ML20148D225
| ML20148D225 | |
| Person / Time | |
|---|---|
| Issue date: | 10/24/1978 |
| From: | Jennifer Davis NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20148D206 | List: |
| References | |
| NUDOCS 7811020276 | |
| Download: ML20148D225 (4) | |
Text
'
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
)
Union Boiler Company Byproduct Material P. O. Box 1618
)
License No. 47-16182-01 Huntington, West Virginia 25717
)
ORDER IMPOSING CIVIL MONETARY PENALTIES I
Union Boiler Company, P. O. Box 1618, Huntington, West Virginia (the
" licensee"), is the holder of Byproduct Material License No. 47-16182-01 (the " license"), issued by the Nuclear Regulatory Commission (the " Commission").
The license, which authorizes the iicensee to perform industrial radiog-raphy in accordance with conditions specified therein, was issued originally on October 8,1974, and is due to expire on October 31, 1979.
II A special inspection of the licensee's activities under the license was conducted on June 6 and 7, 1978.
As a result of this inspection it appears that the licensee has not conducted its activities in full compliance with the conditions of the license and with the requirements of the NRC's " Standards for Protection Against Radiation," Part 20, and
" Licenses for Radiography and Radiation Safety Requirements for Radio-graphic Operations," Part 34, Title 10, Code of Federal Regulations.
A written Notice of Violation was served upon the licensee by letter dated I
August 14, 1978, appended hereto as Appendix I, specifying the items of noncompliance in accordance with 10 CFR 2.201.
A Notice of Proposed Imposition of Civil Penalties dated August 14, 197.8, was served con-currently upon the licensee in accordance with Section 234 of the Atomic
^1?cIIoDOc27(p
. Energy Act of 1954, as amended, (42 USC 2282), and 10 CFR 2.205, incor-porating by reference the Notice of Violation, which stated the nature of the items of noncompliance and the provisions of NRC regulations with which the licensee was in noncompliance.
A response dated September 5,1978, to the Notice of Violation and the Notice of proposed Imposition of Civil Penalties was received from the licensee and is appended hereto as Appendix II.
III Upon consideration of the answer received and the statements of fact, explanation, and argument in denial or mitigation contained therein, the Acting Director of the Office of Inspection and Enforcement has determined that the penalties proposed for the items of noncompliance designated in the Notice of Violation as Items A, B and C, should be imposed.
IV In view of the foregoing and pursuant to Section 234 of the Atomic Energy Act of 1954, as amended (42 USC 2282), and 10 CFR 2.205, IT IS HEREBY i
l ORDERED THAT:
The licensee pay civil penalties in the cumulative amount of Five Thousand Dollars ($5,000) within twenty j
(20) days of the date of receipt of this Order, by check, draft, or money order payable to the Treasurer of the United States and mailed to the Acting Director of the Office of Inspection and Enforcement.
. V The licensee may, within twenty (20) days of the date of rece.ipt of this Order, request a hearing.
If a hearing is requested, the Commission will issue an Order designating the time and place of hearing, Upon failure of the licensee to request a hearing within the specified twenty (20) days, the provisions of this Order shall be effective without further proceedings and, if payment has not been made by that time, the matter may be referred to the Attorney General for collection.
VI In the event the licensee requests a hearing as provided above, the issues to be considered at such hearing shall be:
(a) whether the licensee was in noncompliance with the Conmission's regulations and the conditions of the license as set forth as Items A, B and C in the Notice of Violation attached hereto as Appendix I; and
. (b) whether, on the basis of such items of noncompliance the Order should be sustained.
FOR THE NUCLEAR REGULATORY COMMISSION ohn G. Davis Acting Director Office of Inspection and Enforcement Dated at Bethesda, Maryland this __ z /
day of (,,e 4 / v 1978
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NUCLEAR REGULATORY COMMISSION 3$^y; f
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$j WASHING TON. D. C. 20555 August 14, 1978 Union Boiler Company License No. 47-16182-01 Attn:
fir. J. H. McDavid Presidant P. O. Box 1618 Huntington, West Virginia 25717 Gentlamen:
One of your employees was overexposed on June 3,1978 as a result of his failure to retract a radiographic source after completing radiog-raphy at the Philip Sporn Steam Plant.
The emoloyee also failed to perform an adequate survey and failed to follow procedures for the work in progress.
Findings of a special inspection of this incident were discussed with you and members of your staff at the completion of the inspection.
The Director of our Region II Office called you on June 21, 1973 and discussed our concern for the overexposure and the need for improvement in your management controls and for additional training of radiographers.
The five items of noncompliance found during the inspection are set forth in the l'otice of Violation enclosed as Appendix A to this letter.
In addition to our concern for the overexposure of approximately 123
. rems to portions of the left hand and approximately 1.9 rems to the lens of the eyes, we consider the incident to be very serious because of the potential for an even larger radiation overexposure.
We are also concerned that the radiographer chose to disregard high radiation level readings on his radiation survey meter indicating that the source was still exposed.
Further, while securing the radiographic device, the radiographer was unable to complete certain steps and disregarded a statement in the procedure that inability to lock the connector selector ring indicates that the source is not in its shieldeo position.
Consequently, we propose to impose civil penalties in the cumulative amount of Five Thousand Dollars ($5,000) for those noncom-pliances related to the overexposure.
Appendix B of this letter is the flotice of Proposed Imposition of Civil Penalties.
You are required to respond to this letter, and in preparing your response you should follow the instructions in Appendix A.
CERTIFIED f! AIL RETuRh RECEIPT REOUESTED M7003 4
Union Boiler Company August 14, 1978 Your written reply to this letter and t!otice of Violation and the findings of our continuing inspections of your licensed activities will be considered in determining whether further enforcement action, such as additional civil penalties or orders to suspend, modify or revoke the license, may be required to assure future compliance.
In accordance with Section 2.790 of the NRC's " Rules of Practice,"
Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosures will be placed in the NRC's Public Document Room.
Sincerely, r
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V A ting Director Office of Inspection and Enforcement
Enclosures:
1.
Appendix A, Motice of Violation 2.
Appendix B, Notice of Proposed Imposition of Civil Penalties cc:
Mr. W. G. Yeoman, Radiation Safety Officer Huntington Testing Division of Union Boiler Company P. O. Box 1618 Huntington, VA 25717 A_7TEGII 1
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l Appendix _A NOTICE OF VIOLATION Union Boiler Company License No. 47-16182-01 1
This refers to the inspection conducted by representatives of the Region II (Atlanta) Office at the Philip'Sporn Steam Plant, New Haven West Virginia, and the Huntington Testing Division Facility, Huntington, West j
Virginia, of activities authorized by NRC License Fo. 47-16182-01.
During this inspection conducted on June 6-7, 1978, the following apparent items of noncompliance were identified.
A.
10 CFR 20.101, " Exposure cf individuals to radiation in restricted areas," requires in part that the dose to the whole body of an
)
individual -(including the lens of the eye), in a restricted area be limited to one and one-quarter rems per calendar quarter, and that the dose to the extremities be limited to eighteen-and three-quarter rems per calendar quarter.
Contrary to the above, an individual who was performing radiographic operations at the Philip Sporn Steam Plant near Hew Haven, West
'!irginia on June 3,1978, received a dose to the left hand of approximately 123 rems and a dose to the~ lens of the eyes of approximately 1.9 rems.
~
This violation constitutes an occurrence related to health and safety.
(Civil Penalty - $2,000)
B.
10 CFR 20.201, " Surveys," requires that each licensee make or cause to be made such surveys as may be necessary for him to comply with the regulations of 10 CFR 20.
f s defined in 10 CFR 20.201 section (a) " survey" means an evaluation of the radiation hazards incident to the production, use, release, disposal, or presence of radio-1 active materials or other sources-of radiation under a specific set of conditions.
Contrary to the above, you failed to make such surveys as were necessary to assure compliance with 10 CFR 20.101 " Exposure to Individuals to Radiation in Restricted Areas." Specifically you failed to make such a survey to assure that dose limits would not be exceeded on June 3,1978 when an employee at the Philip Sporn Steam Plant disconnected a source guide tube from a radiographic projector without first completely retracting the source to the shielded position.
This violation contributed to an occurrence related to health and safety.
(Civil Penalty - 52,000) 1
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Appendix A C.
Condition 15 of the license requires in part that licensed material be used in accordance with statements, representations, and proce-dures contained in the application dated June 12, 1974'and in letters dated December 23, 1974 and December 4, 1977.
Procedure 12, " Operation of the Tech / Ops. 'todel 660 Projector,"
contains the following:
a.
Section 5.8 specifies that the connector selector ring be rotated from the OPERATE position to the LOCK position and that the projector be secured with the projector lock.
b.
A "ilote" immediately following Section 5.8 states that if the projector connector selector ring cannot be rotated to the lock position, then the source has not been fully retracted.
Contrary to the above, on June 3,1978, at the Philip Sporn Steam Plant, a radiographer in your employ, at the conclusion of his last radiographic exposure, attempted and could not move the connector selector ring to the LOCX position as specified in Section 5.8, and notwithstanding the " Note" following Section 5.8 proceeded to Section 6.0 and performed additional projector securing actions.
This is an infraction.
(Civil Penalty - 51,000)
D.
10 CFR 20.403, " Notifications of incidents," requires in section (b)(1) that each licensee shall within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> notify by telephone and telegraph, mailgram, or facsimile, the Director of the appro-priate NRC Regional Office listed in Appendix D of any incident involving licensed material possessed by him and which may have caused or threatens to cause exposure of the hands to 75 rems or more of radiation.
Contrary to the above, while the licensee reported a possible hand overexposure to the Region II office of 9:35 a.m. on June 5, 1978 within the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> limit, the mailgram report was not transmitted until S:00 a.m. on June 6, 1978.
This is a deficiency.
E.
10 CFR 20.408, " Reports of personnel exposure on termination of employment," requires a radiation exposure report to the NRC on individuals who terminate employment with the licensee; a similar report to the terminated individual is required by 10 CFR ?O.409,
" Notifications and reports to individuals."
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i Appendix A s Contrary to the above, as of June 7, 1978, an exposure report had not been submitted to the NRC and to an individual who terminated employment in November 1977.
This is a deficiency.
This notice of violation is sent to you pursuant to the provisions to.
Section 2.201 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations.
You are hereby required to submit to this office, within twenty (20) days of your receipt of this notice, a written statement or explanation in reply, including for each item of noncompliance:
(1) admission or denial of the alleged items of noncom-pliance; (2) the reasons for the items of noncompliance, if admitted; (3) the corrective steps which have been taken by you and the results achieved; (4) corrective steps which will be taken to avoid further noncompliance; and (5) the date when full compliance will be achieved.
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Appendix B NOTICE OF PROPOSED IMPOSITION OF CIVIL PENALTIES Union Boiler Company License No. 47-16182-01 This Office has considered the enforcement options.available to the NRC including administrative actions in the form of written notices of viola-tion, civil monetary penalties, and orders pertaining to the modification, suspension or revocation of a license.
Based on these considerations we propose to impose a civil penalty pursuant to.Section 234 of the' Atomic Energy Act of 1954, as amended, (42. USC 2282), and toa 10 CFR 2.205 in the cumulative amount of Five Thousand Dollars ($5,000) for the' specific items of noncompliance set forth in Enclosure A to the cover letter.
In proposing to impose civil penalties pursuant to this section of.the Act and in fixing the proposed amount of the penalties, the factors identified in the statements of consideration published in the Federal Register with the rulemaking action which adopted 10 CFR 2.205 (36 FR 16894)
August 26, 1971, and the " Criteria for Determining Enforcement Action,"
which was sent to MRC licensees on December 31, 1974, have been taken into account.
Union Boiler Company may, within twenty (20) days of receipt of this notice pay the civil penalties in the cumulative amount of Five Thousand Dollars (55,000) or may protest the imposition of the civil penalties in whole or in part by a written answer.
Should Union Boiler Comoany fail to answer within the time specified, this office will issue an order imposing the civil penalties in the amoun'c proposed above.
Snculd Union Boiler Company elect to file an answer protesting the civil penalties, such answer may (a) deny the item of noncompliance listed in the Notice of Violation.in whole or in part, (b) snonstrate extenuating circum-stances, (c) show error in the Notice of Violation, or (d) snow other reasons why the penalties should not be imposed.
In addition to pro-testing the civil penalties in whole or in part, such answer may request remission or mitigation of the penalties.
Any written answer in accordance with 10 CFR 2.205 should be set forth separately from the statement or explanation in reply pursuant to 10 CFR 2.201, but may incorporate by specific reference (e.g., giving page and paragraph numbers) to avoid repetition.
Union Boiler Company's attention is directed to the other provisions of 10 CFR 2.205 regarding, in particular: failure to answer and ensuing orders; answer, consideration by this office, and ensuing orders; requests for hearings, hearings and ensuing orders; compromise; and collection, t
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Appendix B Upon failure to pay any civil penalty due which has been subsequently determined in'accordance with the applicable provisions of 10 CFR 2.205, the matter may be referrred to the Attorney General, and the penalty, unless compromised, remitted, or mitigated, may be collected by civil action pursuant to Section 234c of the Atomic Energy Act of 1954, as amended, (42 USC 2282).
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- 9 6 21 QARY G MARAHAM CARL O.ANDRCWS RtCKLIN BRCWN September 5, 1978
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THOM AS B. G EN N CTT S ARAM C. S MITH RICHARD M. FRANCl3 CERTIFIED MAIL - RETURN RECEIPT REQUESTED John G. Davis, Acting Director Office of Inspection and Enforcement United States _ Nuclear Regulatory Commission Washington, D. C.
20555 Re:
License No. 47-16182-101 -
Union Boiler Company
Dear Mr. Davis:
In response to your letter dated August 14, 1978, with Appendix A, Notice of Violation; and Appendix B, Notice of Proposed Imposition of Civil Penalties attached, Huntington Testing, a Division of Union Boiler Company, hereinafter
" Licensee", by counsel, pursuant to 10 C.F.R. S 20.205 submits the following answer:
I.
(A)
Licensee admits that the Radiographer re-ceived 1.9 rems exposure to his whole body and 123 rems to his left hand.
However, Licensee denies that the 1.9 rem the whole body is an " overexposure" under 10 exposure to,101 (b)(2) and admits that the 123 rem exposure C.F.R.
S 20.
to the left hand is an overexposure under 10 C.F.R. S 20.101(a).
Licensee submits that the civil penalty
($2,'000.00) assessed is excessive for an overexposure to the left hand and in conjunction with the explanation contained in its written statement enclosed herewith, respectfully protests this excessive assessment.
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Licensee-denies that it failed to make the
" Surveys" as required by 10 C.F.R.
S 20.201.
Licensee sub-mits that these surveys were, in fact, performed.
- However, Licensee submits that the Radiographer in the incident alleged, exercising personal judgment, chose to ignore the clear and correct measurement registered by the survey meter.
In conjunction with the explanation contained in its written statement, enclosed herewith, Licensee respectfully
. protests this assessment.
(C). Licensee admits that the Radiographer per-formed additional projection securing actions subsequent to its attempt and failure to move the connector selector ring to the lock position, as alleged.
The Licensee accepts full responsibility for this infraction and accepts imposition of the penalty as assessed.
(D)
Licensee admits the allegations contained in paragraph D of Appendix A'.
(E)
Licensee admits the allegations contained in paragraph E of Appendix A.
Licensee, for the above-stated reasons, respect-fully requests that the Acting Director, after review of this answer and the written statement attached hereto, reduce the imposition of the excessive penalty set forth in paragraph A of Appendix A and dismiss the penalty imposed under paragraph B of Appendix B.
Respectfully submitted, HUNTINGTON TESTING, a Division of Union Boiler Company By Counsel Ricklin Brown BOWLES, McDAVID, GRAFF & LOVE Attorneys for Licensee RB/nw cc:
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T H O M AS C. 8 EN N ETT SAR&M C. S M IT H RICHA90 M. FRANCIS CERTIFIED MAIL - RETURN RECEIPT REQUESTED John G. Davis, Acting Director Office of' Inspection and Enforcement United States Nuclear Regulatory. Commission Washington, D. C.
20555 i
Re:
License No. 47-16182-101 -
Union Boiler Company
Dear-Mr. Davis:
?
In response to your letter dated August 14, 1978,.
with Apper. dix A, Notice of Violation; and Appendix B, Notice of Proposed Imposition of Civil Penalties attached, Huntington Testing, a Division of Union Boiler Company, hereinafter "Licensen", by counsel, pursuant to 10 C.F.R. 9 2.201 submits i
the fo'. lowing written statement, as requested.
l I.
(A)
In answer to paragraph A of Appendix A, Notice of Violation, Licensee says that it has complied with the requirements of 10 C.F.R.
S 20.101(b) (2), in that it has determined that the dose alleged to have been received by the Radiographer's "whole body", when added to the accumu-lated occupation dose to the whole body, did not exceed 5 (N-18) rems.
Furthermore, Licensee has complied with 10 C.F.R. S 20.101(b)(3), in that it has determined the Radio-grapher's accumulated occupational dose to the whole body and it has been set forth on a form acceptable under current
' regulations and that it has therefore complied with 10 C.F.R.
S 20.102.
However, Licensee admits that in the incident alleged, the Radiographer did receive in excess of 18-3/4 n?.ricIx II
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e September 5, 1978 Page Two rems exposure to the extremities in one calendar quarter and that that constitutes overexposure to the extremities as defined in S 20.101(a).
(B)
In answer to paragraph B of Appendix A, Notice of Violation, Licensee answers that it has performed physical surveys in accordance with 10 C.F.R.
$ 20.201, and an evaluation of these surveys has been conducted.
In the instance alleged, the Radiographer inaccurately determined
.the extent of the radiation hazard present.
It contends, therefore, that insofar as the Licensee's duty under the section, the rea.uirements of 10 C.F.R. S 20.201 were complied with.
The Radicsrapher in this instance individually chose to ignore the clear measurement registered on the survey meter.
The meter which was in use had become wet with a mixture of fly ash and water which rendered the SK-1 audible speaker inoperable.
The Radiographer concluded that the offscale meter reading and the selector ring stiffness were directly attributed to the same cause.
(C)
In answer to paragraph C of Appendix A, Notice of Violation, Licensee answers that it has complied with the requirements of Condition 15 of the license, in that it has used licensed materials in accordance with vtatements, representations, and procedures contained in the application dated June 12, 1974, and in letters dated December 23, 1974 and December 4, 1977.
(D)
In answer to paragraph D of Appendix A, l
Notice of Violation, Licensee answers that it was deficient as stated.
The mailgram report was not transmitted due to clerical oversight.
(E)
In answer to paragraph E of Appendix A, Notice of Violation, Licensee answers that it was deficient as stated.
The report required by 10 C.F.R. S 20.408 has now been submitted to the Nuclear Regulatory Commission under separate cover.
II.
-Corrective steps which have been taken by Licensee in compliance with the requirements of 10 C.F.R. S 2.201 are as follows:
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The Radiographer has been reinstructed in the proper evaluation of survey results in order to more accurately determine the existence of radiation hazards.
(b)
The incident has been discussed with the Radiographer and the potential for similar incidents which result from his negligence has been impressed upon him.
(c)
The Radiographer has been reinstructed in the proper performance of radiation surveys.
This instruction lasted for approximately 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and the Licensee is satisfied that the employee can safely perform his duties.
(d)
All Radiographers and Assistants in the employ of the Licensee have been issued " Prima II" beepers which provide a secondary source of audible warning, should the survey meters become inoperable.
(e)
All Radiographers and Assistants are receiving continuing instruction in the performance of radiation surveys and evaluations.
(f)
All further incidents will be reported in compliance with 10 C.F.R.
S 20.403, should over-exposure occur.
(g)
Administrative controls have been established which will automatically require that reports be sent out in compliance with 10 C.F.R.
S 20.408.
III.
Full compliance was achieved by implementation of the above measures on June 15, 1978.
IV.
To further answer the Notice of Violation, the Licensee requests the Acting Director to consider the past
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September 5, 1978 Page Four history of the Licensee in complying with the Code.
Previous inspections by the Nuclear Regulatory Commission over the four years that the Licensee has operated have resulted in one item of noncompliance.
This item was a deficiency (2) in-posting a notice pursuant to 10 C.F.R.
S 19.11(a) (1),
and (3); and 19.11(b), which deficiency was immediately corrected on September 16, 1975.
No civil penalty was assessed as a result of this inspection and there has never been any other deficiency whatsoever found as a result of
' subsequent inspections.
The Licensee requests that ac-knowledgment of this past history be made in mitigating the assessment of civil-penalties assessed in the instant matter.
Respectfully submitted, HUNTINGTON TESTING, a Division of Union Boiler Company By Counsel e
Ricklin Brown LOWLES, McDAVID, GRAFF & LOVE Attorneys for Licensee RB/pw cc:
William Rader 1
Roger W. Magaw William Yeoman 1
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