ML20138B266
| ML20138B266 | |
| Person / Time | |
|---|---|
| Issue date: | 02/28/1986 |
| From: | Everett R, Ricketson L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20138B263 | List: |
| References | |
| 15000042-85-01, 15000042-85-1, NUDOCS 8603200320 | |
| Download: ML20138B266 (6) | |
See also: IR 015000042/1985001
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APPENDIX A
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U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report:
15000042/85-01
General Licensee
Docket:
15000042
License:
H & G Inspection Company, Inc.
9315 Summer Bell
Houston, Texas 77272
Inspections at:
Shute Creek, Wyoming and Houston, Texas
Inspections Conducted:
November 13 and November 21, 1985
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Inspector:
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L. T.
ketson, P.
E., Radiation Specialist
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Approved:
3/2f[%
R. J. Everett, Chief, Nuclear Materials Safety
Date
Section
Inspection Summary
Inspection Conducted November 13 and 21, 1985 (Report:
15000042/85-01)
Areas Inspected:
A special, unannounced inspection was conducted in response to
allegations of violations of regulations and operating procedures and unsafe
practices.
Included are a field inspection to observe operations and interview
personnel, and a visit to company headquarters to review records of personnel
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monitoring, source utilization, survey instrument calibration, and personnel
training.
The inspection involved 6 inspector-hours onsite by one NRC inspector.
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Findings:
Of five allegations involving possible violations of NRC regulations or NRC
license conditions, two allegations were substantiated.
A third allegation was
substantiated, but did not result in a violation of regulations being cited.
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addition, the field inspection resulted in the identification of three violations.
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The findings were:
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8603200320 860311
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Failure of the licensee to limit the exposure of individuals occupationally
exposed,'and having a documented radiation history, to less than three rems
per calendar quarter.
(Section 4)*
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2.
Failure of persons performing radiography to perform radiation surveys to
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document radiation levels in unrestricted areas. (Section 3)
3.
Failure of persons performing radiography to perform adequate radiation
surveys to determine that the radioactive source has returned to its
shielded position. (Section 3)
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4.
Failure to maintain an adequate number of calibrated and operable survey
instruments to perform required radiation surveys. (Section 4)*
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5.
Failure to properly post areas in which radiography was being performed.
(Section 3)
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Alleged item.
A third allegation was proven to be correct, that of vehicles carrying radio-
active sources not being placarded with DOT signs; however, this proved not to
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be a violation of regulations.
(Section 3)
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DETAILS
1.
Persons Contacted
H & G Inspection Company
- Harry Gibson, Owner and President and Radiation Sa'fety Officer
- Steve Steen, Operations Manager and Assistant Radiation Safety Officer
Lloyd'Kay, Site Supervisor
Randy Thompson, Radiographer
Tony Ramon, Assistant Radiographer
Robert Snider, Assistant Radiographer
Kirk Smith, Radiographer
Rick Coleman, Radiographer
- Jim Russell, Exxon, Night Superintendant
- Bill Wilson, Project Construction Company (PCC), Night Supervisor
- Denotes those present for exit meetings in Wyoming.
- Denotes those present for exit meeting in. Texas.
2.
Reason for Special Inspection
On November 11, 1985, the Region IV allegations coordinator received an
anonymous call from an individual alleging unsafe practices and violations
of operating procedures and regulations by workers performing radiographic
work for H & G Inspection Company, Inc., in the Shute Creek area of Wyoming.
Of the allegations made, five were related to regulations or license condi-
tions and would be under the jurisdiction of the Commission.
The five
allegations were:
(1) Unqualified personnel were working as radiographers
and assistant radiographers, (2) Survey instruments were being used when
not in calibration, (3) Utilization records were. altered to indicate that
instruments used were in calibration when they actually were not,
(4) Trucks transporting radioactive sources were not properly placarded
with DOT signs, and (5) Individuals performing radiography had been over-
exposed to radiation because of a source disconnect.
3.
Field Inspection
On the night of November 13, 1985, the NRC inspector visited the site of
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the Exxon plant in the Shute Creek area of Wyoming.
Both the night super-
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visors for Exxon and their prime contractor, Project Construction Company
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(PCC) were contacted upon arrival, in order to gain access to the
construction area.
The NRC inspector stated that he wished to perform an
unannounced inspection of H & G Inspection Company.
Both representatives
gave their complete support.
The NRC inspector was taken by a PCC representative to the first site where
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radiography was being performed.
The area was roped, but no signs were
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posted. This was identified by the NRC inspector as a violation of 10 CFR
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34.42. -The radiographer was working on an elevated section of pipe.
Two
other individuals were maintaining surveillance on the ground and kept the
NRC inspector and PCC employee from entering the restricted area.
The NRC
inspector observed the radiographer perform an exposure and return the
source to its shielded position.
The radiographer did not have a survey
instrument with him and therefore did not make a survey of the exposure .
device after completing the exposure.
This was identified by the NRC
inspector as a violation of 10 CFR 34.43(b).
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The NRC inspector identified himself to the work crew and asked to examine
personnel monitoring devices.
The radiographer and one assistant carried
both film badges and pocket dosimeters.
The second individual carried
neither.
This was at first identified as a violation of 10 CFR 34.33(a);
however, observations were insufficient to establish conclusively that the
individual had indeed been performing the duties of assistant radiographer.
The licensee stated that the individual'had just arrived at the job site
and had merely gone to introduce himself to the person with whom he would
be working and had actually not performed the duties of assistant radio-
grapher. The individual had previously stated the same thing to the NRC
inspector. This item was not cited, although it was discussed with the
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licensee as an area of concern.
The NRC inspector asked ~to see the survey instrument that was being used.
The radiographer questioned the assistant and, after a few minutes, the
assistant produced an instrument which he said he had lef t on.the ground
nearby.
The instrument was in calibration.
The NRC inspector asked to see the survey records for the current job and
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found that surveys had not been done.
This was identified by the NRC
inspector as a violation of 10 CFR 20.201.
A second crew was observed and was found to be following proper procedures
with the exception of inadequately surveying the exposure device by not
surveying the guide tube after each exposure.
This was identified as a
second example of a violation of 10 CFR 34.43(b).
The vehicles observed by the NRC inspector were placarded with DOT signs.
In response to the NRC inspector's questions, the licensee stated that two
of the vehicles being used to transport licensed sources at the work site
were not placarded with DOT signs.
He also stated that material was stored
at the site and not carried on roads offsite and that material was shipped
to the site originally, either by common carrier or one of the other
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properly marked vehicles.
None were observed on the highways.
Allegation #4 was substantiated, but there was no violation.
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The company president was onsite and stated to the NRC inspector that there
had been an incident which resulted in the overexposure of one individual.
Details are listed in the next section.
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4.
Inspection of Records at Home Office
On November 21, 1985, the NRC inspector went to Houston to inspect records
unavailable at the field office.
Records for training of radiographers included any previous training and
experience, the training course given by the company's consultants, written
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tests, and the results of practical testing. The only records available
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for assistant radiographers were signed statements attesting to the fact
that they had received and reviewed. copies of the operating procedures and
a copy of written exams given after their first day's orientation. No
record of practical training was available.
Records for the several
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radiographers, picked at random from an employee list, were available.
Allegation-#1 was not substantiated.
Records of utilization were reviewed by the NRC inspector. On the records
were blanks on which the user could indicate the serial number of the
survey instrument used and indicate whether or not it had a current
calibration.
The NRC inspector noted that'on several occasions instruments
not calibrated within the previous 90 days had been used.
As an example,
instrument, serial number 1905, was used on November 6, 1985 (the time of
the apparent exposure).
It was last calibrated on July 24, 1985.
This
was identified by the NRC inspector as a violation.of 10 CFR 34.24.
Allegation #2 substantiated.
Although some examples of utilization records were incomplete as to whether
or not the survey instrument used was in calibration, no examples of
altered records were observed.
Allegation #3 not substantiated.
The NRC inspector reviewed the personnel monitoring report showing that
one individual had received an exposure of 3.4 rems for the period of
October 19, 1985, the individual's first day of work, to November 6, 1985,
the day of the incident.
This was identified by the NRC inspector as
a violation of 10 CFR 20.101.
According to Texas' equivalent form to NRC
Form 4, the individual had no previous experience or radiation exposure.
Allegation #5 substantiated.
The NRC inspector reviewed the licensee's evaluation of the'cause of the
exposure and found that signed statements from the individuals involved
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indicated that it was due to a source not being fully retracted to its
shielded position (not a source disconnect) and going undetected because an
adequate survey was not performed.
The lack of an adequate survey was
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identified by the NRC inspector as another example of a violation of 10 CFR
'34.43(b).
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5.
Exit Meeting
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Exit meetings were held at the project in Wyoming. Apparent violations
identified by the NRC inspector were discussed with the licensee and
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company officials -in charge -of ~ project safety in separate meetings. All e- .
gations investigated up to that point'in time were. discussed with the.
_ licensee. The licensee acknowledged the' findings of. the inspector and
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expressed ~ concern..
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An exit meeting was also held in Houston where the remainder of the all'ega--
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tions were discussed.
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