ML19261A638
| ML19261A638 | |
| Person / Time | |
|---|---|
| Issue date: | 01/10/1979 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19261A637 | List: |
| References | |
| NUDOCS 7902050261 | |
| Download: ML19261A638 (3) | |
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APFENDIX A NOTICE OF VIOLATION Trans-Eastern Inspection Services, Incorporated License No. 37-14855-01 Washington, Pennsylvania 15301 This refers to the inspection conducted by Messrs. F. Costello and J. Davis of our Region I (Philadelphia) office at field sites in Jeannette and Philadelphia, Pennsylvania and your office in Washington, Pennsylvania, of activities authorized by NRC License No. 37-14855-01.
The inspection was an examination of activities conducted under your license as they relate to radiation safety and to compliance with the Commission's rules and regulations and the conditions of your license.
The inspectica consisted of selective examinations of procedures and representatiie records, interviews with personnel, measurements made by the inspector, and observations by the inspector.
During this inspection, ccnducted on November 14, 16 and 17, 1978, the following apparent items of noncompliance were identified.
A.
Condition 16 of your license requires that you possess and use licensed material in accordance with the statements, representations, and procedures contained in certain referenced documents.
One of these documents is your Radiation Safety and Operating Procedure Manual submitted as an attachment to your letter dated February 20, 1974.
Revised copies of Pages 10 and 13 of this Manual were provided with your letter dated May 7, 1974.
1.
Section III, Item G.3.c (page 19) and Item H.7 (page 19a) of the Manual require that the radiographer survey the perimet.er of the restricted area once radiographic sources are exposed.
Contrary to this requirement, radiographers in your employ did not survey the boundaries of the restricted areas while using Gamma Industries Pipeliners at a field site in Waynesburg, Pennsylvania, in June 1978, and using a Panoramic-type exposure Jevice at a field site in Philadelphia, Pennsylvania on November 14, 1978.
Further, the radiographer failed to make a similar survey on November 16, 1978, using a Panoramic-type exposure device at a field site in Jeannette, Pennsylvania.
This is an infraction.
7902050.26/'.
Appendix A 2.
Section III, Item G.3.1 (page 19a) of the Manual requires that, when using a Panoramic-type exposure device, the radio-grapher survey the entire length of the guide tube once the source has been retracted.
Contrary to this requirement, on liovember 14, 1978, at a field site in Philadelphia, Pennsylvania, a radiographer in your employ failed to perform the required survey.
This is an infraction.
3.
Appendix A (page 28) of the Manual requires that, when not in use, all radiographic exposure devices be stored within the mobile iadiographic unit.
Contrary to this requirement, during November 1978, you stored a radiographic exposure device at a customer's facility in Jeannette, Pennsylvania.
This is a deficiency.
4.
Appendix F, Item A (page 34) of the Manual requires that unannounced inspections of every radiographer and radiographer's assistant be conducted at 90 day intervals by certain named members of management, one of whom is the Radiation Safety Officer.
Contrary to this requirement, during 1978, the required management audits were delegated by the Radiation Safety Officer to another member of management.
This delegation and the credentials of the individual involved had not been submitted to and approved by the NRC's License fianagement Branch.
This is a deficiency.
5.
Section II, Item A.6 under " Physical Radiation Surveys" (page 9),
of the Manual requires that records of surveys of the restricted area boundary be maintained on the weekly radiation survey report.
Contrary to this requirement, a radiographer in your employ failed to maintain records of the surveys of the restricted area boundary for work performed at field sites in Philadelphia, Pennsylvania, during October and flovember,1978.
This is a deficiency.
Appendix A 6.
Section II, Item B.4, under " Personnel Monitoring Equipment,"
(page 8) of the Manual requires that each radiographer record his dosimeter reading on the weekly radiation survey repurt on a daily basis.
Contrary to this requirement, on November 15, 1978, at a field site in Philadelphia, Pennsylvania, a radiographer in your employ failed to record his dosimeter reading at the end of the day.
This is a deficiency.
B.
10 CFR 20.105(b) requires that radiation levels in unrestricted areas be limited so that if an individual were continuously present in the area, he could not receive a dose in excess of 2 millirems in any one hour or 100 millirems in any seven consecutive days.
Contrary to this requirement, on November 16, 1978, an individual continuously present outside a building in Jeanette, Pennsylvania, in which a radiographer in your employ was conducting radiography, could have received a dose of 3 to 5 millirems in any one hour in an area between a rope and the building where radiography was being performed.
While a rope had been placed outside the building, access to the area was not controlled as required for restricted areas.
This is an infraction.
C.
Condition 9.C of your license limits the use of Gamma Industries Pipeliners to the performance of industrial radiography.
Contrary to this requirement, during June 1978, at a field site in Waynesburg, Pennsylvania, radiographers in your employ used a 35 curie and a 58 curie iridium-192 source in a Gamma Industries Pipeliner as a source of radiation to control the operation of a portable X-Ray unit, a use not authorized by your license.
This is an infraction.
This notice is sent to you pursuant to the provision of Section 2.201 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations.
Section 2.201 requires you to submit to this office, within twenty (20)
~
days of your receipt of this notice, a written statement or explaration in reply including:
(1) corrective steps which have been taken by you and the results achieved; (2) corrective steps which will be taken to avoid further items of noncompliance; and (3) the date when full compli-ance will be achieved.
APPENDIX B Trans-Eastern In:pection Services, Incorporated Enforcement History February 26, 1975 to November 17, 1978 License No. 37-14855-01 Docket No. 30-8168 MANAGEMENT MEETING Date Problem Initiating Action /Results March 18,1975 75-01 Inspection findings indicated lack of management control / licensee committed to improved tra
..ng program and management control system.
August 16, 1977 77-02 Inspection findings indicated lack of manage-ment control / licensee committed to hiring Radiation Safety Officer and outside consultant.
NONCOMPLIANCE ITEMS Inspection Citation 75-01 A.
Exposure in excess of 1.25 rem, but less than (Inspection at 3 rem, without AEC-4 forms (3 individuals) home office on (10 CFR 20.101) (iafraction) (noted again in February 26,1975) 76-01 )
B.
Failure to provide required training (38 individuals) (10 CFR 34.31) (infraction)
(noted again in 77-02)
C.
Failure to perform required audits (License Condition 16) (infraction) (noted again in 77-02 and 78-01)
D.
Failure to conduct adequate inspection and maintenance program (10 CFR 34.28) (infraction)
(noted again in 77-02 and 78-01)
E.
Failure to report overexposures in A (10 CFR 20.405) (infraction) (noted again in 76-01) 75-02 A.
Failure to establish adequate procedures for (Inspection at opening packages (10 CFR 20.205) (infraction) home office and one field site on B.
Failure to report fire resulting in property December 10,1975) damages in excest of $1,000.00 (10 CFR 20.403 (b)(4)) (infracti-s)
Appendix B Inspection Citation 76-01 A.
Exposure of 4.5 rem to whole body (one individual)
(Inspection at (10 CFR 20.101) (infraction) (noted previously home office and in 75-01)'
one field site on May 19 and B.
Failure to report overexposure in A.
(10 CFR 27, 1976) 20.405 and 19.13(a)) (infraction) (noted previously in 75-01)
C.
Failure to survey radiographic exposure area and failure to survey to ensure source had returned to shielded position (two examples, one resulted in exposure in A) (10 CFR 20.201(b) with renard to 20.101) (infraction) (noted again in 76-
?,.
77-02,78-03)
D.
Failure to submit termination reports (40
'di-viduals) (10 CFR 20.408) (deficiency) 76-02 A.
Failure to survey to ensure that source had (Inspection at returned to shielded position (one example) home office and (10 CFR 34.43(b)) (infraction) (noted previously one field site on in 76-01 and again in 77-02 and 78-03)
August 11 and 12,1976) 77-01 i o items of noncompliance identified.
Inspection (Limited limited to review of 14.5 R film badge reading.
The inspection at inspectors ccicurred in the licensee's finding home office on that no actual exposure to the individual had June 14, 1977) occurred.
77-02 A.
Failure to provide required training to radio-(Inspection at graphic personnel (10 CFR 19.12) (infraction) home office and (noted previously in 75-01) three field sites on July 19-20 and B.1 Failure to perform required audits (License August 1,1977)
Condition 16) (infraction) (noted previously in 75-01 and again in 78-01)
B.2 Failure to perform inspection and maintenance (License Condition 16) (infraction) (noted previously in inspection 75-01 and again in 78-01)
Appendix B Inspection Citation B.3 Failure to perform daily inspection (License Condition 16) (infraction)
B.4 Failure to perform survey of guide tube to ensure source had returned to shielded position (License Condition 16) (infraction) (noted pre-viously in 76-01 and 76-02 and again in 78-03)
C.
Failure to wear and charge dosimeter daily (10 CFR 34.33(a)) (infraction)
D.
Failure to survey boundary of restricted area (10 CFR 20.201(b) RE 20.105) (infraction)
(noted again in 78-03)
E.
Failure to maintain direct surveill ance of radiographic area (10 CFR 34.41) (infraction)
F.
Failure to lock expositre device when not under direct surveillance (10 CFR 34.22) (infraction)
G.
Radiation levels in excess of limits in unre-stricted area (10 CFR 20.105(b)) (infraction)
(noted again in 78-03) 78-01 A.1 Failure to conduct requir.d audits (License (Inspection at Condition 16) (infraction) (noted previously
.sme office and in 75-01 and 77-02) one field site on February 23,1978) A.2 Failure to conduct adequate inspection and main-tenance program (License Condition 16) (infraction)
(noted previously in 75-01 and 77-02)
B.
Failure to read and record pocket dosimeters daily (10 CFR 34.33(b)) (infraction) 78-02 No items of noncompliance identified (Inspection at home office on July 20, 1978)