ML19276J527
| ML19276J527 | |
| Person / Time | |
|---|---|
| Issue date: | 04/10/1980 |
| From: | Brown G, Cain C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19276J522 | List: |
| References | |
| 80-01, 80-1, NUDOCS 8007020937 | |
| Download: ML19276J527 (9) | |
Text
'
U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV REPORT OF SPECIAL INSPECTION IE Special Inspection Report No. 80-01 License No. 43-11213-02 Priority:
II Category:
C1 Licensee:
Universal Testing, Inc.
369 West Gregson Avenue Salt Lake City, Utah 84115
Subject:
Licensee Report of 12.8 Rems Whole Body Radiation Exposure to a Radiographer Period of Inapection:
April 1-2, 1980 Inspector:
k d}h 4 flo f90 C. L. Cain, Radiation Specialist Date
_1,/,!47
//
[
/'en 'D Reviewed by:
4f Gl
. Brown, Chie'f, Fuel Taci1ity '
' / Datg
~
and Material Safety Branch Inspection Summary Inspection on April 1-2, 1980 (Report No. 80-01)
Areas Inspected:
Investigation of an apparent whole body exposure in excess of regulatory limits at a radiography facility. Specisl inspection of radiation protection program including organization and administration; training and qualification of personnel;. Licensee internal audits; inspection and maintenance of radiographic equipment; utilization logs and quarterly inventories; uses of materials, facilicies, and equipment; personnel monitoring; leak tests; surveys; posting and labeling; field site inspection; and receiving and shipping of material. The inspection involved seven (7) hours an site by one inspector.
R007020 f y
2 Results: Of the thirteen (13) areas inspected, no items of noncompliance or deviations were identified in eight (8) areas; six (6) apparent items of non-compliance were identified in five (5) areas (violation - exposure of an individual to radiation in a restricted area in excess of 10 CFR 20.101(b)(1) limits, see paragraph 3; infraction - failure to require an individual to disclose prior dose in a written, signed statement, see paragraph 10; infraction - failure to install warning signals, see paragraph 9; infraction -
failure to perform personnel inspection, see paragraph 6; deficiency - failure to maintain record of calibration, see paragraph 9; deficiency - failure to post a high radiation area, see paragraph 14).
REASON FOR SPECIAL INSPECTION The NRC Region IV office was notified by the president, Universal Testing, Inc.,
Salt Lake City, Utah, at 11:20 am on March 28, 1980, that the licensee's film badge processor had reported by telephone to the licensee on March 27 a whole body exposure of a licensee employee in excess of the limits in 10 CFR 20.101(b)(1).
SCOPE OF SPECIAL INSPECTION On April 1-2, 1980, a Region IV inspector visited the licensee's facility for the purpose of investigating the reported incident and performing a routine inspection of all licensed activities.
The inspector reviewed relevant licensee records and interviewed licensee employees.
The radiographer credited with the high exposure, designated as Individual A in this report, was interviewed by telephone.
CONCLUSION The licensee's film badge processor reported an exposure of 12.780 millirems to Individual A for the month of February 1980.
Licensee records indicated that Individual A used an eighty (80) curie irridium-192 source and an x-ray machine during the period in question.
The licensee was unable to identify a cause for the reading which the processor reported to be from a fixed exposure to a low-energy source such as the x-ray machine or to a very high energy dose rate flux for a short time which caused a very sharp filter pattern.
Pocket dosimeter readings for iridium radiography exposure during the quarter totaled 94 millirem.
Consequently, the fact that the radiographer incurred the exposure indicated on the film badge cannot be supported.
The inspector identified five apparent items of noncompliance during the special inspection.
DETAILS 1.
Persons Contacted Universal Testing, Inc.
- Mel S. Mulliken, President and Radiation Safety Officer (RS0)
- N. Wayne Hanson, Assistant Manager Jim Reed, Radiographer Rick Hughes, Radiographer
- Individual A (Exposed Individual)
Utah Department of Health Dane L. Finerfrock R. S. Landauer Company
- Dick Knuth
- Present at exit briefing.
- Interviewed by telephone.
2.
Licensee Action on Previous Inspection Findings a.
(Closed) Noncompliance (78-01):
This item related to the maintenance of records of quarterly inventories.
The inspector noted that the licensee's co:nmitment to maintain such records had been acted upon.
b.
(Closed) Noncompliance (78-01): This item related to the maintenance of records of receipt of licensed material.
The inspector noted that the licensee's commitment to maintain such records had been acted upon.
3.
Investigation Findings Mr. Dick Knuth of R. S. Landauer, the licensee's film badge processor, telephoned Mr. Mel Mulliken on March 27, 1980, and reported that a film badge assigned to Individual A during the month of February 1980 indicated an exposure of 12,780 millirems from a low energy (less than 100 kev) source.
Mr. Mulliken telephoned the Region IV office on March 28 to report the exposure.
When the Region IV inspector arrived at the licensee's facility on April 1, the licensee had received a written report from R. S. Landauer documenting the exposure.
The report assigned the energy range of the exposure as Code "L" identified as " low" and "less than 100 kev" on the reverse side of the report. The licensee stated that Mr. Knuth
4 had verbally reported "a very sharp filter pattern" on the film which indicated the likelihood that either the film was stationary during an extended period of exposure in a low dose rate flux or the film was exposed to an extremely high dose rate flux for a very short duration. The available radiation sources would suggest the former case as more likely and that the film was not worn by an individual at the time of the exposure.
Mr. Knuth confirmed his evaluation of the filter pattern to the Region IV inspector during a telephone conversation on April 4.
The inspector reviewed utilization log entries summarizing use of licensed material by Individual A during February 1980.
The same exposure device containing eighty (80) curies of iridium-192 was used on the following occasions:
Date Location No. of Exposures Pocket Dosimeter Total 2/1 Salt Lake City, UT 32 18 2/4 St. George, UT 22 10 2/5 St. George, UT 33 25 2/6 St. George, UT 4
2 2/7 St. George, UT 31 25 2/8 St. George, UT 10 4
2/12 (in transport) 10 94 millirems The ten (10) millirem reading on February 12 was not readily explainable.
In addition Individual A parformed frequent radiographs with a Sperry 300 KV, 10 mA, x-ray machine during February.
This work was performed at the licensee's permanent radiographic facility at Salt Lake City.
There were no pocket dosimeter records for the x-ray work, although the licensee stated that both film badges and pocket dosimeters were worn during x-ray as well as iridium radiography.
A radiographer's assistant accompanied Individual A during the iridium radiography in February and received a February dose totaling 128 millirems by pocket dosimeter and 260 millirems by film badge. All other radiography personnel (two individuals) received film badge results less than above for February.
f 5
Exposure history records for Individual A are summarized as follows:
Accumulated lifetime (1/1/80) 43.985 rem Period January 1-31, 1980 0.250 rem Period February 1-29, 1980 12.780 rem Accumulated lifetime (3/1/80) 57.015 rem The accumulated exposure as of March 1, 1980, was well below the lifetime permissible considering the age of Individual A.
Mr. Mulliken presented a letter written and signed by Individual A which stated that there was no identifiable event which might have caused the hi;h exposure.
Individual A was performing radiography at St. George, Utah, on the day of the inspection.
However, Individual A was interviewed by telephone on April I by the Region IV inspector, and he stated that equipment had worked perfectly during February and that no incident occurred which might have explained the exposure. He further stated that dosimeters were on his person at all times and were not set near a radia-tion source.
The inspector also interviewed the radiographer's assistant at the Salt Lake City facility. He also had no explanation for the high reading.
At the conclusion of the investigational portion of the inspection, the inspector stated that the exposure of an individual in excess of that limit delineated in 10 CFR 20.101(b) was an apparent item of noncompliance.
The inspector further explained that the exposure limit included the sum of components from both licensed material and unlicensed sources of radiation as indicated in 10 CFR 20.1(b).
The licensee responded that a report in accordance with 10 CFR 20.405 was pending.
4.
Organization and Administration Mr. Mullikin described the organization and the administration of the radiography program.
The inspector noted the organization to be as described in the Management Control Section of the Operating and Emergency (0E) Procedures except as follows:
Mr. Jim Reed is no longer Manager.
a.
b.
Mr. Hanso-has been recently hired with the title of Assistant Manager.
Mr. Mulliken also stated that the firm is pending reorganization under the came of Met-Chem Engineering. Three radiographers and one assistant are presently employed.
6 5.
Training and Qualification of Personnel The inspector reviewed training records of Rick Hughes who had been hired since the last inspection.
Mr. Hughes described the training he had received upon hire.
The inspector noted that Mr. Hughes had signed a receipt form for copies of regulations, procedures, and the license. The inspector also reviewed records of periodic training for radiography personnel performed during 1979.
6.
Licensee Internal Audits The inspector reviewed reports of re.diographer audits conducted and documented by the RSO.
The reports cited several instances of the auditor discovering procedural deficiencies, thus signifying the validity of the program.
The inspector noted that records indicated that one radiographer had not been audited between August 15, 1979, and December 10, 1979. The RSO stated that an audit had not been performed for the individual between the two dates.
The inspector stated that page OP-1 of the OE procedures require that such audits shall be performed at least once every 90 days.
The inspector further stated that failure to perform audits within the prescribed interval constituted noncompliance with License Condition 16.
7.
Inspection and Maintenance of Radiographic Equipment The inspector reviewed records of daily and quarterly equipment inspections.
All such cocuments were found to be prepared and approved in accordance with the licensee's OE procedures.
8.
Utilization Logs and Quarterly Inventories The inspector verified that quarterly physical inventories had been conducted and documented in accordance with 10 CFR 34.26.
The inspector observed that utilization log information required by 10 CFR 34.27 was maintained and appropriately documented.
9.
Uses of Materials, Facilities, and Equipment The inspectar verified that device and source model numbers and amounts were as authorized by the licenre.
The inspector observed that no changes in the licensee's facilities had been made since the previous inspection.
Locked exposure devices were observed to be ctored in a locked storage cabinet.
7 The inspector observed that a visible warnirg signal actuated by radiation and an audible signal actuated upon entry were not installed on the licensee's permanent radiographic installation.
The inspector stated that failure to install such devices constituted noncompliance with 10 CFR 34.29.
The inspector review 2:1 instrument calibration records dating back to the previous inspection.
Calibration was performed by the licensee or instru-ment repair service.
The inspector observed that several instruments were labeled as recently calibrated, were operable, and otherwise met require-ments of 10 CFR 34.24. A calibration record was missing for an Eberline E-120G survey meter, serial number 200, with documented calibration on January 31, 1979, and again on August 20, 1979. The daily log listed the instrument as used on May 4 and June 20, 1979 after the instrument was due for calibration.
Each of the log sheets indicated the calibration due date as August 3, 1979, thus indicating that the device had been calibrated on May 3 but that the record was unavailable.
The inspector stated that failure to maintain a calibration record constituted noncompliance with 10 CFR 34.24.
10.
Personnel Monitoring The inspector reviewed the personnel monitoring program and determined that film badges and direct-reading pocket dosimeters (range 0-200 mR) were utilized during radiographic operations.
Pocket dosimeters are recharged daily and the daily exposure readings are recorded. Film badges are supplied by R. S. Landauer on a monthly exchange schedule.
The licensee posts badge results to Form NRC-5.
The licensee stated that a radio-grapher hired during January 1980 had not been requested to sign a statement to facilitate determination of prior dose.
The inspector responded that failure to require such a written, signed statement constituted noncompliance with 10 CFR 20.102(a).
The inspector reviewed and found satisfactory a report of personnel expo-sure issued by the licensee upon termination of a worker's employment.
The licensee also presented copies of annual exposure reports for calen-dar years 1978 and 1979 pursuant to 10 CFR 20.407, 11.
Leak Tests The inspector reviewed leak test records which indicsted that sealed sources had been tested every six months.
Analyses of the test swabs were performed by Gulf Nuclear.
~
~
~
8 12.
Surveys The inspector reviewed the records of surveys performed pursuant to NRC regulations and the licensee's OE procedures.
Surveys conducted to establish boundaries of restricted areas and to determine radiation levels in unrestricted areas are documented on utilization log sheets.
These forms also document surveys of vehicles transporting licensed material and surveys of exposure devices upon removal from storage and prior to securing.
13.
Posting and Labeling The inspector observed that Form NRC-3 was posted in the shop area with a notice pursuant to 10 CFR 19.11(b).
The inspector examined the posting and/or labeling of transportation vehicles, storage areas, containers, and exposure devices. All met the requirements of 10 CFR 20.203 except as indicated in paragraph 14 below.
14.
Field Site Inspection Radiographer Jim Reed performed a mock radiograph in the Salt Lake City permanent radiographic installation using an eleven-curie source on April 1.
The inspector observed the set up, performance, and disassembly procedures.
The radiographer did not post the high radiation area at any time during the demonstration. The inspector informed the licensee that failure to so post the area constituted noncompliance with 10 CFR 34.42.
All other aspects of the demonstration were performed in compliance with NRC regulations and the license.
15.
Receiving and Shipping of Material The inspect r reviewed records of shipping container surveys performed upon receipt and prior to transfer. Also reviewed were receipt and transfer records for licensed material. The inspector observed that the licensee possessed procedures pertaining to the quality assurance of shipping containers and the pickup, receivin-and opening of shipping containers.
.