastra, NMSS

(301) 492-3416 Attachment: List of Recently Issued NRC Information Notices

MKing *EKraus 8/2/88 *SEE PREVIOUS CONCURRENCE

mFC: *I;B *IMOB *IMAB *IMOB *IMOB *OE *OGC *IMNS IMNS

-___

_-----------------------------------------------------_-

%wuP-

NAME: Mlamastra JMetzger VMiller DACool JHickey JLieberman SLewis RHall RECunningham

DATE: 8/03/88 8/03/88 8/03/88 8/05/88 8/05/88 8/15/88 8/15/88 8/05/88 5"/7/;88 UtHIFIAL KLUUMD CUPY

IN 88- Date: As a result of these findings, the NRC suspended FTL's license and subsequently

issued an order to show cause why the license should not be revokeri In

accordance with a settlement between the NRC and the licensee, thtlicense was

terminated and Gordon Finlay, owner of the licensee, agreed notAb*perform

certain functions in radiographic operations until September . Mr. Finlay

also agreed to provide written notice to the NRC or any AgreQ nt State before

performing duties related to any licensed activities for a Smilar period.

In addition, the matter has been referred to the U.S. De - tment of Justice for

investigation of possible criminal wrongdoing.

Discussion:

Licensees are responsibile for ensuring the safe grformance of licensed

activities in accordance with NRC regulations aW* the terms of their licenses.

In so doing, licensees should not only use trigged individuals, provide adequate

procedures and maintain accurate records, bu ~hould also exercise close

supervision over their employees to ensure mpliance with procedures and with

NRC and any other applicable requirements Licensees are also responsible

for ensuring that an employee's prior ex i ience, if any, has been satisfactory

and complies with regulatory requiremen .

Transportation of radiographic materi , with its potential for impact on the

public health and safety, is a matte jof significant regulatory concern. This

case highlights the need to ensure at material is packaged and shipped in

approved ways to avoid potential ext sure to the public.

Moreover, the NRC will not excuse 'icensee employee violations in radiography

operations because management was naware of the violations; because the

employees were not trained to re gnize applicable regulatory requirements; or

because compliance with the appl cable regulations would have been inconvenient.

Similarly, violations of NRC re irements caused by inattention to detail are

unacceptable and may result in evere civil enforcement action. In addition, violations caused by intentio 1 acts may subject wrongdoers to criminal

prosecution. As evidenced by he cases described in Information Notice 86-54,

"Criminal Prosecution of a f r Radiation Safety Officer who Willfully

Directed an Unqualified Ind idual to Perform Radiography," and Information

Notice 87-64, "Conviction f r Falsification of Security Training Records,"

criminal sanctions may inc de a fine and/or imprisonment.

No written response is r uired by this Information Notice. If you have any

questions about this mat r, please call the technical contact listed below

or the appropriate NRC gional Office.

Richard E. Cunningham, Director

Division of Industrial and

Medical Nuclear Safety, NMSS

Technical Contac4PM. Lamastra, NMSS

(301) 492-3416 Attachment: List of Recently Issued NRC Information Notices ad- MKing *EKraus 8/2/88 *SEE PREVIOUS CONCWRENCE VApO

OFC: *IMAB *IMOB *IMAB *IMOB *IMOB 7,2QEX *IMNN IMNS

NAME: MLamastra JMetzger VMiller DACool JHickey JLieberman w"I 1allRECunningham

DATE: 8/03/88 8/03/88 8/03/88 8/05/88 8/05/88 / /88 V/1?1/88 8/05/88 / /88 OFFICIAL RECURD COPY

IN 88- Date: a result of these findings, the NRC suspended FTL's license and subsequently

issued an order to show cause why the license should not be revoked .6&tYn

accrdance with a settlement between the NRC and the licensee, the-,Oicense was

ternjiated and Gordon Finlay, owner of the licensee, agreed not *Ztperform

certa\p functions in radiographic operations until September 1 . Mr. Finlay

also areed to provide written notice to the NRC or any Agre *nt State before

perform kg duties related to any licensed activities for a imilar period.

In additibp , the settlement does not preclude other inve igations of possible

criminal wfvngdoing.

Discussion: 4 Licensees are restonsibile for ensuring the safe. rformance of licensed

activities in accof~ance with NRC regulations the terms of their licenses.

In so doing, licenseis should not only use try ed individuals, provide adequate

procedures and maintat,,accurate records, be should also exercise close

supervision over their 4*ployees to ensure $iompliance with procedures and with

NRC and any other applicable requirement' Licensees are also responsible

for ensuring that an employee's prior ei<<erience, if any, has been satisfactory

and complies with regulatort.requirem \ s.

- . 4,"

Transportation of radiographic'tetial, with its potential for impact on the

public health and safety, is a m er of significant regulatory concern. This

case highlights the need to ensuj '$hat material is packaged and shipped in

approved ways to avoid potentifexl ure to the public.

Moreover, the NRC will not e use licensee employee violations in radiography

operations because management was unawar f the violations; because the

employees were not traine- o recognize ap oicable regulatory requirements; or

because compliance with $ e applicable regu ltions would have been inconvenient.

Similarly, violations of.NRC requirements causd by inattention to detail are

unacceptable and may r ult in severe civil enf-cement action. In addition, violations caused by fitentional acts may subject Wongdoers to criminal

prosecution. As evi. nced by the cases described MInformation Notice 86-54,

"Criminal Prosecuted of a former Radiation Safety 0fficer who Willfully

Directed an Unqua led Individual to Perform Radiogra and Information

Notice 87-64, "Cguviction for Falsification of Security Jkaining Records,"

criminal sancti~is may include a fine and/or imprisonment.>-;

No written re onse is required by this Information Notice. Yf you have any

questions abI t this matter, please call the technical contact lipted below

or the appr riate NRC Regional Office. X

Richard E. Cunningham, Director

Division of Industrial and

I Medical Nuclear Safety, NMSS 5tA

TechnI/~al Contact: M. Lamastra, NMSS M

(301) 492-3416 At hment: List of Recently Issued NRC Information Notices "'f.

M~y *EKraus 8/2/88 *SEE PREVIOUS CONCURRENCE VA.

YFC: *IMAB *IMOB *I AB ' If OE OGC IMNS IMNS

- - - ------------- ff-----

t-------

- ---

NAME: MLamastra JMetzger VMiller DACool JHid ey JLieberman SLewis iHall RECunningham

DATE: 8/03/88 8/03/88 8/03/88 J4 88 14f,/88 /88 / 88 F/'c/88 /88 OFFICAL RECOR LUPY

IN 88- Date: As a result of these fin4ings, the NRC suspended FTL's license and subsequently

issued an order to show &use why the license should not be revoked. In

accordance with a sett emet between the NRC and the licensee, the license was

terminated and Gordon Finl 'I, owner of the licensee, agreed not to perform

certain functions in radiogVtphic operations until September 1990. Mr. Finlay

also agreed to provide writtft notice to the NRC or any Agreement State before

performing duties related to y licensed activities for a similar period.

In addition, the matter-ha --referred-to-the-US,--De-partnent--of-J-ustce-f4or

investigationsof possible crimiI1 wrongdoing. 4 &/1 -<'1 fU44e 4 Discussion:

Licensees are responsibile for ens ing the safe performance of licensed

activities in accordance with NRC r ulations and the terms of their licenses.

In so doing, licensees should not on use trained individuals, provide adequate

procedures and maintain accurate reco s, but should also exercise close

supervision over their employees to endre compliance with procedures and with

NRC and any other applicable requiremen . Licensees are also responsible

for ensuring that an employee's prior e rience, if any, has been satisfactory

and complies with regulatory requirements

Transportation of radiographic material, w its potential for impact on the

public health and safety, is a matter of sig ificant regulatory concern. This

case highlights the need to ensure that mater 1 is packaged and shipped in

approved ways to avoid potential exposure to t public.

Moreover, the NRC will not excuse licensee emplo violations in radiography

operations because management was unaware of the v lations; because the

employees were not trained to recognize applicable gulatory requirements; or

because compliance with the applicable regulations ld have been inconvenient.

Similarly, violations of NRC requirements caused by i ttention to detail are

unacceptable and may result in severe civil enforcemen action. In addition, violations caused by intentional acts may subject wrong ers to criminal

prosecution. As evidenced by the cases described in Inf mation Notice 86-54,

"Criminal Prosecution of a former Radiation Safety Officeiiwho Willfully

Directed an Unqualified Individual to Perform Radiography,\and Information

Notice 87-64, "Conviction for Falsification of Security Trai ing Records,"

criminal sanctions may include a fine and/or imprisonment.

No written response is required by this Information Notice. I>4ou have any

questions about this matter, please call the technical contact 1ited below

or the appropriate NRC Regional Office. \ 5t '.,4 Richard E. Cunningham, Dire or

Division Q*-Fu41_LycLe,_Fedi.gl, Ac demic- d-Comnwerc~a l4Use '*afetyj

Technical Contact:

M. Lamastra, NMSS Adr- a f

(301) 492-3416 Attachment: List of Recently Issued NRC Information Notices

MKing E aus .K l a--S te S I

OFC: IMAB/ IMB IR IMOB IMOB IMNS IMNS

---

V r----- -- ---------------------------------------------- ______

NAME: ML stra JMe -ge--- er DACool JHickey RHall RECunningham

DATE:' / 88 '/', /88 C/3/88 4 88 4 88 / /88 / 88 UFtCIIAL MtUME LUFY