ML20031D211
| ML20031D211 | |
| Person / Time | |
|---|---|
| Issue date: | 09/22/1981 |
| From: | Riedlinger B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20031D210 | List: |
| References | |
| NUDOCS 8110130124 | |
| Download: ML20031D211 (2) | |
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Appendix A NOTICE OF VIOLATION Smith-Emery Company License No. 04-19467-01 781 East Washington Boulevard Los Angeles, California 90021 As a result of the inspection conducted on August 27, 1981, and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7,1980),
the following violations were identified:
A.
License Condition 12. lists those individuals who are the only persons authorized to act as radiographers.
Contrary to this requirement, an unauthorized radiographer performed industrial radiography with a 92 curie iridium-192 source on August 7,1981 at Building 114 at Hunters Point Shipyard.
This is a Severity Level IV violation (Supplement VII).
B.
10 CFR 30.3 states that except for persons exempt as provided in Part 30 and Part 150, no person shall use byproduct material except as authorized in a specific or general license issued pursuant to regulations in 10 CFR.
Contrary to this requirement, Smith-Emery Company employees conducted radiography on seven occasions which were not authorized in a specific or general license issued pursuant to regulations in 10 CFR.
Specifically, radiography was performed:
1)
Once on 12-12-80 with a 40 curie fridium-192 source in the engine room aboard the USS SAN JOSE.
2)
Once on 12-17-80 with a 37 curie iridium-192 source in the engine room aboard the USS SAN JOSE.
3)
Three times on 12-18-80 with a 37 curie iridium-192 source aboard the USS SAN JOSE.
l 4)
Once on 12-23-80 with a 35 curie iridium-192 source aboard the USS KANSAS CITY.
5)
Once on 12-26-80 with a 104 curie iridium-192 source aboard the USS WABASH.
None of the above uses were described in a Form NRC-241 which would grant a general license pursuant to 10 CFR 150.20.
These uses were also not authorized by a specific license, as NRC License 04-19467-01 w l
was not issued until December 31, 1980.
l I
This is a Severity Level IV violation (Supplement VII).
e11o130124 810922 NMS LIC30 04-19467-01 PDR
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Appendix A C.
10 CFR 34.43(b) requires that the entire circumference of the radiographic exposure device be surveyed after each radiographic exposure to determine that the sealed source has been returned to its shielded position.
Contrary to this requirement, at the time of the inspection, a licensee representative stated that linear rather than circumferential surveys were conducted after each radiographic exposure.
This is a Severity '_evel V violation (Supplement VII).
D.
10 CFR 34.26 states that each licensee shall conduct a quarterly inventory to account for all sealed sources received and possessed under his license.
Contrary to this requirement, no inventory to account for sealed sources received and possessed was conducted between March 1980 and April 17,1981.
This is a Severity Level V violation (Supplement VII).
E.
10 CFR 20.4'11(b) states that each licensee shall maintain records showing the results of monitoring required by 10 CFR 20.205(c).
10 CFR 20.205(c) requires that the radiation levels external to a package of radioactive material in excess of Type A quantities be monitored upon receipt.
Contrary to this requirement, no records were maintained of surveys on receipt of radiography devices shipped on 7-6-81 and 5-15-81 from Technical Operations. These were iridium-192 sources of:
103 curies, serial number 9817; and 100 curies, serial number 9516, respectively.
This is a Severity Level VI violation (Supplement VII).
l pursuant to the provisions of 10 CFR 2.201, Smith-Emery Company is hereby required to submit to this office within thirty days of the date of this Notice, a written statement or explanation in reply, including:
(1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further items of l
noncompliance; and (3) the date when full compliance will be achieved.
Consideration may be given to extending your response time for good cause shown. Under the authority of Section 182 of the Atomic Energy Act of 1954, as amended, this response shall be submitted under oath or affirmation.
The responses directed by this notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwcrk Reduction Act of 1980, PL 96-511.
Original signed by R. ZurabW h dated Miedlinger, Radiation Specialist, i
Radiological Safety Branch l