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Insp Rept 15000001/99-01 on 990317-18.Violation Noted. Major Areas Inspected:Mtg Oversight,Personnel Radiation Protection,Observation of Radiographic Operations & Office Insp
	ML20205Q304
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Issue date:	04/08/1999
From:	; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
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ML20205Q289	List: ML20205Q283; ML20205Q304;
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	15000001-99-01, 15000001-99-1, NUDOCS 9904210160
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U.S. NUCLEAR REGULATORY COMMISSION

REGION ll

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Docket No.: 150-00001 l

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License No.: General License (10 CFR 150.20)) l

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 j

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Approved by: Mark S. Lesser, Chief l

Materials Licensing / Inspection Branch 2

Division of Nuclear Materials Safety

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Enclosure 1

9904210160 990408

PDR STPRG ESGAL

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EXECUTIVE SUMMARY

Code Services, Inc. I

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,

l 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 1

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; j

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. l

Through interviews with cognizant licensee personnel at the temporary job site and field office, I

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

i 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, 1

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 I

in accordance with 10 CFR 150.20 to conduct licensed activities at NASA

Marshall Space Flight Center, Huntsville, Alabarna.

b. Observation and Findinas l

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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 I

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. j

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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 '

approximately 30 yards from the nitrogen building. Radiographic operations

were performed by a licensee's radiographer and a radiographer's assistant. l

The inspector observed the licensee set up the area for radiography by <

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

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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,

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 l

required safety training. The inspector verified that the State of Alabama j

approved the radiography training received by both the radiographer and the i

radiographer's assistant and that they were certified under the State of Alabama. '

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

2 INSPECTION PROCEDURE USED

IP 87120 Industrial Radiography Programs

3. ABBREVIATICNS USED

CFR Code of Federal Regulation

Ir-192 Iridium 192

MSFC Marshall Space Flight Center

mci millicurie

mrem /hr millirem per hour

NASA National Aeronautics and Space Administration

NRC Nuclear Regulatory Commission

RSO Radiation Safety Officer

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JPEN PREDECISIONAL ENFORCEMENT CONFER ' .f AGENDA

CODE SERVICES, INC.

APRll 22,1999, AT 1:00 P.M.

l NRC REGION ll OFFICE, ATLANTA, GEORGIA

1. OPENING REMARKS AND INTRODUCTIONS

L. Reyes, Regional Administrator

11. NRC ENFORCEMENT POLICY

A. Boland, Enforcement Officer

Enforcement and Investigations Coordination Staff

Ill. SUMMARY OF THE ISSUES

L.Reyes l

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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

Vll. NRC FOLLOWUP OUESTIONS

Vill. CLOSING REMARKS

L.Reyes

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Enclosure 3

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ML20205Q304

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