ML20205Q304
| ML20205Q304 | |
| Person / Time | |
|---|---|
| Issue date: | 04/08/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20205Q289 | List: |
| References | |
| 15000001-99-01, 15000001-99-1, NUDOCS 9904210160 | |
| Download: ML20205Q304 (8) | |
See also: IR 015000001/1999001
Text
U.S. NUCLEAR REGULATORY COMMISSION
REGION ll
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Docket No.:
150-00001
License No.:
General License (10 CFR 150.20))
Report No.:
150-00001/99-01
Licensee:
Code Services, Inc., Madison, Alabama
Location:
NASA Marshall Space Flight Center, Huntsville, Alabama
Field Office, Madison, Alabama
inspection Date:
March 17 and 18,1999
Inspector:
Richard Gibson, Jr., Radiation Specialist
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Approved by:
Mark S. Lesser, Chief
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Materials Licensing / Inspection Branch 2
Division of Nuclear Materials Safety
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Enclosure 1
9904210160 990408
STPRG ESGAL
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EXECUTIVE SUMMARY
Code Services, Inc.
NRC Inspection Report No. 150-00001/99-01
An unannounced reciprocity field inspection pursuant to 10 CFR 150.20 was conducted on
March 17 and 18,1999, at NASA Marshall Space Flight Center (MSFC), Huntsville, Alabama,
an area of exclusive Federal jurisdiction, and the Code Services, Inc., field office in Madison,
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Alabama. The field inspection involved Code Services, Inc., a State of Alabama licensee,
conducting radiographic operations at the Marshall Space Flight Center under a general NRC
license pursuant to the reciprocity requirements of 10 CFR 150.20. The inspection included
interviews with licensee representatives, selective examination of records, and direct
observations of licensed activities. Areas inspected included: management oversight;
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personnel radiation protection; observation of radiographic operations; and office inspection.
The inspector determined that the licensee's management, which is new, appears to be directly
involved with the radiation safety program.
During the field inspection on March 17,1999, the inspector determined that licensee's
activities were appropriate to support the radiographic operations being conducted and to
ensure the safe use of radioactive materials. However, one apparent violation was identified.
Through interviews with cognizant licensee personnel at the temporary job site and field office,
and review of documentation, the inspector determined that on February 16,1999, at NASA
MSFC, a radiographer's assistant entered a radiography boundary during the conduct of
radiography without an alarm ratemeter. Further discussions and review of records with the
State of Alabama Department of Public Health, Office of Radiation Control, indicated two similar
events had occurred within the last year within the State of Alabama jurisdiction.
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REPORT DETAILS
1.
Management Oversight (87120)
a.
Scope
Code Services, Inc., was acquired by new management in October 1998. During
that time, the licensee hired a new Radiation Safety Officer to oversee licensed
activities and the radiation protection program. The new management had
retained most of the radiographers and radiographer's assistants who were
conducting radiography. The inspector interviewed knowledgeable licensee
representatives to understand the licensee's management oversight in order to
determine whether the organization and staffing were as required by the license
and commensurate with the complexity of the radiation safety program.
b.
Observation and Findinas
Through interviews with cognizant licensee representatives and review of
records, the inspector determined that the licensee's management is actively
involved with the radiation protection program. The inspector determined
through interview with licensee representatives at the temporary job site that the
Managing Partner and Technical Manager, who is also the Radiation Safety
Officer, have performed regular job site visits since the company was taken over
by new management. In addition, both managers are listed as persons to
contact on the emergency procedures. The licensee has approximately
12 certified radiographers, one assistant radiographer and two helpers.
Radiographic operations are conducted by the licensee at several locations in
the State of Alabama and at federal facilities under the jurisdiction of the NRC.
Radiographic operations at temporary job sites are conducted by at least one
radiographer and a radiographer's assistant. The radiographer and
radiographer's assistant are evaluated in the field during radiographic operations
by either the Radiation Safety Officer, the Managing Partner or their designee
every six months. During the time of this inspection, the licensee was
conducting radiographic operations for Brown Mechanical, a contractor of NASA
Marshall Space Flight Center.
c.
Conclusions
The inspector deterrnined that the licensee's management and staffing were
adequate. The inspector also determined that the licensee's management
appears to be directly involved with the radiation safety program.
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2.
Personnel Radiation Protection (87120)
a.
Scope
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Code Services, Inc., is licensed by the Alabama Department of Public Health,
Office of Radiation Control (license number 1075) to possess and use Iridium-
192 for industrial radiography within the jurisdiction of the State of Alabama. On
January 8,1999, the licensee filed an NRC Form 241 for an NRC generallicense
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in accordance with 10 CFR 150.20 to conduct licensed activities at NASA
Marshall Space Flight Center, Huntsville, Alabarna.
b.
Observation and Findinas
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During the inspection at the temporary job site and the licensee's field office, the
inspector determined through interviews with a radiographer, radiographer's
assistant and the Radiation Safety Officer for Code Services, Inc., that on
February 16,1999, the MSFC RSO conducted a field audit of Code Services,
Inc., performing radiography at the NASA Marshall Space Flight Center. The
inspector determined through interviews with licensee personnel and review of
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records, that the MSFC RSO observed the radiographer's assistant enter the
radiography boundary and approach the exposed source without an alarm
ratemeter. This was immediately brought to the attention of the radiographer
and corrected. NASA MSFC held a meeting on February 18,1999, with the
managers of Code Services, Inc., to discuss the findings identified by the MSFC
RSO. Code Services, Inc., responded to NASA MSFC in a letter dated
February 22,1999, signed by the Managing Partner, addressing the findings
identified by the MSFC RSO and their implementation of corrective actions.
Performing radiographic operations without an operating alarm ratemeter on
February 16,1999, is an apparent violation of 10 CFR 34.47(a), which states, in
part, that the licensee may not permit any individual to act as a radiographer or
a radiographer's assistant unless, at all times during radiographic operations,
each individual wears, on the trunk of the body, an operating alarm ratemeter.
The inspector determined that within the past year, the Alabama Department of
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Public Health, Office of Radiation Control, had conducted a field inspection of
Code Services, Inc., on May 4,1998, and an office inspection on October 8,
1998, following an incident that occurred on August 31,1998, with the licensee.
The State of Alabama on two occasions identified the licensee's failure to wear
alarm ratemeters while performing radiography. The inspector dettrmined that
Code Services, Inc., was cited for a violation by the State during en inspection on
May 4,1998, in which a radiographer was wearing an alarm rate meter that was
not turned on during radiography operations. On Oct6cer 8,1998, the State of
Alabama cited Code Services for a violation relating tc an incident that occurred
on August 31,1998, at a facility in Alabama, in which '.he raangrapher's alarm
ratemeter was not turned r n at the time of the incidert, and the helper did not
have an alarm ratemeter caring radiographic operatic ns. The incident involved
the helper carrying the radiographic exposure device to the next set up location.
The source was not fully retracted and secured into its shield and the helper
received a whole body dose of 1100 millirem.
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c.
Conclusions
The inspector concluded that recurring problems appear to exist regarding failure
of licensee personnel to properly wear alarming ratemeters. An apparent
violation was identified where on February 16,1999, the radiographer's assistant
failed to wear an alarm ratemeter.
3.
Observation of Radiographic Operations and Office inspection (87120)
a.
Scope
The inspector observed the licensee perform a radiography operation, discussed
plans for the operation, and reviewed selected records to determine if the
licensee was operating safely and in accordance with NRC requirements.
b.
Observation and Findinas
On March 17 and 18,1999, the inspector conducted a reciprocity inspection of
Code Services, Inc., performance of radiographic operations at a temporary job
site located on NASA Marshall Space Flight Center, Huntsville, Alabama, and at
the field facility in Madison, Alabama. The radiographic operations involved the
licensee performing radiography on 3/4 inch piping, approximately nine shots,
outside the nitrogen building, S-4659. The work area was a pipe shed located
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approximately 30 yards from the nitrogen building. Radiographic operations
were performed by a licensee's radiographer and a radiographer's assistant.
The inspector observed the licensee set up the area for radiography by
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establishing a posted rope boundary around the shed prior to exposing the
source. After ensuring that the area was free of unnecessary personnel and the
individuals in the nitrogen building were informed of the radiography, the
radiographer removed the camera, an Amersham Model 660B, S/N B-3410
containing 58 curies of irid'm-192, from the secured dark room of the vehicle
and set it up in the area fc radiography. The radiographer assembled the
camera with the necessary equipment and posted the high radiation area sign
prior to performing radiography. While the radiographer was performing
radiography, the radiographer's assistant was conducting confirmatory radiation
surveys in unrestricted areas and maintaining surveillance of the roped
boundary. The inspector observed that the radiographer and the radiographer's
assistant each wore a combination of a current TLD, a calibrated self-reading
pocket dosimeter and a calibrated operating alarm ratemeter during radiography,
in addition, the inspector observed that the survey instruments possessed by the
radiographer and the radiographer's assistant were calibrated and properly
functioning.
At the completion of each radiography operation, the inspector observed the
radiographer approach the camera from the rear with the survey meter and his
alarm raiemeter on, survey the entire circumference of the camera and the guide
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tube and ensure that the source had been completely retracted. The inspector,
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on occasion performed independent radiation surveys at the roped boundary
during radiographic operations and on the surface of the camera after the source
had been retracted at tne completion of radiography. Independent
measurements by the inspector indicated 0.7 mr/hr maximum along the roped
boundary and approximately 30 to 35 mr/hr on the surface of the camera.
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During the inspection at the field office of Code Services, Inc., the inspector
interviewed the RSO and selectively reviewed records to determine certification
and qualifications of the radiographer and radiographer's assistant who were
conducting radiography at the temporary job site at NASA MSFC, Huntsville,
Alabama. Through discussion with the RSO and review of records, the inspector
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determined that both the radiographer and radiographer's assistant received
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required safety training. The inspector verified that the State of Alabama
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approved the radiography training received by both the radiographer and the
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radiographer's assistant and that they were certified under the State of Alabama.
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The inspector also reviewed records of audits and utilization logs of the
radiographer and the radiographer's assistant and determined that they were
audited by the RSO within the last six months and the utilization logs were
properly completed and up to date.
c.
Conclusions
From the observation of radiographic operations and the inspection at the field
office, the inspector determined that the licensee conducted activities in
accordance with the license conditions and NRC regulatory requirements.
EXIT MEETING SUMMARY
An exit meeting was held with the licensee representative on March 18,1999. The overall
findings from the inspection were discussed, including the concerns that were identified by the
MSFC RSO and the associated apparent violation of 10 CFR 34.47(a). The licensee
reemphasized that management is new to the radiation protection program; however, they
expressed a commitment towards the support of the radiation protection program and
compliance with NRC regulatory requirements. The licensee did not specify any information
reviewed during the inspection as proprietary in nature.
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ATTACHMENT
1.
PERSONS CONTACTED
Licensee
- Chris Chandler, Technical Manager and Radiation Safety Officer
James Chandler, Radiographer
Tim McMurry, Radiographer's Assistant
- Attended the March 18,1999, Exit Meeting
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INSPECTION PROCEDURE USED
Industrial Radiography Programs
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ABBREVIATICNS USED
CFR
Code of Federal Regulation
MSFC
Marshall Space Flight Center
mci
millicurie
mrem /hr
millirem per hour
National Aeronautics and Space Administration
NRC
Nuclear Regulatory Commission
Radiation Safety Officer
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JPEN PREDECISIONAL ENFORCEMENT CONFER '
.f AGENDA
CODE SERVICES, INC.
APRll 22,1999, AT 1:00 P.M.
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NRC REGION ll OFFICE, ATLANTA, GEORGIA
1.
OPENING REMARKS AND INTRODUCTIONS
L. Reyes, Regional Administrator
11.
A. Boland, Enforcement Officer
Enforcement and Investigations Coordination Staff
Ill.
SUMMARY OF THE ISSUES
L.Reyes
IV.
STATEMENT OF CONCERNS / APPARENT VIOLATION
D. Collins, Director
Division of Nuclear Materials Safety
V.
LICENSEE PRESENTATION
R. Lambert, Managing Partner
Code Services, Inc.
VI.
BREAK /NRC CAUCUS
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NRC FOLLOWUP OUESTIONS
Vill.
CLOSING REMARKS
L.Reyes
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Enclosure 3
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