ML20043B019
| ML20043B019 | |
| Person / Time | |
|---|---|
| Issue date: | 05/08/1990 |
| From: | Dan Collins, Mcalpine E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20043B008 | List: |
| References | |
| 15000023-90-01, 15000023-90-1, NUDOCS 9005240066 | |
| Download: ML20043B019 (5) | |
See also: IR 015000023/1990001
Text
,
-
-
l
2 har
UNITED STATES '
9
- L
'
NUCLEAR REGULATORY COMMISSION
, 2
-
REGION 88
s -.
k>
'
~101 MARIETTA STREET, N.W.
s
ATLANTA, CEOROl A 30323
\\/
MAY 9 4990
.
Report No.:
150-00023/90-001
,
Licensee:
Mississippi X-Ray Service, Inc.
$
P. O. B:
127
Wesson, Mississippi
39191
Docket No.:
150-00023-
-License No.:
General License
-
. (10CFRc150.20)
Inspection Conducted:
April 26, fl9901 at field location at' Richmond,
.
'
Inspector: In l
. 8890
-
/Bavid J. Collins, Radiation Specialist
yte/ Signed .
Approved by: In
Ab4
[ O
dward J. McAlpine, Chief .
Date Signed
s
adiation Safety Projects Section
Nuclear Materials Safety and Safeguards Branch
Division of Radiation Safety and Safeguards
'
i
3
,
s
SUMMARY
Scope:
l
L
This special unannounced safety inspection,was; conducted in response. to
,
l
allegations . of improper - conduct of radiographyJat a temp rary jobsite in
Et
Richmond, Virginia.
The licensee is authorized by a General: License granted by
.
~!
-
i
10 CFR 150.20- to conduct radiography operations-at temporary jobsites where NRC
maintains jurisdiction.
The radiography. operations are the same as those
i
authorized by. Mississippi License No. MS-292-01
,
L
Results:
1
Four apparent violations were identified:
Failure, to survey a radiographic
L-
device after each exposure.(paragraph 4);
Failure to observe a radiation area
to preclude ; intrusion by unauthorized individuals (paragraph 4); Failure to
post radiation and high radiation areas. while performing radiographic
operations (paragraph 4); and, Failure to notify- NRC of operations in NRC
jurisdiction by-an Agreement State Licensee (paragrapn 4).
,
,
t
I
,
9003240066 900309
-
<
REG 2 SUBJ
N
J
.
]
'
7
aimm%
,
$
.
.,
,
s
.
REPORT DETAILS
-..
1.
Persons Contact 6d
H. K. Russell, President and Radiation Safety' Officer
,
C. Smith, Radiographer
'
W. J. Smith, Radiographer:
2.
Follow-up of Allegation No. RII 90-A-0053
In response to an April 19, 1990 allegation, an.NRC. Region II inspector
j
performed an unannouncM inspection of construction site - radiography;
[
activities in theacuthern saa of Richmond,- Virginia on: April 26, 1990
!
3.
Inspector Observations of Raatography
.
i
,-
The inspector obsrrved radiogrg hy_ operations in progress at four areas of
~
the pipeline construction.
Observations.of radiography activities near
H
noontime on the western side of-I-95 between the railroad right-of-way and
i
a truck body fabrication yard were made by the inspector-without the
4
radiographer's knowledge.
The pipeline. welds being examined were on the temporarily elevated pipe
about six feet from the edge of the right-of-way and- about 25 feet from
y
the entrance to a material storage frame area within the' truck body fabri-
~!
cation yard. Also, within 50 feet of the welds were various truck and van
bodies.
The inspector noted that no-signs were posted within the truck
!
fabrication yard, alongside the pipeline-right-of-way, or lengthwise along-
!
the pipeline.
The inspector observed the licensee radiograph two welds,
j
the first with three exposures, the second with one.
Between exposures
i
the radiographer did not survey the exposure. device and guide' tube as
-
required.
During the first exposure - on the second weld, _ an individual
drove a forklift into the material storage frame area, preparing to
I
transfer material to a w@ng vehicle.
The radiographer, whose view of
i
the traterials area was ect. obstructed, spent the. entire time of the
i
exposures facing away from the pipeline and the truck body ' area towards
l
the railroad tracks' and I-95.
The inspector located himself during the
i
first set of exposures- about 75 feet from the_ weld and behind :a truck
-
'
body. The inspector's micro-R meter showed more than 5 millirem /hr during-
the crankout and crankin periods and 5 millirem /hr. during the -film
,
exposure time of about 45 seconds, resulting in about 0.25 millirem total
j
!
!
!
l
l}
--
,
.
l
/*
' . ,
.
2
'
exposure . at 75 feet.
The inspector moved back to maintain the same
.i
. distance during the' examination of the second weld..
The inspector
i
estimated the exposure of,the forklift operatorLto have been 5 r.illirem,.
based on the 25-foot distance.from the source to the forklift operator,
the 55 curie iridium-192 source strength, and. the three-quarter minute
,
'
time of exposure.- At the conclusion of the fourth exposure the inspector
identified himself'to the radiographer.
l
.
Y
4.
Radiography Documents Reviewed-
The irspector reviewed these documents':
l
a.
Mississippi State Department of Health' Radioactive Material License
,
No. MS-292-01. Amendement No. 52, dated November 6, 1989..
[
b.
Mississippi X-Ray Service Operations'and Emergency Procedures Manual.
I
c.
Daily ' operations utilization logwheets for the week of- Aprt123
1990, including. April:26,1990, log.
'
d.
Source inventory and decay chart for SPEC-2-T radiography camera'
SN-74, source 07802, 108 curies on February 28, 1990, decayed =to 55-
'
curies April 26, 1990..
'
i
e.
Calibration sheets for NDS Model 2000 survey meters.
,
5.
Radiographer's Statements
The radiographers stated that the required. surveys had not'been made', and
U
that-the areas had not been posted as required.
The: radiographer also
stated that he had not observed the intrusion of the forklift operator
i
into the radiography controlled area.- The radiographers stated that'they.,
a
had yielded to construction management pressures for increased speed.
The
L
radiographers stated that it was . their impression that NRC- Form 241, _
1
" Report of Proposed Activities in Non-Agreement :St.tes," had.- been
submitted to the NRC by their home office-in Wesson, Mississippi.
6.
Other Raolography Observations
Observations of radiography at the tie-in site on the east side of;I-95 at
1
the northern end of the rail siding switch were partially blocked from.the
inspector's view and were inconclusive.
Observations.-of radiography on
the west side of I-95 just north of the high-tension electricity towers-
were brief and inconclusive. Operations at the. tie-in location just south
of the highway underpass conducted after the-inspector identified himself
were conducted properly.
.
7
i
]
e
o
,
.
0
.' -
.
?
"
~3
,
=
7.
Inspection Findings
1
10 CFR 150.20(a) grants a general license to any person holding a specific
license from en Agreement Si. ate (Mississippi is an Agreement. State)-
.i
subject to certain provisions.
10CFR1150.20(b)statesthatsuchgeneral
,
licenses are subject to the re i
f 10 CFR Part 34, SubpartfB
!
.(Radiation Safety. Requirements)qu rements oSubpart B includes--10 CFR 34.21 thro
!
.
10 CFR 34;51. The inspector ' determined that Mississippi ~ X-Ray. Service, .
State)perations within a<non-Agreement State-(Virginia;is'aLnon-Agreemenmt
Inc. o
i
are subject /to NRC: jurisdiction..
]
a.-
10 CFR 34.41 requires the licensee's . radiographer. or rasiographer's -
assistant to maintain e direct surveillance of the' operation to -
protect against unauthorized entry. into .a high radiation! area. -
Mississippi X-Ray Service, Inc. ' operating procedure, Operations 'and.
~
,
Emergency Procedures' Manual, also requires in Step .15, that the:
'
radiographer or assistant maintain direct. surveillance of- the: ..
,
operation.
Failure of the radiographer-and/or assistant to maintain-
'
.
. direct observation of the' radiographic operation :to protect againstL
i
unauthorized entry into high radiation-areas is an apparent! violation
[
of 10 CFR 34.41 and Step 15 of Specific Instructions conta.ined in'the
Operations :and Emergency Procedures Manual ofJ Mississippi _. X-Ray
..i
Service, Inc.
b.
10 CFR 34.42 requires that are'as in: which radiography is being
s
-
performed shall be conspicuously posted.
Failure to post. radiation
I
.
areas and'high radiation areas where radiography-was being' performed
i
is an apparent violation of'10 CFR'34.42.
p
c.
10 CFR.34.43 (b) requires the licensee:to. ensure that a survey with'a
calibrated and operable radiation survey instrument isLmade after
each exposure to determine that the sealed source has'been returned
'l
-to its shielded position.
Such survey' is to include the entire-
-
,
I
circumference cf the rad 1ographic exposure Ldevice, including the
<
I
source guide' tube.
Failure to survey the_ radiography'exoosure device
and guide tube after each exposure is an apparent' violation of 10 CFR 34.43(b).
!
10 CFR 150.'20(b)(1) requires that any person. engaging inyactivities.'in
non-Agreement States under a general-license'shall, at'least three days -
1
before engaginc 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 for the Region in which .the Agreement State that issued the'
+
license is located.
s
l
l
!
!
1
y
1
.
.
W
l
'
a,-
.
.
.
,
- c .'
t
.a
-
.
.
4
,
t
As? stated previously, during the '. inspection in Richmond, ~ Virginia, thel
l
inspector asked 'the 1icensee representatives' W5 ether.a Form 241' had. been
filed as required.. They indicated that.such a form had'been filed before
.i
~ he' jobi started, to the: best of their' knowledge. -During a ; telephone.
t
conversetion with the: president of Mississippi- X-Ray Service, Inc., he was
!
asked whether; or-not a Form. 241' had been: filed.
The licensee indicated-
-
that a form had been filed with> Reigon IV- in Arlington, Texas but not with-
j
Region II in Atlanta, Georgia.
A search ofDthe records in the Region II
and. Region IV of# ices revealed that no. record of filing 07 Form 241.could '
be located.
Since Form 241'is required to :be filed with; the' Regional-
j
Office in which the principal office and radiation safety records of the
-
-
,
licensee are-located and since MississippiLX-Ray Service, Inc. offices are:
locat'ed in Mississippi, a state within NRC Region II .: failure to-file Form
i
'
241:with NM Region II is an apparent violation'.of 10 CFR 150.20(b)(1)..
,!
.
8.
Conclusion
Through~ review of licensee ' documents,- discussions ~ ith lic'ensee
'
w
-
representatives, and , observations- 'of.- radiographic activities, the-
allegations werei substantiated.
Apparent violations 1were noted for-
failure to survey theLradiographic device after each exposure, failure to-
!
' observe and maintainL control. of the area, and failurej to post' the
,
radi.ation and- high radiation = areas while perfoming . radiographic'
operations. Another apparent violation-was subsequently noted.for failure
1
.to file Form 241 as required,
a
'
9.
Exit Interview
The inspector conducted an exit interview with the' radiographers on
April 26, '1990, at the conclusion of-the inspection.-
'
-4
On May 1,1990, an exit' interview was= conducted by telephone:between
i
Mr. W. Cline of this office and Mr. H. Xeith Russel1~, President and
'
Radiation Safety Officer of Mississippi X-Ray Service, Inc. .TheLinspector
summarized the scope and the findings of the inspection.-
1
!
,
?
,
d .
t
1
J
rr
.
< ,
,
.
--
.