ML20205H221
| ML20205H221 | |
| Person / Time | |
|---|---|
| Issue date: | 08/13/1986 |
| From: | Fisher W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Gibson H H & G INSPECTION CO., INC. |
| References | |
| NUDOCS 8608200021 | |
| Download: ML20205H221 (1) | |
See also: IR 015000042/1985001
Text
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AUG 13 W
Docket: 15000042
, General License (10 CFR Part 150) =
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H&G Inspection Company, Inc.
ATTN: Mr. Harry Gibson
P.O. Box 721856
Houston, TX 77272
Gentlemen:
Thank you for your letter of July 29, 1986, in response to our letter and
the attached Notice of Violation dated July 21, 1986. We have reviewed your
reply and find it responsive to the concerns raised in our Notice of
Violation. 'We will review the implementation of your corrective actions
during a future inspection to determine that full compliance has been achieved
, and will be maintained.
1
Sincerely,
'Lpw L.;...J Ly;"
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William L. Fisher, Chief -
Radiological and Safeguards
Programs Branch
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CC:
Texas Radiation Control Program Director
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P. O. BOX 721856 713-498 6517
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liOUSTON TEXAS 77272
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July 29, 1986
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Director, Office of Inspection and Enforcement -
U.S. Nuclear Regulatory Commission
Washington, D. C., 20555
SUBJECT: DOCKET No. 15000042
General License (10 CFR Part 150)'
EA 86-104
Responding-NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL
PENALTY (NRC INSPECTION REPORT NUMBERS 15000042/85-01
AND 15000042/85-02)
Dear Sir:
Pursuant to the provisions of 10 CFR 2.01, H & G Inspection hereby submits
a written statement or explanation regarding each alleged violation addressed
in the Notice of Violation Letter dated July 21, 1986. The particular vio-
lations and associated responses are set forth below:
A.) Violation of 10 CFR 20.101 except as provided by 10 CFR 20.101 (b).
A Radiographer's Assistant in the Shute Creek area of Wyoming did,
in fact, receive a whole body dose of 3.4 rems during the fourth
quarter of 1985. It was discovered through an investigation of the
incident that the exposure resulted when the Assistant approached
the exposure device, without his survey meter in hand, while the
source was partially out of the device. The action taken immediately
upon notification from the field that the Assistant's dosimeter had
gone off-scale,was to have the film badges of the Radiographer and
the Assistant mailed in for Emergency Processing,along with the
removal of the Assistant from working with Radioactive Material to
the office and darkroom aspect of our operation, pending notifica-
tion from the Film Badge Service of the level of exposure received.
Implemented due to this incident was the use of the G.E. Smith and
Associates, Inc. Model GS-15 Personal Alarm or Audible Dosimeter by
each radiographic crew in the field performing operations. Al so
site inspections of each radiographic operation by H & G Inspection's
on-site supervisor were stepped up. Full compliance was achieved
almost immediately following the incident at the Shute Creek facility.
B.) Vi lation of 10 CFR 34.43 (b).
On November 6,1985, a radiation survey was not perfonned following
a radiographic exposure to determine that the sealed source had
returned to its shielded position inside the exposure device, result-
ing in the over-exposure to the Radiographer's Assistant listed in
the above described violation.
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, Director, Office of Inspection and Enforcement-U.S. NRC
1-
Docket No. 15000042 General License (10 CFR Part 150) EA 86-104 ,
Responding-Notice of Violation and Proposed Imposition of Civil Penalty l
(NRC Inspection Report Numbers 15000042/85-01 and 85-02) !
j July 29, 1986 -2-
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B.) Violation of 10 CFP. 34.43 (b). Continued....
i On November 13, 1985, at the time of the site inspection of Mr. Larry Ric-
ketson, a Radiographer performed radiography without performing a radi-
ation survey following each exposure. On the same date he observed a
i second radiographic crew performing incomplete and therefore inadequate
l surveys after radiographic exposures, in that the guide tube of the ;
, device was not surveyed. The personnel were questioned in regard to t
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the violation of these regulations and none of them had reasons for I
completely disregarding these procedures. Upon discovery of these
violations, H & G Inspection Supervisory personnel verbally reprimanded
these crews. Then a policy was implemented for fines for personnel
who violated radiation safety policies. The First Violation is a fine
of $100.; the Second Violation-$200.; with the Third Violation resulting
' in Termination of Employment, due to continuous safety violations. Also !
implemented was the stepping-up of Supervisors' periodic unannounced
inspections, at intervals of one inspection per hour per crew, of the
areas where radiographic operations were being performed.
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C.) Violation of 10 CFR 20.201 (b), (1) and (2) as per 10 CFR 20.105.
A radiography crew performing radiography on November 13,1985, at the
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time of the inspection of Mr. Larry Ricketson, in the Shute Creek area
of Wyoming, did not complete the Daily Job Sheet (or Area Survey) con-
firming that the radiation levels in unrestricted areas did not exceed
the allowable limits as set forth in 10 CFR Part 20.
Upon the discovery of the violation, the H & G Inspection personnel were
interrogated regarding this and stated that they had just overlooked ;
(or forgotten) the paper work, in their haste to getlto work. They
were immediately questioned as to whether the area was indeed cardoned
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off; the crew confirmed the area was, in fact, not exceeding the allow-
able limits (2 MR/HR at the ropes).
The action taken to attempt to prevent such an incident from recurring
has all been mentioned in the preceding paragraphs. Highlighting the
steps to prevent recurrence of such incidents: Fine Policy for Safety
l Violations was implemented. Supervisory monitoring and periodic unnanounced
inspections were stepped up. The third such preventative measure is a
survey (form) performed at the beginning of each shift, before lunch,
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after lunch, and at the end of each shift. These surveys are to be per-
formed by the supervisor or a designated person. The form is dated,
checks each radiographer and assistant radiographer's dosimeter (both
before shift and after shift), surveys camera to assure that the source
is secure, and checks survey meter to assure tbt it is within calibra-
tion and that the area is roped off and secure. These procedures were
implemented in late November 1985.
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Director, Office of Inspection and Enforcement-U.S. NRC
Docket No. 15000042 General License (10 CFR Part 150) EA 86-104
- - Responding-Notice of Violation and Proposed Impsoition of Civil Penalty
! (NRC Inspection Report Numbers 15000042/85-01 and 85-02)
)- July 29, 1986 -3-
!' D.) Violation of 10 CFR 34.24 and 10 CFR 34.43 (a).
Survey Meter Victoreen Model 492 Serial Number 1905 was, in fact,
utilized by a radiographic crew in the Shute Creek area of Wyoming
on Novemer 11, 1985 with the due date for calibration having been
October 24, 1985.
The supervisor did not check the survey instrument before issuing
it and the radiographer for whom the instrument was issued, did
not check the calibration date either. Upon notification of this,
all survey meters which were presently out of calibration or within
. one week of going out of calibration,were shipped back to the home
office for recalibration. i
The preventativemeasures which we have taken to prevent this from
i recurring is, once again, the fining policy for safety violations,
the utilization of the forms for checking and double-checking equip-
ment;which survey meters are checked four times for each shift to
! assure that they are within calibration and operable, and the periodic
unannounced inspections by the supervisors. Also the Radiation Safety
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Officer in the Houston, Texas (home) office will contact by telephone,
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two weeks in advance to meters going out of the three month calibra-
tion period, and, in writing, with replacement meters, one week in -
, advance to assure such meters will not be utilized.in radiograWic
i operations. This went into effect in early December 1985. l
E.) Violation of 10 CFR 34.42 as required by 10 CFR 20.203 (b) and (c) (1). l
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At the time of the site inspection by Mr. Ricketson on November 13, !
1985, radiographic operations were observed as being performed in a
High Radiation area which was not posted with either Radiation signs '
- or High Radiation signs. When questioned, the radiographer had no
! excuse for operating without " Caution Radiation Area" or " Caution
j High Radiation Area" signs conspicuously posted, as required by the
Regulations. When interrogated, it was discovered that they had kept
constant visual surveillance of the area to keep unauthorized per-
!. sonnel from entering the area and receiving a radiation exposure.
i
The action taken to prevent recurrence of this encompasses the fines
for safety violations, the monitoring and periodic unnanounced.inspec-
tions by the supervisors of radiographic operations and the checking '
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at beginnings and endings of shifts, to assure that radiographers
have posted signs designating radiation areas.
H & G Inspection Company strives to provide the safest radiographic operations
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in the industry. Because of our timely and comprehensive corrective actions,
including initiation of a program to deter violations of operating procedures,
I multiple internal inspections and a provision for alarming dosimeters for all
- radiographers, I feel that we have not only deterred but eliminated further -
- violations from recurring.
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Director, Office of Inspection and Enforcement-U.S. NRC
..
Docket No. 15000042 General License (10 CFR Part 150) EA 86-104
Responding-Notice of Violation and Proposed Imposition of Civil Penalty
(NRC Inspection Report Numbers 15000042/85-01 and 85-02)
July 29, 1985 -4-
It is my feeling that H & G Inspection maintains an excellent safety train-
ing program as well as effective management control over its radiation
safety program.
If further information is needed, please advise.
Thank you.
Yours truly,
FOR H & G INSPECTLOS COMPANY
,z
Steve M. Steen
Vice President
Radiation Safety Officer
cc: Mr. Robert D. Martin
Regional Administrator
U.S. Nuclear Regulatory Commission
Region IV
611 Ryan Plaza Drive, Suite 1000
Arlington, Texas 76011
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