ML20207M744

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp of License 50-23257-01

ML20207M744
Person / Time
Site:	03020423
Issue date:	10/12/1988
From:	Jonathan Montgomery NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Russell L INSPECTION SERVICES & TESTING, INC. (FORMERLY INSPECT
References
NUDOCS 8810180353
Download: ML20207M744 (1)

See also: IR 05000232/1957001

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OCT 121999

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License No. 50-23257-01

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Inspection Services and Engineering

611 30th Avenue

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P. O. Box 61179

Fairbanks, Alaska 99706

Attention:

Larry Russell.

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Vice President

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Gentlemen:

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Thank you for your letter'of August'25,'1988, iri response to our Notice of

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Violation dated August 12,1988, 'itifouning us of the steps you have taken to

correct the items which we brought to your attention.

The Notice of Violation

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and other inspection findings were also discussed by R. Thomas, Region V with

you during a Management Conference on September 15, 1988.

Your corrective

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actions will be verified during a future inspection.

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Your cooperation with us is appreciated.

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Sincerely,

On9 ncJ Ss wd

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James L. Montgomery, Chief

Nuclear Matertals Safety and

Safeguards Branch

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State of Alaska

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August 25, 1988

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U.S. Nuclear Regulatory Commission

ATTN: Document Control Desk

Washington, D.C. 20555

Subject:

Reply to a Notice of Violation

License No. 50-23257-01

Document No. 030.20423

Gentlemen:

In response to the Notice of Violation: dated August 12, 1988,

inspection Services submits the following statements and explanations:

A.

10CFR 34.43(b) requires tnat the entire circumference of the

radiographic exposure device be surveyed with a calibrated and

operable radiation survey instrument after each exposure to deter-

mine that the sealed source has been returned to its shielded

position.

Contrary to the above requirement, a licensee radiographer did

not survey around the entire circumference of the Gamma Century

SA exposure device (serial number 2834) following the return of

a 48 curie iridium-192 sealed source to its shielded position in

the exposure device during field radiography nn July 29, 1988 at

Eielson Air Force Base, Alaska.

Statement:

The radiographer did perform a survey of the source tube

and the front of the exposure device to ascertain that the source

had been retracted to the same position.

Radiation readings did

confirm this.

_Gorrective Steps:

Radiographic personnel have been instructed to

survey the length of the source tube and the total circumference

of the exposure device after each exposure is completed as stated

in 10CFR 34.43(b) and IS&E Radiation Safety Manual, Section 5.,

Page

9, Para. 3(N).

This matter was discussed in detail at a safety meet-

ing held on August 3, 1988.

Full Compliance Achieved:

Immediately - August 3, 1988

8.

License Condition 14 states that the licensee may transport

licensed material in accordance with the provisions of 10CFR 4

Part 71, "Packaging and Transportation of Radioactive Material".

10 CFR 71.5(a) states that each licensee who transports licensed

material outside the confines of its plant or other place of use,

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U.S. Nuclear Regulatory Commission

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(Page 2)

or who delivers licensed material to a carrier for transport,

shall comply with the applicable requirements of the regulations

of the Department of Transportation in 49 CFR Parts 170 through

189 appropriate to the mode of transport.

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1.

49 CFR 177.842(d) states that packages containing radioactive

materia 1 must be so blocked and braced that they cannot change

positions during conditions normally incident to transportation.

Also, item 5, Section 5 of the Radiation Safety Manual, included

by reference in License Condition 15, requires that exposure

devices transported to field locations be securely positioned

in a lockable steel ' source box' which is bolted to the vehicle.

Contrary to the above requirements, on July 29, 1938 at Eielson

Air Force Base, Alaska, the licensee transported a radiographic

exposure device (SPEC 2-T serial number 318 containing a 48

curie iridium-192 sealed source) outside of the vehicle ' source

box', and without any blocking or oracing of the exposure de-

vice.

2.

49 CFR 173.475(1) states that before each shipment of any

radioactive materials package, the shipper shall ensure by

examination or appropriate tests, that external radiation

levels are within the allowable limits specified in this sub-

chapter.

Contrary to the above requirement, on July 29, 1988, the

radiation levels at the surface and at one meter from packages

containing licensed material were not measured prior to ship-

ment of the packages by private carrier betwaen Fairbanks and

Eielson air Force Base, Alaska.

Statement di:

Radiographic personnel did transport the exposure device

secured in the steel lead lined ' source box' from the IS&E Fairbanks

facility to the job site (Eielson Air Force Base).

After making the

exposures at one location, the device was placed in the self con-

tained darkroom mounted on a pickup truck and transported from one

manhole to the next location (approximately one mile) without ' lace-

ment in the ' source box'.

Corrective Steps:

All radiographic personnel employed at IS&E are

aware of the requirements pertaining to proper placement and locking

procedure, this violation was caused by neglect on the radiographer's

part and definitely not acceptable practice.

The radiographer was informed that another violation on his part

would result in termination of employment with IS&E.

Full ComDliance Achieved:

Imediately - August 3,1988

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(Page 3)

Statement #2:

The requirements for examination of radiation levels

was discussed with the radiographic personnel the day following this

audit. He did state that he had surveyed the exterior surface of

the darkroom prfor to leaving the IS&E Fairbanks facility and that

radiation levels were well below 2mr.

He.did not document the

survey.

Corrective Steps: Survey requirements were discussed in great detail

at the safety meeting held on August 3,1988.

Audits will be increased by the Radiation Safety Officer and Radiation

Safety Supervisors to assure full compliance.

Full Compliance Achieved:

Immediately - August 3, 1988

3.

49 CFR 172.403 requires appropriate "Radioactive" category labels

that identify the activity and radioactive contents of packages

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containing radioactive material.

Determination of the p aper

label is based on the radiation dose rates at the surface and

at one meter (transport index) from the package.

Contrary to the above requirement, on July 29, 1988, radiographic

exposure devices containing licensed material were transported

by private carrier between Fairbanks and Eielson Air Force Base,

Alaska, without any "Radioactive" category labels.

Statement: All IS&E vehicles have placards displaying "Radioactive"

but have not utilized category labels.

Corrective Ste,p_s:

All vehicles now have "Radioactive" category

Tabels affixed to the source storage box.

these are completed

prior to movement of the radioactive material.

This was discussed

during the safety meeting held August 3, 1988.

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Full Compliance Achieved:

Immediately - August 3, 1988

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49 CFR 172.200(a) requires that each person who offers a hazard-

ous material for transportation shall describe the hazardous

material on a shipping paper in a manner prescribed by Subpart

C of 49 CFR Part 172.

49 CFR 172.101 classifias radioactive

material as a hazardous material for the purpose of transportation.

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Contrary to the above requirement, on July 29, 1988, radiographic

exposure devices containing licensed material were transported

by private carrier between Fairbanks, Alaska and Eielson Air

Force Pase, Alaska, without any shipping papers describing the

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hazardous material.

Statement: No shipping papers were completed during this radio-

graphic operation located at Eielson Air Force Base (approximately

25 miles from the IS&E facility).

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(Page 4)

Corrective Step:

Shipping papers are now affixed to clip boards in

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the venicles and completed prior to movement of radioactive materials.

This was discussed at the safety meeting held on August 3, 1988.

Full Compliance Achieved:

Immediately - Sugust 3, 1988

C.

10CFR 34.31(c) requires the lican';ee to maintain, for three years,

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records of training of radiographers and assistant.radiographers,

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including copies of written tests and dates of oral tests and

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field examinations.

Contrary to the above requirement, at the time of inspection, the

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licensee had not maintained records of the written examination

of a radiographer on December 11, 1986, nor of a field examin-

ation of another radiographer on April 28, 1988.

Also, records

were not maintained of the licensee's training nor field'examin-

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ations of two assistant radiographers during approximately June,

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1988.

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Statement:

Examinations were completed on all personnel as required

by 10 CFR 34.31(c) and IS&E safety manuals.

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Records could not be located for the December 11, 1986 and April 28,

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1988 exams.

Records had not been completed on the training and

field examinations of the two assistant radiographers.

This was

the second day of employment for the two assistants.

A field audit

was conducted on their first day of employment by L. Russell, RSO.

Corrective Steps:

Retests were administered on August 3, 1988 to

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replace missing exams,

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Check sheets are being closely reviewed to verify timely and com-

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plete documentation is achieved.

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Full Complianc_e Achieved:

No later than August 31, 1988

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D.

License Condition 15 requires that the licensee conduct its

program in accordance with the statements, representations,

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and procedures contained in the application dated December 30,

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1986,

1.

Item 0, Section E of the Radiation Safety Manual, contained

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in the application dated December 30, 1986, states that

records of all training of radiography personnel conducted

by the licensee will be maintained on file.

Contrary to the above requirement, at the time of inspection,

the licensee had not maintained records of the licensee's

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retraining of radiography personnel on May 1, 1988 and May

20, 1988.

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(Page 5)

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Statement:

Retraining is an ongoing way of life with IS&E.

Person-

nel are always short term even though some have worked for IS&E since

inception.

Example:

E. Nunn worked approximately 20 days during

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the first half of 1987, none of the second half, and approximately

15 days on radiography in the first half of 1988, etc.

Corrective Steps:

Retraining sessions will be conducted and docu-

mented each calendar quarter for personnel employed at that time.

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Full Compliance Achieved: No later than September, 15, 1988

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2.

Item F.1, Section F of the Radiation Safety Manual, included

in the application dated December 30, 1986, requires that the

radiographer record the results of the daily inspection of

radiographic equipment prior to its use for field radiography.

Contrary to the above requirement, a licensee radiographer had

not recorded the results of the daily inspection of a SPEC Mo' del

2-T exposure device (serial number 318) prior to its use for

field radiography on July 29, 1988 at Eielson Air Force Base,

Alaska.

Statement:

All radiography personnel are well aware of this

requirement.

This radiographer evidently neglected to complete

the documentation as required.

Corrective Steps:

Documentation and survey requirements were dis-

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cussed at great length at the safety meeting held August 3, 1988

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and the radiographer cited in this instance was informed of dis-

c:plinary (termination of employment) action to be taken if an

additional violation was noted.

Full Compliance Achieved:

Imediately - August 3,1988

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It is IS&E's intent to provide safe equipment and guidelines for all

radioactive operations and I will add to my radiation safety staff

a Radiation Safety Manager to assure that no further violations or

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documentation delays occur.

If additional information is needed, please contact me.

Sincerely,

Lawrence Russell

Radiation Safety Officer

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cc: U.S. Nucle *r Regulatory Commission

Region V

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