ML20206R132

Notice of Violation from Insp on 990317-18.Violation Noted:Individual Was Granted NRC General License,Per 10CFR150.20,acted as Radiographer Assistant & Failed to Wear Alarm Rate Meter.Pages 19 Through 23 of Encl Not Included

ML20206R132
Person / Time
Site:	15000001
Issue date:	05/07/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20206R131	List: IR 015000001/1999001 ML20206R132
References
15000001-99-01, 15000001-99-1, EA-99-074, EA-99-74, NUDOCS 9905200007
Download: ML20206R132 (53)

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NOTICE OF VIOLATION i l

Code Services, Inc. Docket No.150-00001 Huntsville, Alabama License No. General License j EA 99 074 During an NRC inspection conducted on March 17 and 18,1999, a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedures for NRC Enforcement Actions," NUREG-1600, the violation is listed below l 10 CFR 150.20 provides in part that any person who holds a specific 2 cense from an Agreement State is granted an NRC general license to conduct the same activity in areas of exclusive Federal jurisdiction within Agreement States, provided an NRC j Form 241 is properly filed. The general license is subject to all provisions of the Act and '

to all applicable rules, regulations and orders of the Commission including Subpart C of 1 Part 34. ,

1 10 CFR 34.47(a) requires, in part, that a licensee may not permit any individual to act as a radiographer or a radiographer's assistant unless, at all times during radiographic j operation, each individual wears, on the trunk of the body, an operating alarm rate meter.

Contrary to the above, on February 16,1999, an individual, employed by Code Services, Inc., who holds a specific license from the State of Alabama and was granted an NRC generallicense pursuant to 10 CFR 150.20, acted as a radiographer's assistant at the NASA Marshall Space Flight Center, Huntsville, Alabama, an area of exclusive Federal jurisdiction, and the individual failed to wear an alarm rate meter. (01013)

This is a Severity Level 111 violation (Supplement VI).

Pursuant to the provisions of 10 CFR 2.201, Code Services, Inc. is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region ll, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for the violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps i that will be taken to avoid further violations, and (4) the date when full compliance will be l achieved. Your response may reference or include previously docketed correspondence,if the correspondence adequately addresses the required response. If an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be

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issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.

If you contest this enforcement action, you should also provide a copy of your response to the Director, Office of Enforcement, U. S. Nuclear Regulatory Commission, Washington, DC 20555-0001, and the Enforcement Officer, Region ll.

Under the authority of Section 182 of the Act,42 U.S.C. 2232, this response shall be submitted under oath or affirmation.

Enclosure 1 9905200007 990507 PDR STPRO ESGAL PDR g L.

i Notice of Violation 2 Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction, if personal privacy or proprietary information ,

is necessary to provide an acceptable response, then, please provide a bracketed copy of your 1 response that identifies the information that should be protected and a redacted copy of your l response that deletes such information. If you request withholding of such material, you must I specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will ;

create an unwarranted invasion of personal privacy or provide the information required by 1 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

In accordance with 10 CFR 19.11, you may be required to post this Notice with two working days.

Dated at this 7th day of May,1999 i

I LIST OF ATTENDEES Nuclear Reaulatorv Commission:

L. Reyes, Regional Administrator D. Collins, Director, Division of Nuclear Materials Safety (DNMS) l A. Boland, Enforcement Officer, Enforcement and Investigations Coordination Staff (EICS)

O. Evans, Regional Counsel 4 M. Lesser, Chief, Materials Licensing / Inspection Branch 2, DNMS A. Jones, Enforcement Specialist, ElCS

R. Gibson, Health Physicist, DNMS D. Moser, Health Physicist, DNMS l J. DelMedico, Senior Enforcement Specialist, Office of Enforcement (telephone conference)

D. Dambly, Assistant Counsel for Hearings and Enforcement, Office of General Counsel i

Code Services. Inc.

Reggie Lambert, Managing Partner l Chris Chandler, Radiation Safety Officer I

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L NRC Meeting We appreciate the opportunity to address this body, offer an explanation of the -

occurrence in question and to demonstrate our commitment to safety. The management I of Code Services realizes the importance of safety and has committed the company and I

it's employees to full implementation of its' radiation safety as well as its' industrial l safety programs.  !

1 l In the binder provided are the following items ofinformation that may be pertinent to the conclusion of this hearing today. Each item will be addressed during our presentation.

> Company History

> Resume's of Managing Partner and Radiation Safety Officer l

> Employee Handbook l > MSFC Finding

> Written Statements of Radiographer and Assistant Radiographer l

' > Management Evaluation and Conclusion of Finding ( Included within this document )

> Recovery Plan / Corrective Action

> Copies of Safety Meeting (Subject Matter and Attendance)

> . History of Unannounced Audits By Code Services.

Company History:

The company was formed in 1991 under the name of Code Services, Inc. The founder

. and owner until October of 1998 was W. H. Stewart III. Mr. Stewart also held the position of radiation safety officer. During the years 1992 through 1998 the company was audited by the State of Alabama to test compliance of the safety program. On many occasions findings ranged in severity and in some cases were repeat offences. It became apparent that the company . lacked implementation of its' safety program and the commitment of management was not visible. At this point the company was in jeopardy oflosing its license.

On October'1,1998 Reggie Lambert acquired the company. The company name was changed to Code Services, LLC.

On October 3,1998 the State inspector arrived for an un-announced audit of the company safety program. On this occasion there were nine findings ranging in severity and some were repeat offences. This was an inherited problem of the former regime.

Mr. Chris Chandler was brought on board as Radiation Safety Officer and along with the new owner committed themselves to the task of implementing the company safety program.

Enclosure 3

In the month of January 1999 the State again performed an un announced audit on the company and its safety program. Although there were seven findings, none were in a severe category and most were clerical in nature. The vast improvement in the program and its implementation was obvious.

On March 17th and 18th the NRC performed an un announced audit on Code Services at ~

the MSFC while performing radiography and at its office. During this audit there were no findings.

Management Team:

The resume's included demonstrate the skills and background of the Managing Partner and the Radiation Safety Officer.

Personnel Handbook:

The company personnel handbook (included) contains the company policy with regard to conduct and safety.

MSFC Finding:

The finding states in part that the radiographer assistant was observed entering a restricted area without wearing proper monitoring equipment, (alarming rate meter).

Upon notification of this finding the Code Services RSO immediately investigated the i

situation. The radiographer in charge and the assistant were interviewed. Written statements were taken and are included.

Written Statements:

The statements of the radiographer and assistant indicate that there was a misunderstaliding of what the MSFC RSO was asking for and what the radiographer assistant understood.

Conclusion of Management:

i Although there are conflicting statements and an apparent misunderstanding, the management of Code Services has concluded that neither the radiographer nor the assistant acted in a manner conducive to lending assistance to the MFSC RSO.

O It is the company's position and policy that any employee working in any area should not only answer direct questions but also assist any authorized person performing surveys or audits. Individuals should offer for inspection all personal monitoring equipment whether asked or not.

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These individuals have been reprimanded and all personnel have been made aware of the

! company policy that requires immediate termination of employment if an individual is discovered not wearing all required monitoring equipment.

Recovery Plan / Corrective Action:

Included Safety Meetings:

Included Un-announced Audits: i Included 'i l

Summary:

The management of Code Services is committed to the implementation of its safety program. Willful non-compliance with our program or those of clients will not be tolerated. The company will continue to enhance personnel training and safety awareness.

In the few months this management team has been in place, the program has undergone vast improvements both in structure, content and implementation. The management has taken an active role with regard to quality and safety and will continue to participate and set the pace for the company.

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Reggiff?ambeY '

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i Enclosures

Curriculum Vitia for Reggie Lambert l

Mr. Lambert has 25 years experience in Management, Quality Assurance and Quality Control. Having served as General Manager and Quality Assurance Manager for '

a fortune 500 company, Mr. Lambert has developed a I panoramic understanding 'of the quality needs of the I client. Building on this, Mr. Lambert has assembled a I management and service team capable of providing the very best quality service.

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r Summary Experience for

. Chris Chandler Over eighteen years of experience in Non-Destructive examination and interpretation, field supervision and Radiation Safety Assurance. Extensive experience in various military standards and specifications and ASME piping and vessel codes. Certifiable Level III in RT, PT, MT, VT.

Work Experience:

Visual Testing, LevelII Liquid Penetrant, Level II Radiographic Testing, Level II Magnetic Particle Testing, Level II Ultrasonic Testing (Thickness Only), Level II Employment History: "

Il-98 to Present Code Services Technical Manager Madison, AL Radiation Safety Officer Level III Technician RT, UT, MT, PT, VT 8-97 to 11-98 MQS Inspection. Operations Supervisor Madison. AL Extended Radiographer .

Level II RT, UT, MT, PT, VT 3-93 to 2-97 Code Services, Incorporated Level III NDT Inspector Madison, AL RT, UT, MT, PT, VT

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2-87 to Il-92 Morton Thiokol. LevelII Film Interpretor Redstone Arsenal, AL ]

o 1-81 to 2-87 Hitco, Inc. Level IIInspector Athens, AL RT, MT, PT, VT

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CODE SERVICES EMPLOYEE HANDBOOK I

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l Revised 10-1-98

Table of Contents POLICY STATEMENT CHAPTER 1 Conditions for Employment CHAPTER 4 Confidentiality Clause Security Policy Work Week Holiday Pay CHAPTER 5 Overtime Pay Safety Policy Minimum Pay Rework Pay CHAPTER 6 Per Diem and Expense Drug Policy Overhead Time CHAPTER 2 Vacation Sick Leave and Personal Time On the Job injuriestillness Necessary Time Off Comnany Genents Performance Reviews / Merit increases CHAPTER 3 Pacilities Use Policy Equipment Policy Vehicle Policy Code of Conduct Code of Conduct Viodations Job Site Policy

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Code Services is a Total Quality Management Company. It is the I policy of our Company that the function of Quality Management shall \

exist in each individual operation to the degree necessary to ensure j that: 'l

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1. The acceptance and performance standards of ourproducts and i services are met.

2. The cost of quality goalsfor each operation is achieved.

policy statement i

Code Services is an equal opportunity employer. Hiring, promoting, pay or benefits are not l

based on religion, age, sex, national origin, race or color.

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Employees of Code Services are required to comply with all Local, State and Federal laws  ;

regarding sexual harassment in the work place. This applies to all circumstances including l

, employees of Code, clients or visitors.

l This Company strives to achieve the highest quality of service, workmanship and client approval in a congenial atmosphere. In order to maintain this goal, individuals who violate l this policy, Code's drug policy, safety policy or code of conduct will be subject to dismissal for cause.

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REHEM CONDITIONS FOR EMPLOYMENT No individual shall be considered for employment with Code Services unless two forms L

of identification can be produced, as required by the U.S. Department of Justice, j Immigration and Naturalization Service. i l No individual shall be considered for employment with Code Services until he has been

! admirustered and passed a drug test.

No individual shall be considered for employment unless that individual agrees to the terms of this policy, its addendum and Code Services Code of Conduct that is made a l part of this document.

i No-individual employed by Code Services is considered hired until completion of a l tlurty-day probationary period. During this probationary period a new employee can i be dismissed without a hearing on the cause.

No individual shall be eligible for company benefits until the above-described probationary period has been satisfied. Thereafter, enrollment in insurance programs and other benefits will be offered on the first day of the month subsequent to completion of said probationary period.

No individual shall be considered for employment with Code Services until they have complied with the pre-employrnent testing procedure.

1 Confidentiality Clause Divulging company or customer information to outsiders is a serious offense and may be cause for dismissal and/or legal action. The acceptance of this policy by an employee's signature affixed to the back of this document is a legally binding commitment to non-disclosure.

Any employee who knowingly interferes with, circumvents or causes the loss of Company contracts will be subject to dismissal and/or legal action in civil courts.

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7 WORK WEEK i

Code's workweek begins on Monday and ends on Sunday. Employee time is tracked '

through work orders and overhead authorization sheets. Work Orders are to be filled out and submitted daily. Overhead Authorization sheets and expense accounts must be i filled out daily left in the office and must be submitted on Monday by 10: 00 AM. -

Failure to submit paper work in a timely fashion may result in delay of paycheck. By I

noon on Tuesday, Accounting shall provide each hourly employee with a listing of the hours worked the previous week. Any errors or omissions should be reported by Wednesday evening. Employee's paychecks will be available on the following Friday morning by 8:00 AM at the front office.

l l Office personnel are to report as directed upon hire date. Lunch is one hour and must t

be scheduled to allow at least one secretary to be on duty at all times during the workday. Closing time is 5:00 PM. Unscheduled early arrival or late departure does l not accumulate and can not be used to offset late arrival or early departure. Tardy arrival will be docked to the nearest 1/10 hour.

i HOLIDAY PAY Code has no paid holidays; however, if work is performed on a Cornpany observed holiday; pay will be at double time rate. The following are recognized holidays:

New Year's Day Memorial Day I July 4 Labor Day Thanksgiving Day Christmas Day 4

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l OVERTIME PAY l

Employees will be paid the equivalent of time and one half after completion of forty hours of work during any pay period. Over eight hours in one day will be paid at -

straight time. The cognizant department supervisor must approve all overtune.

MINIMUM PAY It is recognized that individuals may be called in to perform certam minimum charge projects. Employees are paid on the basis of actual time worked without regard to Company's charge to client. On occasion, it may be necessary to call employees in for l' i short-term projects. In the event of such an occurrence, employees will be paid two

) hours.

REWORK PAY Code provides trauung, matenals and equipment for technicans to pedorm work to required codes and specfications. Substandard work can not be tolerated. It shall be the technician's responsibility to assure all work meets specfic codes and standards.

1. Code Services will not pay for hours of rework for film turned into customer that l does not meet code.

l 9 Wages will be deducted as follows: l

a. Time will be deducted in proportion to the number of hours necessary to I perform rework.

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b. If the responsible technician (s) is not available to perform the rework, those perfornung the work will be paid and that amount of time required to perform the rework will be deducted from the responsible technician (s).

c. Individuals on guaranteed forty would have rework deducted from their forty-hour mmunum if no overtune is worked.

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Processing rework will be deducted from the darkroom technician. Technique rework will be deducted from the radiographer.

4. Continued rework may result in dismissal.

5. Individuals may redeem lost hours when:

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a. There has been no rework for a period of three months.

6. This policy has become a necessity due to the amount of rework done during the past. It is designed to insure the success of Code Services and to instill a better work ethic in all that contribute to a joint effort of quality and services.

PER DIEM AND EXPENSES Hourly employees will receive payment for meals plus lodging for any out of town ovemight assignments. Lodging will be paid in advance by Code Services; per diem will be included in employees' paycheck for that pay period. Meals will be paid for employees on overnight assignment in the following manner:

Breakfas t. . . . . . . . . . . . . . .S 5.00 Maxunum l

Lunch. . . . . . . . . . . . . . . ..S 5.00 Maxunum Dinner. . . . . . . . . . . . . . . . 510.00 Maxunum Code Services will not pay for alcoholic beverages or meals that exceed the allowances set forth above.

EXPENSES Meals are not provided by Code Services for any jcb that does not involve ovemight travel. Mileage will be reimbursed at the rate of 31 cents per. mile for personal vehicles.

Unless personal vehicle usage is approved in advance, mileage will be disallowed.

An expense report must be submitted by 7:00 AM the following Monday. Mileage will be included in paychecks. Gas or credit cards for anticipated expenses (gasoline, oil, etc.) will be issued for out of town assignments. Receipts for these ourchases must be submitted with expense account or be subject to payroll deduction.

Lodging arrangements will be made through the office (purchasing department).

Itemized receipts are required for all expenses Receipts are to be submitted with an expense report. Reimbursement will be included in your paycheck. Cash advances for expenses must be approved in advance and the amount deducted from the paycheck for that pay period.

Code Services will not reimburse any expenses without a receipt and only the expenses listed above, under the conditions set forth.

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, l In the event that special circumstances arise, any other expenses not listed above must be approved in advance.

Code Services does not deduct time for meals when eaten during work. Time taken for i meals away from the assigned job site are to be deducted from the time sheet by the employee. .

OVERHEAD TIME l Any employees who charge time to overhead must first fill out an Overhead Authorization form and have it approved by management or this time will not be paid.

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l VACATION Code Services Employees with more than one-year service and less than three years service are entitled to one week paid vacation per year. Those with over three years service are entitled to two weeks paid vacation per year. Vacation time does not accrue.

Thirty days notice, in writing, must be given when requesting vacation.

Vacations may only be taken in seven-day increments.

Vacation time not taken by the employee's anniversary is lost. If vacation is requested and denied, it is still lost upon the employee's anniversary.

At employee termmation, for any reason, all accrued vacation is lost.

SICK LEAVE AND PERSONAL TIME Code Services does not have paid sick leave or personal time for employees. However, reasonable time off for bereavement in the event of death of an immediate family member will be allowed with consent of management.

NECESSARY TIME OFF Code recognized that time off is required for jury duty, maternity leave and military service. Time off for these situations should be approved in advance. Positions will be secured for a period of 12 weeks. There is not pay for these absences from work...

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ON THE JOB INJURIES / ILLNESS Although evg effort is made to ensure a safe and healthy workplace, accidents will happen. On the job injuries / illnesses are normally fully covered by Workman's .

Compensation; however, in order for them to be covered, they must be reported to our insurance company within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the occurrence.

In the event that you are injured or become ill while on the job, notify your supervisor or the Company Personnel Manager immediately. If the injury happens while the office is closed, notify the Company Personnel Manager the next business day. Except in an emergency; notify Personnel prior to going to the doctor.

Supervisors are responsible for ensuring that their subordinates receive proper medical treatment and that Personnel is notified of any accidents, injuries, or illnesses.

COMPANY BENEFITS Code Services insurance coverage for all full time employees. Company pays 50% of the premium for the employee only. Family coverage is available at the employees' -

expense.

I PERFORMANCE REVIEWS / MERIT INCREASES All employees will be given Objectives at the end of their 30-day trial work period and each January thereafter. Periodic performance reviews will be conducted utilizing the objectives assigned to each employee. Increases in pay rates will be determmed from the performance reviews and will be based solely on merit and performance without regard to length of employment.

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l FACILITIES USE POLICY Unauthorized or personal use of company facilities or client facilities and/or equipment is forbidden.

Employees that are not scheduled for work are not allowed in the facility after work hours. (NO EXCw110NS)

Technicians are not permitted in the front offices of Code's facility unless summoned on official business. (NO EXLW110NS)

All technicians are to park in the east parking lot. Office personnel and visitor parking _

is on the west side. There will be no parking at any time in loading dock area. No ._

personal vehicles are allowed in the west drive or in back of the building.-

Each employee is responsible for mamtainmg the area of Code's facility in which he/she works. The following " housekeeping" chores are to be assumed by all employees:

Maintainmg a clean and orderly lobby area Maintaming a neat and orderly desk Cleaning and mamtaining an orderly restroom and kitchen area Removalof garbage i Keeping floors and furniture clean... includes vacuummg, sweeping and i dusting as necessary.

Keepingitems in designated places Cleaning of mobile darkrooms.

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l EQUIPMENT POLICY Equipment assigned to employees for use must be mamtained and any damage or needed repair is to be reported to the employee's supervisor immediately. -

Certam equipment requires employee signature prior to assignment to the employee.

Loss, theft, damare and/or abuse of this eauipment will be charged to the employee to whom it was assigned. Equipment that has been assigned should NEVER be loaned to another employee. It should be turned in to the supervisor and removed from the employee's equipment list prior to being reassigned.

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VEHICLE POLICY Employees using Code vehicles should observe the applicable State laws for the use of l motor vehides. Obey all traffic rules.

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Employees using Code vehides should observe all clients site requirements for the use of motor vehicles.

Vehides should be kept clean and in order. Each truck should have its own racks, cassettes, flashes, etc. Documentation should be kept in a designated area and be  ;

mamtained. Insurance information and accident information should be kept within easy reach.

Chemicals in the trucks should be replenished when needed and changed after every 300 pieces of film.

Repairs that are needed should be reported immediately. Repair Request Fonns are kept in the lab office for your use.

Oil should be changed every 3 months. Check the Vehide Service Record on the vehide you use to determme any needed service. Fill out a Repair Request Form and tum in to the supervisor.

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l CODE OF CONDUCT

- The Code of Conduct is to be strictly adhered to at all time by all employees.

1. Insubordination or refusing to follow directions will not be tolerated.

2. Sleeping on the job will not be tolerated.

3. Stealing or hiding property belonging to Code Services, its customers or other employees willnot be tolerated.

4. Divulging Company proprietary or confidential information is strictly forbidden.

5. Deliberate misuse of Company property will not be tolerated.

6. Unauthorized use of or neglect of Company property is unacceptable. t

7. Commission of an unlawful act or conduct, which dtscredits the Company in any way, whether on or off Company property or time will not be tolerated.

8. Failure to call in to the office and report unavailability for work is unacceptable.

9. Failure to call in to the office and report availability for work is unacceptable. .

10. Refusal to accept a job assignment is not acceptable.

11. : Violation of any governmental law, regulation, rule or ordinance that affects the Company or your employment with the Company is unacceptable.

12. ' Fighting with x attempting bodily harm to a fellow employee; fighting with or attempting bodily hun to any other person on Company property or at a job site will not be tolerated.

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13. Code Services will not tolerate the use of abusive language.

14. Failure to report for work is not acceptable.

15. Failure to work safely is not acceptable.

.16.- Performance of substandard work will not be tolerated.

17. Excessive absences or tardiness is not acceptable.

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18.

12aving company premises or a job site without supervisor's approval is not permitted.

19. Stopping work before supervisor's authorization to do so is not permitted.

20. Horseplay or practical jokes are not permitted. l 21, Refusal to wear safety equipment or improper use of safety equipment will not be tolerated.

22. Carelessness in observing quality, safety, and housekeeping requirements is not acceptable.

23. Conducting personal business on Company time or with Company equipment and resources is not permitted.

24. Violation of the Company's Substance Abuse Policy will not be tolerated.

25. Failure to immediately report personal injury and/or incident to supervision is not acceptable.

26. Malicious gossip is unacceptable.

27. Filling out another employee's time sheet or changing another employee's time sheet will not be tolerated.

'28. Failure to submit Company required reports or other documents in a timely manner-is unacceptable.

29.

Unauthorized or. improper use of motel room or restaurant charges and/or Company credit cards will not be tolerated.

30. Overstaying breaks or lunch periods is unacceptable.

31. Giving false information to the Company will not be tolerated. Falsifying or cheating on x-rays will not be tolerated and will result in immediate ternunation of employment.

.32. Unnecessarily talkmg to, or in any other way, distracting the attention of another employee during working hours is not permitted.

33. Failure to promptly respond to business related pages are unacceptable.

34. Use of personal vehicles for Company purposes without management approval is not permitted.

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35. Gambling on Company time or property is not permitted.

36. Posting of any material on Company or Customer property is not permitted.

37. Failure to comply with Company notices is unacceptable.

38. Removing, defacing or changing Company notices or any other Company documents is unacceptable.

39. Possession of a firearm or weapon at a job site or on Company property will not be tolerated.

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40. Any other offense that, in supervision or management's judgment, threaten the well being of Code Services or any of its employees will not be tolerated.

1 VIOLATIONS OF CODE OF CONDUCT Any employee who violates this policy is subject to (1) disciplinary action, (2) report in permanent employee file and (3) discharge from employment.

JOB SITE POLICY '

l 1. When on client's construction site or property, Code employees' will be governed by the terms of the particular contract and by the regulations and/or requirements of the client.

2. Code employees will use the gate designated for contract personnel.

3. Code personnel are confined to the particular area in which they are working.

4. All employees will wear an identifymg badge at all times when on client property.

l 5. Employees are responsible for the care of Code's property and Client property.

l Damage to property belonging to Code or their client is to be reported immediately to your supervisor.

6. Employees are responsible for personal conduct and behavior representative of Code Services. That means no abusive language, no gambling, no horseplay, fights or practical jokes. Drinking liquor or use of r.arcotics on Company time - on Company or -

client property is stnctly forbidden. Possession of narcotics on Company time - on Company or client property is strictly forbidden. Possession and/or use of any type of explosive device or weapon are not allowed on Code property or client property.

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7. Employees may not post notices on client property and may not distribute written material of any type.

8. Employees with beards are not allowed in any chemical areas.

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VIOLATIONS OF POLICY 3

1 An employee who violates this policy is subject to disciplinary action, up to and including dtscharge from employment.

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l I have received, read, understand and agree to the Code ofConduct and Job Site Policy as l statedabove.

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I SECURITY POLICY

1. Counterfeit badges or use of another employee's badge is not permitted and is l grounds for disnussal.

2. ' Termmated employees must surrender their badges (s) to personnel when leaving Code's employment.

3. Code's employees or visitors will be required to identify themselves when entering or leaving client's property by exhibiting his/her authorized badge to the plant guard ,

or security staff. BADGES MUST BE WORN VISIBLY AT ALL TIMES WHILE ON '

CLIENT'S PROPERTY. i

4. If gate passes are required, Code employees are required to comply with all client requirements for vehicle use and safety.

5. In those cases where permits are required to perfonn work on client property, Code employees are responsible for obtauung the proper permits and complying with the client's requirements regarding use of the permit.

VIOLATIONS OF POLICY Any employee who violates this policy is subject to disciplinary action, up to and including discharge from employment.

I have received, read, understand and agree to the Safety Policy as stated above Signa:ure Date 16

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3 INTRODUCTION This policy sets forth guidelines and rules for Code Services employees while on Code Services property or while representing Code at any client facilities.

Code Services shall provide for the safety of its agents and employees and assure compliance with applicable local, state and federal legal requirements. A Code representative is available to assist you with any questions you may have regarding this guide or other company practices.

Code is required to have you (1) attend a company safety and health orientation, (2) conduct weekly safety meetings, (3) inspect your job for safety, and (4) have a safety program to promote improved safety. You are expected to participate fully in these activities and make safety an integral part of your job every day.

GOVERNMENT REQUIREMENTS Code shall comply with all federal regulations as specified under 29 CFR, Chapter XVII, Part 1926 Safety and Health Regulations for Construction and Part 1910, General Industry Safety and Health Regulations identified as Applicable to Construction.

GENERAL SAFETY RULES 1.

Do not do any job you thmk is unsafe. Contact your supervision and others as needed to make your job safe prior to proceeding.

2. Except in office areas, employees are required to wear safety glasses and protective headgear. They are to wear goggles and/or face shields when required.

3.

All operungs (including excavations) where hazards to personnel exist will be adequately barricaded.

4. Construction or contractor personnel must report to his/her foreman any unsafe condition (s) found.

17

5. Each employee is responsible for knowing AREA SAFETY RULES, conditions related to his or her work, and the personal protective equipment required for his/her job and the area.

6.

Defective equipment should not be used. Use the proper equipment in good condition. -

7. Portable electrical equipment must be of the three-wire ground type or protected by an approved system of double insulation.

8. Read all signs and follow the wamings or instructions given.

9. Never place sealed or closed containers of any' kind in dumpsters. Never put liquid chemicals of any kind in dumpsters.

10. Clean up any chemicals you spill immediately. Report such spills to the company representative. Store solvent soaked rags in metal containers with tight lids. Your supervision and/or the company representative on a case will determme disposal by case basis.

11. All electrical lines must be coiled and stored out of aisles when not in use.

12. Do not store material closer than ten feet from railroad tracks and power poles. -

HAZARD COMMUNICATIONS

1. Code Services mamtains an up-to-date Material Safety Data Manual, which is available for each employee to review.

2. For Code Services'sub<ontractor personnel, the assigned Code Services foreman or supervisor is responsible for informing suli-contractor supervision of lazardous chemicals to which their employees may be exposed while performing their duties.

Any recommendations or requirements for protective measures will be provided through review of Material Safety Data Sheets with sub-contractor supervision.

3.

Before any chemical is brought into the plant by Code Services a company l

representative will notify and produce a copy of the MSDS to the client liaison foreman.

4. Client employees expected to be associated with Code Services work will be made aware of the appropriate hazards regarding the chemical (s) being used through the clients'contractorliaison.

1a i

I TESTING OCCASIONS

1. Pre-Employment:

Pnor to hiring / placement of an applicant, as a condition of an offer of employment.

2. Reasonable Cause:

When any employee appears to be unfit for work, based on specific observation of the employee, conditions such as, but not limited to:

appearance, behavior, speech, breath odor, any obviously altered condition or reasonable basis to suspect alcohol or other drug use, possession, abuse or misuse.

3. Post-Accident:

Following an on-the-job injury regturing medical attention or any accident that results in damage to a company vehide or property or client property.

I

4. Random:

Testing of all employees, induding admmistrative personnel, to be performed on a quarterly basis, or as dictated by dient policies.

VIOLATIONS OF POLICY An employee who violates this policy is subject to disciplinary action, up to and induding discharge from employrnent.

I have received, read, understand and agree to the Alcohol and Controlled Substance Policy as stated above.

Signature ~ Date i

EMPLOYEE ACKNOWLEDGEMENT 24

l l-l I HAVE RECEIVED, READ, UNDERSTAND AND AGREE TO THE POLICIES l

~

AND PROCEDURES AS STATED IN THIS HANDBOOK  !

l Signature Date .

l l

copy of this page to befiled in employeefile EMPLOYEE HANDBOOK 25

. ...............~..-e.m db .

AJT & Associates, Inc.

Building 4249, Room 116 ,

Marshall Space Flight Center Huntsville, Alabama 35812 Fax Cover Sheet DATE: 2/9/99 l

TO: CHRIS CHANDLER PHONE:

FAX: 340-1134 FROM: JIM SULT- MSFC RSO PHONE:

(256) 544-5738 FAX: (256)544 5746 Number of pages including cover sheet: 2 -

MESSAGE: I I

1 l

l l

......... .. . . .. . r,u t

Sult, James _

To:

Cc: Thaxton. David: Eagan, Joyce; Harvey, David; Ramsey, Brian: Crowe, Lesley; Holt, Dona Phillips. Eddie: Pinkston, Scott Smitn. Greg;

Subject:

- Radiograpny Contractor Prooiems Code Services, of Greenbriar Alabama, occasionally performs source radiography of various compo,nents at this site in support of EG&G, LB&B, and ,

other contractors. This organization has a history of violating MSFC procedures when problems performing with state work at this rite. In addition, this company has recently had regulators.

Several attempts have been made to reconcile these problems. Most recently, Greg Smith and myself made a trip to their office and discussed the problem '

areas with company president, Reggie Lambert. Unfortunately, this has not solved the problems. '

There will be a meeting on Thursday, February 18, at 9:00 AM in building 4249, room 116, to discuss this issue. Reggie Lambert and Chris Chandler from Code Services will be here. Please make plans to attend if possible.

Jim Sult, RRPT AT010M/AJT MSFC Radiation Safety Officer -

544-5738 Page 1

- To m. Paae.e2 =

1 Code Services Problem History Perpetual problems in the areas of posting during radiography On-site personnel have been cautioned repeatedly.

There seems to be confusion among staffconceming requirements. .

ce posting Perpetual problems with failure c noufy MSFCy RSO prior to On-site personnel have been cautioned several times. .

Office has been called several times.

k i

Code Services office to discuss posting and ! .

prior noti 5 cation ofMSFC RSO. Chris out Ch{ i contacted, and knew nothing about the prior noti 5 cation requirement Failure to locate emergency procedures j to locate emergency procedures. __On 1 of 2 inspections sFailure to utilize required equipment MSFC RSO observed radiographer's assistant enter radiogra approach the exposed source without an alarnung ratemeter. Individ

that this piece of equipment required by 10 CFR 34.47 e was in the radiographer in charge declined to address the problem immediat disregard for ALARA practices. requested by the MSFC RSO

,j Code Services violation. has been recently cited by the State of Alabam Regulatory History these areas were repeat danciencies.Last State of Alabam Previous State of Alabama inspection showed 9 areas of noncomplia Code Services, due to its poor history of regulatory compliance, accelerated inspection schedule by it's licensor, the State of Alabama

1 m .wouwm P.e2

.m II. Summary of Compliance.

NONCOMPLIANCE  !

1.

RULE / CONDITION SEVERITY CLASS Inadequate shipping papers THIS IS A REPEAT DEFICIENCY.420-3 IV -26Transportation

.02(24) 2.

Inadequate labeling of devices THIS IS A REPEAT DEFICIENCY.420-3-26 .04(23)(b) IV - Operations

3. Inadequate utilization logs 4 IV - Operations Failure to maimmin receipt / transfer 420-3-26 .04(10) records 420 3-26 .01(4) IV - Operations

5. ~

No records ofincoming package surveys / source change surveys 420-3-26 .03(32) IV - Operations 6.

7. Failure to block & brace devices Overdue leak test 420-3-26 .02(24) IV - Transportation License Cond.17A IV - Operations III. Correction of Deficiencies Noted on the Previous Inspection.

ITEM CORRECTED?

1. s'.

2. Unauthorized users of radioactive material l'Yeh Failure to properly use alarm rate meters 3.

Improper use of radiographic exposure device / Yes ~

4 '

Inadequate internal inspec: ion program l' Yes '

5. Yes

6. Failure to leak test sealed sources prior to shipment Yes 7 Failure to properly label radiographic exposure device  ;

Incomplete area sutvey records NO

8. Yes

9. Improper transport of an Amersham 660 exposure device Yes

' Failure to use SI units on shipping papers & transport NOlabels IV. Scope of Licensee Operadon .-

1.

use. The licensee possesses 3 AEA 660B came 7 radiographers and one assistant radiographer and onee person per. The classified as licensee' accomplishes approximately 60 jobs per month with" most bein st. I, b W

. g g

. 8 pg3 17 '99 14:25 4 .

m 20 W N.82 L

OC.e m,,,u,,

CIVICes WMMlWORNM To: Chris Chandler, RSO Code Services, LLC 4454 Re:-NReinspection of 2-16-99 -

Chris, Mr. Bult, at the end of his inspection of our operation asked Mr.Mout his alarming dosimeter. MrMen showed Mr. Bult his pocket dosimeter thinking that was what he was inquiring about.~ After showing Mr. Bult his pocket dosimeter M'ent into the darkroom to load film holders. At that time, Mr.M, the lead Mr.

technician on thejob). was asked about his alarming dosimeter. Mr. hen showed Mr. Bult his alarming rate meter. Mr. Bult told Mr. at r.

was not wearing his rate meter. Mr.gid Mr Bult that he would talk to Mout this when he terurmed from the darkroom. At this time, Mr Bult left.

When Mr Mr.

etumed from darkroom, Mr. Mked him about his rate afarm.

Mr.

howed Mr. gis rate alarm which he had in front pocket. He told ,'

that he thougnt mat ivir. Bult was asking about his pocket dosimeter. Mr..

~ '

$~also stated that Mr. Bult did not identify himself and that he (Mr.Mhad.

alarming rate meter in front pocket from,the start of the work shift. Mr.gls stated that he had witnessed Mr. M putting on his pocket dosimeter, nlm eacge, and rate alarm before beginning radiograpliic operations.

,DAr;c: N7-97 26412 Old Highway 20, Madison, Alabarna 35678 Phone (256) 340-1117 Fax (256) 340-1134 ,

1 l

.- . 1' ode e,, , a,,,

ervices wre. rcs a . ;E February 22,1999 A J T & Associates Inc.

Marshall Space Flight Center Huntsville AL 35812 ATTN: Mr. Jim Bult l e-mail: James.bult@msfc. nasa. gov I Re: Problems while working on NASA site Dear Mr. Bult.

Enclosed I have addressed the problems discussed at the meeting held'at your fac 2/18/99. Each problem has been noted with recovery plan and the implementation date.

We at Code Services share your concem about safety and procedure and are committed the implementation of our program. After our meeting there we held an aftemoon meeting. In this meeting all personnel viewed the video from the NRC. Additionally w made personnel aware of the problems noted. Discussions were held and policy was made clear. There should be no question from our personnel as to Code's commitment to safety and implementation of all its procedures.

With regard to our regulatory history, vast improvement has been accomplished du the tirst three months of the new ownership. We fully intend to continue enhancement of our program while assuring compliance.

I hope this recovery plan meets with your approval and will follow up by phone after have had time for review. Should you have questions or comments, pieuse contact me at your convenience.

Best regards.-

Code Services Reggie Lambert Managing Partner s

26412 Old Highway 20, Madison, Alabama 3M78 Phone (256) 340-1117 Fax (256) 340-1134

Code Services Recovery plan of sited problems at NASA Problem: Posting during radiography Recoverv:

1) Additional training of radiographers to address posting and surveillance.

" 2) Frequent unannounced site audits to assure compliance and identify deficiencies.

Imniementation: 2/18/99 Complete.

i 1 Problem: Failure to notify MSFC RSO of on site radiography.

Recoverv: 1) Send FAX notification of planned radiography.-

2) Radiographers shall check in at bidgA9& Notify RSO or other safety personnel. Wyf Imniementation: Upon each trip to NASA site for radiographic testing.

Problem:

Radiographer was unable to locate emergency procedures quickly.

l Recoverv:

1) Procedures are located in all vehicles used for radiography.

j. 2) Further training and better tabulation will result due to this observation.

Imolementation: 7J28/99 Problem:

Assistant radiographer did not appear to be wearing required personal monitoring equipment.

l Recoverv:

1) Weekly safety meetings shall be held to address radiation safety and compliance. Operational safety shall be addressed at these same meetings.

2) Any personnel found not wearing required personal monitoring equipment

- while performing radiography or being in a controlled area, shall be immediately terminated.

3) Any violations or observations noted by MSFC personnel and mentioned to radiographers shall be immediately reported to the Code Services RSO.

4) Frequent unannounced site audits Shall be performed to assure procedure and safety compliance.

, Imniementation: 2/18/99 e

• ~ . _

1 Code Services 26412 Old Highway 20

' Madison, AL 35758 I I

SAFETY MEETING 1

DATE: ,

y g g,99 CONDUCTED BY: 1 REGGIE LAMBERT & CHRIS CHANDLER SUBJECT TO BE COVERED COMPLETED 1.

NASA ON SITE RADIATION VIOLATIONS

2. VIDEO ON NRC REGULATIONS YES 00 t . .

/

YES fi/' SO O

3. ATTITUDE AND PROFESIONALISM OF TECHS.

/

4. YES WNO R YES O NOO I understand the material covered in this safety meeting and will incorporate this knowledge into my job performance.

nre; />>// h Employee Signatu re

!- 1

. 1 Code Services 26412 Old Highway 20 Madison, AL 35758 I SAFETY MEETING DATE:

2/13/99 CONDUC tt.D BY: -

l REGGIE LAMBERT & CHRIS CHANDLER l SUBACT TO BE COVERED COMPLETED

1. I i

NASA ON SITE RADIATION VIOLATIONS

2. VIDEO ON NRC REGULATIONS YES. NO C

/

YES O NO O

3. ATTITUDE AND PROFESIONALISM OF TECHS.

l

4. YES NO O

/

YES @ NO O I understand the material covered (n this safety meeting and will incorporate this

a

/ / knowledge into myjob pt.-formance.

ilnar A Employee Signature

Code Services i 26412 Old Highway 20 l Madison, AL 35758 SAFETY MEETING DATE:

2h 3/99 CONDUCTED BY: --

REGGIE LAMBERT & CHRIS CHANDLER SUBJECT TO BE COVERED '

COMPLETED 1.

NASA ON SITE RADIATION VIOLATIONS YES O

2. VIDEO ON .YRC REGULATIONS YES[ O -

3. ATTITUDE AND PROFESIONALISM OF TECHS.

4. YES PM' YES 0f"I I understand the materts! covered injhtsj su ' v meeting and will incorporate this

/ ,4n ge into myjob 4 -

/ A E m.,,,e.s,performance.

_e

i

-; i 1

Code Services i 26412 Old Highway 20 ,

Madison, AL 35758  !

SAFETY MEETING DATE:  !

2/t 3/99 CONDUCTED BY: -

REGGIE LAMBERT & CHRIS CHANDLER SUBJECT TO BE COVERED {

COMPLETED '

1.

1 NASA ON SITE RADIATION VIOLATIONS l

d

2. VIDEO ON NRC REGULATIONS YES @ NO O  ;

. i i

~

i

- . l I

3. ATTITUDE AND PROFESIONALISM OF TECHS.

1 l

l

s. YES @ NO O  ;

i i

YES O NOC I understand the material covered in this safety meeting and will incorporate this nowledge into my job performance.

t M N Employee Signature i

V J  !

\

i

i H

l Code Services 26412 Old Highway 20

' Madison, AL 35758

{

SAFETY NEETING l

DATE: a.

2/t 3/99 CONDUC12.D BY: --

REGGIE LAMBERT & CHRIS CHANDLER SUB.TECT TO BE COVERED COMPLETED 1.

NASA ON SITE RADIATION VIOLATIONS i

1 i .

2. VIDEO ON NRC REGULATIONS YES E d o O YES C4 0 0

3. ATTITUDE AND PROFESIONALISM OF TECHS.

4.

• YES Ef50 O YES IMO I understand the material covered in this safety meeting and will incorporate this knowled into myjob performance.

No I _/ S. ~~ Employee Signature

1 1

I Code Services 26412 Old Highway 20 Madison, AL 35758 l

1 SAFETY MEETING  !

l DATE:

2/13/99 CONDUC it.D BY: .

1 REOGIE LAM _BERT & CHRIS CHANDLER e SUBJECT T.O BE COVERED COMPLETED I 1.

NASA ON SITE RADIATION VIOLATIONS l

/

2. VIDEO ON NRC REGULATIONS YES E n -

I l

YES I O

3. ATTITUDE AND PROFESIONALISM OF TECHS. ~

i

/

4. YES I O YES O NOO I understand the matertal covered in this sar'ery meeting and will incorpora '

knowledge into myjob performance. '

i v

/ '

/ _m _ Employee Signacure

r~

Code Services 26412 Old Highway 20

'Madis'on, AL 35758 SAFETY MEETING DATE: 4 2/13/99 CONDUC aD BY: -

REGGIE LAMBERT & CHRIS CHANDI.ER SUBJECT TO BE COVERED COMPLETED 1.

NASA ON SITE RADIATION VIOLATIONS

2. VIDEO ON NRC REGULATIONS YES @ NO O YES @ NO O

3. ATTITUDE AND PROFESIONALISM OF TECHS.

l

4. YES @ NO O YES O NOO I understand the material covered

" in this safety meeting and will incorporate this nowledge into myjob performance.

A- [ / Employee Signature

t .

Code Services '

l 26412 Old Highway 20 Madison, AL 35758 SAFETY MEETING DATE:

i 2/18/99 CONDUCTED BY:

REGGIE LAMBERT & CHRIS CHANDLER SUBJECT TO BE COVERED COMPLETED l 1.

! I NASA ON SITE RADIATION VIOLATIONS '

l l

l

2. VIDEO ON NRC REGULATIONS YES @ NO O YES @ NO O

3. ATTITUDE AND PROFESIONALISM OF TECHS.

4. 1 Yr.S Fl.NO O YES G NOC I understand the material covered in this safety meeting and will incorporate this knowledge into my job performance.

Employee Signature

E .

t Code Services Recovery plan of sited problems at NASA Problem; Posting during radiography Recoverv:

' 2) Frequent deficiencies.

unannounced site audits to assure co .

Imolementation: 2/18/99 Complete. ,

Problem:

Failure to notiF

/ MSFC RSO of on site radiography.

Recoverv:

1) Send FAX notification of planned radiography.

2)personnel.

Radiographers shall check in at bldg.M Notify RSO or othe

@ff Imolementation; Upon each trip to NASA site for radiographic testing.

Problem:

Radiographer was unable to locate emergency procedures quickly Recoverv:

1) Procedures are located in all vehicles used for radiography.

2) Further training and better tabulation will result due to this obser Imolementation: 2/28/99 Problem: Assistant radiographer did not appear to be wearing required monitoring equipment.

Recovengcompliance.

1) Week!y safety meetings sM" '- '" :: ddr:ss rdiation safety

• meetings.

Operational safety shall be addressed at these same

2) Any personnel found not wearing required personal monitorin while performing terminated.radiography or being in a controlled area, shall be immediately

3) Any violations or observations noted by MSFC personnel and ment to radiographers shall be immediately reported to the Code Services PSO

4) and Frequent unannounced site audits Shall be performed to assure p safety compliance.

(

• Imolementation: 2/18/99 i

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.- U I DATE: .h. N [ h SUBJECTS COVERED:

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.4 STATE OF TENNESSEE DEPARTMENT OF ENVIRONMENT AND CONSERVATION Division of Radiological Health 3rd Floor, L&C Annex 401 Church Street Nashville, TN 37243-1532 March 29,1999 RadiolooicalInformation e Notice Addressees: All Radiography Licensees

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Subject:

Unplanned Radiation Exposures to Radiographers, Resulting from Failures to l Follow Proper Radiation Safety Procedures On March 1,1999, the IJnited States Nuclear Regulatory Commission (NRC) issued an information notice (attached) reminding radiographers of the risk of unplanned high radiation exposures from radiography equipment, and the need for proper radiation safety practices to prevent such exposu notice was prompted by a se:ies ofincidents that have occurred recently and that resulted in unp exposures; all of which involved failures to follow proper radiation safety procedures.

If you are an industrial radiographer and you do not use you survey meter and alarming dosimeter, you may suffer severe injury or you may die!

It is expected that recipients will review this information for applicability to their facilities and consider actions, as appropriate, to avoid similar problems. If you have further questions conceming this correspondence, please contact the individual named below:

Charles Arnott .

Licensing Manager of Radioactive Materials (615)532-0364

7 UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEG{

WASHINGTON, D.C. 20555-0001 March 1,1999 1

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NRC INFORMATION NOTICE 99-04:

UNPLANNED RADIATION EXPOSURES TO -

RADIOGRAPHERS, RESULTING FROM FAILURES TO FOLLOW PROPER RADIATION SAFET(PROCEDURES

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Addressees: .

All radiography licensees.

Purcose:

The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notic addressees of the risk of unplanned high radiation exposures from radiograph ,

the need for, proper radiation safety practices to prevent such exposures. The notice ! '

prompted by a series ofincidents that have occurred recently and that resulted in un exposures, all of which involved failures to follow proper radiation safety procedures. Thes incidents did not result in radiation exposures that are expected to lead to serio to the exposed individuals. However, there was the that could have led to serious health consequences. potential, in all cases, for high exposures It is expected that recipients will review the information for applicability to their facilities and consider actions, as appropriate, to; similar problems. However, suggestions contained in this information notice are not N requirements; therefore, no specific action nor written response is required.

Descriotion of Circumstances:

1.

Pipe welds were being radiographed at a temporary job site in Indiana on Au (TBq)(105 curies (Cl)] iridium-192 (ir.192) source an controlled area had been set up around the work site to keep unauthorized peopl the area. A radiographer inadvertently walked into the controlled area during one shots, when the source was out ofits shield. He was wearing a film badge, but no alarming ratemeter, and did not carry a survey meter with him. The dose he received from that incident was estimated to be 3.5 milI! sievert (mSv) whole body and 70 mSv (7 rem) to the right hand.

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IN 99-04 March 1,1999 Page 2 of 4 2.

A radiograprer and a radiographer s assistant were making radiographs on diameter pipe at a temporary job site in Oklahoma on November 7,1998. Th using a Spec camera with an 3.2 TBq (87 Ci) Ir-192 source. The camera was inside the pipe during this work to obtain panoramic views of some welds. At t one of the shots, the radiographer s assistant crawled into the pipe to reposition th equipment and prepare for the next shot. When it was time for the shot, the assi .

crawled back into the pipe to deactivate the automatic locking mechanism, but discovered that the source was not in the locked position. She alerted the rad who was able to retract the source to the locked position with about two tums of the .

drive cable crank. A review of the incident showed that the assista survey before approaching the source in the pipe, nor was she wearing an alarmin t

ratemeter.

the whole body. She was estimated to have received a dose of about 1 3.

Two radiographers were using an Amersham-6608 camera with a 2.7 TBq (72 C source at a temporary job site at a refinery in Montana on November 20,1998. They had just finished one shot and were preparing for a second. They then noticed that th source was not in the locked position. One of the radiographers was able to put the source back in the locked position with a half turn of the drive cable handle. A check of the self-reading dosimeters on the two radiographers showed that they were both off-scale, it was later estimated that they were exposed to the unshielded source for about 6 minutes. Film badge results showed a whole-body dose of 40 mSv (4 rem) to one of -

the radiographers and 120 mSv (12 rem) to the other. Although both radiographers had their alarming ratemeters on them, one of the meters did not alarm, and the otherwas turned off. Surveys had not been done after the first shot to confirm that the source was in the shielded position.

4.

A radiographer and a radiography trainee were conducting radiography operations at a temporaryjob site in Texas on December 31,1998. The radiographer, who had been with the company for only two weeks, had not met his partner before that day, and did not know that he was a trainee, but had assumed that he was a qualified radiographer.

The trainee had assumed that the radiographer knew he was a trainee, and had not said anything about his position with the company. As a result the radiographer had asked the trainee to do most of the shots that day, using a camera with a 4.6 TBq (123 Ci) -

ir-192 sourca, and he had himself spent most of the time in the dark room. At the end of the day, the trainee thought they had finished shooting, and had removed his belt and put it in his truck. The belt has his Tl.D and alarming dosimeter on it, but his pocket ionization chamber was in his trousers p ocket. Before he could leave, however, the radiographer told him that they had to reshoot a 5 cm (2") and a 7.6 cm (3") pipe. They both set up for the 5 cm (2") pipe shot and the radiographer then went to the dark room and left the trainee to complete the shot. After shooting the 5 cm (2") pipe, the trainee set up for the 7.6 cm (3") pipe shot. When he went to the camera to extend the source for the shot, he found that he had forgotten to retract it into the camera after the previous shot. He immediately retracted the source and repnrted the incident to the radiographer. I investigation of the incident showed that, although the trainee had a survey meter with I him at the time of the shots, he had not used it. The investigation also concluded that the trainee received a whole body dose of about 100 mSv (10 rem), and a dose to the I index finger of about 30 - 50 Sv (3,000 - 5,000 rem). The dose to the 1

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IN 99-04 March 1,1999 Page 3 of 4 Index finger was high because the shots were being made without a collimato significant shielding. Ten days after the incident, sig

- appear on his index finger.

Discussion: ~

An obvious fact about which radiographers should be repeatedly reminded is that, wit suitable instrument such as a survey meter or an alarming rate meter, both of which are required equipment for radiography work, there is no way for them to be sure that the a radiography camera is not out of its shield when it should have been shielded. A maybe not as obvious, that radiographers should be reminded of is that, with a typical radiography source such as 3.7 TBq (100 Ci) of Ir-192, the dose rate at 30.5 cm (1 f the unshielded source is about 4.5 Sv/hr (450 rem /hr). Exposure at a foot from such a s will result in exceeding NRC s annual whole body-dose limit in about 40 seconds. A dos the whole body of about 2.5 Sv (250 rem) would have a 50 percent chance of being fa could be delivered by a 3.7 TBq (100 Cl) Iridium source a foot away in about half an ho an exposure scenario is unlikely, but it is possible, as for example in a situation where extended preparation work is being done close to a camera with an unshielded source. Another typ severe injury that can result from exposure to such a source is that resulting from localized exposures, such as to the hands. Fcr example, handling the guide tube with the source in it could result in dose rates, to the hand, on the order of to gray (Gy) (1,000 rads] per minute.

Such dose rates could quickly lead to very serious injury to the skin and underlying tissue To avoid serious radiation injury, it is necessary to ensure that people are never close to an unshielded radiography source. Radiography cameras are designed to keep the sources lock in their shields when not in use, but the mechanisms used to accomplish this occasiona either because of mechanical problems or because of improper use. The source may als been cranked out by one person, without knowledge of another person who may later walk in the work area, in all these cases, there is usually no obvious indication that the source is unshielded. Without the proper instruments, a person would not know that a high radiation fiel exists in the area, and for this reason good radiation safety practices, as well as NRC s regulations, require the use of radiation detection instruments to ensure that the source is asecurely in the radiography snieiced work area. position after use, or that it is safe to approach a radiography camer The instruments needed for that purpose are ones that give a quick indication that a high radiation field exists. Dosimeters issued to radiographers, such as thermoluminescence dosimeters (TI D), film badges, and pocket dosimeters, do not serve this purpose. TLD and film must be sent away for processing before they can indicate a dose. Pocket dosimeters, altho they can be read out in the field, are not suitable because they do not give a sufficiently quick indication of a high radiation field, and also because they are meant to be checked only occasionally during work. The only practical options available to the radiographer in the field are survey instruments and alarming rate meters. A radiation survey instrument is carried by the worker and has a meter that shows the dose rate all the time it is in use. It is th of choice when making sure it is safe to enter an area and to verify that the source is in the shield. At times, however, it may be necessary to set the survey instrument aside to prepare for the next shot, or reposition equipment or barriers. Even though the camera may not L

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w IN 99-04 March 1,1999 Page 4 of 4 {

I for possible high radiation fields without the need to co instrument for this purpose is the alarming ratemeter, usually wom on the wo .

does not require the worker to look at a meter, because it is equipped with off when the radiation field exceeds a preset level. This alerts the worker to a Survey instruments and alarming ratemeters can fail to work for a variety of reaso of this, and because of the serious dangers involved in us also act as backups to each other. Note also that, b they must be checked regularly in the field to make sure they are still working prope sutvey instrument is checked by making sure the batteries have sufficient remaini and also by holding the instrument next to a check source and making sure it read dose rate it should read in that position. The user must also be sure the instrument is proper scale. Alarming rate meters are checked by ensuring that the batteries are in go) i condition, the alarm is set at the proper alarm set point, and the alarm actually sounds meter i.s placed in a sufficiently high test radiation field. I k

In addition to using ratemeters and alarming dosimeters, radiographers should be rem follow examples:proper safety procedures when using radiography equipment. These include, as procedures for propedy posting and roping off work area; contro!!ing access to the radiography area during radiography; properiy ensuring that the source is actually locked w it is retracted into the camera; periodically checking the camera to make sure that there is apparent damage, and that moving parts do not show undue wear; and similar actions that ensure that the equipment is in good mechanical condition and that it is operated property This information notice does not require any specific action nor written response. If you any questions about the information in this information notice, please get in touch with the technical contact listed below, or the appropriate regional office.

Donald A. Cool, Director Division of industrial and Medical Nuclear Safety Office of Nuclear Material Safety and Safeguards Technical

Contact:

Bruce Carrico, NMSS 301-415-7826 E-mail:ibc@nrc.cov V -

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l Audits for 1st Ouarter 1999 1

Radiographer Date of Audit l

Audit Location Auditor Results Greg Schuller 2-02-99 Code Shop J. D. Chandler Acceptable Carl Allen 2 04-99 Code Shop J. D. Chandler Acceptable Mike Chandler 2-15-99 Code Shop J. D. Chandler Acceptable Sam Brewer 2-15 99 Code Shop J. D. Chandler Acceptable Barry L. Craig 2-17-99 Code Shop J. D. Chandler Acceptable Billy Bonner 3 02-99 Code Shop J. D. Chandler Acceptable ,

Mike Chandler 3-16-99 Redstone Arsenal Chris Chandler Acceptable Sam Brewer 3-16-99 Redstone Arsenal Chris Chandler Acceptable Bill Franklin 3-18-99 Monsanto (Solutia) Chris Chandler Acceptable Greg Schuller 3-27 99 Redstone Arsenal Chris Chandler Acceptable James Chandler 3-30-99 Redstone Arsenal Chris Chandler Acceptable 26412 Old Highway 20, Madison, Alabama 35678 Phone (256) 340-1117 Fax (256) 3401134 L.

PREDECISIONAL ENFORCEMENT CONFERENCE AGENDA CODE SERVICES, INC.

APRIL 22,1999, AT 1:00 NRC REGION 11 OFFICE, ATLANTA, GEORGIA

1. OPENING REMARKS AND INTRODUCTIONS L. Reyes, Regional Administrator

11. NRC ENFORCEMENT POLICY A. Boland, Director Enforcement and Investigation Coordination Staff Ill.

SUMMARY

OF THE ISSUES L. Reyes, Regional Administrator

! IV. STATEMENT OF APPARENT VIOLATION / CONCERNS D. Collins Director Division of Nuclear Materials Safety V. LICENSEE PRESENTATION Mr. Reggie Lambert, Managing Partner Code Services, Inc.

VI. BREAK / NRC CAUCUS Vll. NRC FOLLOWUP QUESTIONS Vill. CLOSING REMARKS l

L. Reyes, Regional Administrator Enclosure 4 i

I

O' Aooarent Violation 10 CFR 150.20 provides in part that any person who holds a specific license from an Agreement State is granted an NRC general license to conduct the same activity in areas of exclusive Federal jurisdiction within Agreement States, provided an NRC Form-241 is properly filed.

The general license is subject to all provisions of the Act and to all applicable rules, regulations and orders of the Commission including subpart C of part 34.

10 CFR 34.47 (included in Subpart C of part 34) requires 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.

1 i

On February 16,1999, during radiographic operations, the 1

radiographer's assistant failed to wear an alarm ratemeter.

i The apparent violation discussed in this predecisional enforcement conference is subject to further review and is subject to change prior to any resulting enforcement action.

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P. l 27--1999 1 1 :51 tM FRO 4 SERVICES. INC. 225340113d

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OdC mn m monw m MADISON, AL 35756 cant.inj PHONE: 256 340-1117 CDQCC$ FAX: 2.% 340-1134  ;

F From: Reggie Lambert

.g... Mark Lesser l

, Pages: (4) includes Cover Sheet Fasc: (404)562-4900 Date: April 27,1999 Phonc: 600-577.C510 Re: Info discussed in mig f ast wcck CC:

O Please Reply O Please Recycle O urgent X for Review O P(case Comment

• Comments .

Dear Mr. Lesser,

Fo!!owing please find the statements fro nd f that we discussed on Thursday of last week. Also, find the Work Order from the day on which the violation occurred, to be entered as objective evidence. Additionally, the individual in question }has been dismissed as a part of our corrective action.

Sincerely, ,,

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. < /77 Reggie Lambert 9

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To: Mr. Reggie Lambert Code Se: vices -

l Mr. Lambert, "J '

In reference to the Held audit by the NRC on March 17,1999, the NRC of5cial was '

asking me various questions about safety procedures, work habits, etc. At this time, he asked me if we had ever had any problems and I retilied that we had not had any, other than the one where the radiographer's assistant was audited and he.wasn't wearing hi rate alarm. I ivas refer:ing to a prior incident which had already been discussed.

Best regards, g i l

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2412 Old Illghway 20, Madison Alsbama 35678 Phone p.56)340-1U7 Fax (256) 3401134 s

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Mr. Reggie Lambert -

Code Services , 1

.. Re: NRC Reciprocity Field Audit ofMarch 17,.1999 Mr. Lambert, '

In ref .

e to the NRC reciprocity field audit on March 17, 1999, the NRC inspector ask if we had had any proble=s'on Redstons A:senal before. 'Mr.

{Mthinking at the inspector was refening to Code Services in general, answered that yes, we had an_ assistant who got caught without wearing his rate alarm. {

! l Best regards, D)

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26412 Old HJghwsy 20, Madison, Alahama 35678 Phone (1s6) 34o.1117 Fax (256) 340113.1

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