ML20217M937

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Forwards Insp Rept 15000010/98-01 on 970401-14.Apparent Violations Being Considered for Escalated Enforcement Action
ML20217M937
Person / Time
Issue date: 04/24/1998
From: Dan Collins
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To: Uptain D
AFFILIATION NOT ASSIGNED
Shared Package
ML20217M940 List:
References
15000010-98-01, 15000010-98-1, EA-98-222, NUDOCS 9805050172
Download: ML20217M937 (4)


See also: IR 015000010/1998001

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April 24,1998

lEA 98-222

U' ified Testing Services. Inc.

/iTTN: Mr. Donald Uptain

President

P. O. Box 37-

325 ' Industrial-Park Drive

Woodstock. AL 35188

SUBJECT: NRC INSPECTION REPORT NO. 150-00010/98-01

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Dear Mr. Uptain:

This refers to the inspection conducted on April 1.1998 at your Marietta.

Georgia office and at Robins Air Force Base. Georgia and to inspection

- activities that continued in the Region II office. from April 2.1998 through

April'14, 1998. The enclosed report presents the results of this inspection.

The inspection was limited to the activities conducted under reciprocity in

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accordance with the provisions of 10 CFR 150.20. The inspection consisted of

a selective. review of representative records, interviews of personnel, and

observations of licensed activities at a temporary job site at Robins Air -

. Force Base,-near Warner Robins, Georgia.

Based on the results of this inspection, five apparent violations were

identified and are being considered for escalated enforcement action in

accordance.with the " General Statement of Polit.y and Procedures for NRC j

Enforcement Actions" (Enforcement Policy). NUREG-1600. The apparent

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violations relate to: (1) the failure to secure from unauthorized removal or

access and maintain constant surveillance of licensed material that was in an

. unrestricted area. (2) the failure to verify the restricted area boundaries by l

survey. (3) the failure to post the restricted area with " Caution Radiation i

Area". signs. (4) the failure to maintain visual surveillance of the restricted

area, and (5) the failure to train radiographers in accordance with required

procedures. The circumstances surrounding these apparent violations, the

. significance of these issues. and the need for lasting and effective

corrective action were discussed with members of your staff during a telephone-

conference exit meeting on April 2.1998, and during subsequent telephone

calls as inspection activities continued in the. office including April 20,

1998. As a result, it may not be.necessary to conduct a predecisional

enforcement conference in order to enable the NRC to make an enforcement

idecision. However, a Notice of Violation is not presently being issued for

these inspection findings. Before the NRC makes its enforcement decision, we

are providing you an opportunity to either (1) respond in writing to the

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Unified Testing Services, ~ Inc. 2

apparent violations addressed in this. inspection report within 30 days of..the

'date of this letter or (2) request a predecisional enforcement conference.

' Please contact Mr.~ Mark Lesser at (404).562-4731 within seven days of the date

of this letter to notify the NRC of your intent.

Your respons'e. should you choose to provide one, should be clearly marked as a

" Response to Apparent Violations in Inspection Report No. 150-00010/98-01" and

should include for each of the apparent violations: (1) the reason for the

apparent violation, or, if contested, the basis for disputing the apparent!

violation. (2) the. corrective steps that have been taken and the results

achieved. (3) the corrective steps that will be taken to avoid further

. violations, and-(4) the date when full compliance will be achieved. Outline

the root cause(s) and corrective actions for these causes, for the apparent

. violations. In determining the root cause(s) and corrective actions you

should consider that the radiographer was delayed in arriving at the work site-

awaiting calibrated survey meters, that the radiographer did not have

sufficient rope to use to establish restricted areas or have sufficient

signs.

The following specific information is also needed to determine the adequacy of

corrective actions described in your letter dated April 4,1998:

1. Describe how your employees were reminded of your emphasis on safely and

correctly conducting radiographic operations. (i.e., how much time was

spent discussing this emphasis?- Was it done in a formal classroom-

' situation? Were radiographers informed as a group or individually? Was,

written guidance issued to employees that descrioed management's

expectations of employees engaged in industrial radiography?)

2. Describe how you are verifying that employees engaged in industrial

u radiography understand and implement Operating and Emergency Procedures

l properly. (i.e.. At what frequency does management perform field audits

of radiographers? Are radiographers being quizzed (orally or in

writing) on operating and emergency procedures?)

3. Describe how management is ensuring that only those individuals who are

authorized by the Georgia Radioactive Materials License to perform

L- radiographic operations are performing radiography when operating under

l the Georgia license in accordance with the provi.sions of 10 CFR 150.20.

Your response should be submitted under oath or affirmation and may reference

or include previously docketed correspondence, if the correspondence

adequately addresses the required response. If an adequate response is not

received within the time specified or an extension of time has not been i

granted by the NRC. the NRC will p.roceed with its enforcement decision or j

schedule a predecisional enforcement conference.

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Unified Testing Services, Inc. 3

In addition. please be advised that the characterization of the apparent

violations described in the enclosed inspection report may change as a result

of further NRC review. You will be advised by separate correspondence of the

results of our deliberations on this matter.

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice " a copy of

this letter, its enclosure, and your response (if you choose to provide one)

will be placed in the NRC Public Document Room (PDR).

If you have any questions, please contact M- Mark Lesser at (404) 562-4731 or

Mr. John Pelchat at (404) 562-4729.

Sincerely,

original signed by Douglas Collins

Douglas M. Collins. Director

Division of Nuclear Materials Safety i

Docket No. 150-00010

License No. General (10 CFR 150.20)

Enclosure: NRC Inspection Report

No. 150-00010/98-01  ;

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cc w/ encl:

State of Georgia

State of Alabama

78 AMDS/SGPB l

Attn: Capt Craig Refosco )

655 7th Street, B-207 l

Robins AFB, GA 31098-2227

Distribution w/ encl: 1

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In accordance with 10 CFR 2.790 of the NRC's " Rules of Pract

this letter, its enclosure. and your response (ifto you choose'id."

provide one) ac

will be placed in the NRC Public Document Room (PDR).

If you have any questions, please contact Mr. Mark Les r at (404) 562-4731 or

Mr. John Pelchat at (404) 562-4729.

Sincerely,

Douglas M. Collins, Director

Division f Nuclear Materials Safety

Docket No. 150-00010

License No. General (10 CFR 150.20)

Enclosure: NRC Inspection Report

No. 150-00010/98-01

cc w/ encl:

State of Georgia

State of Alabama

78 AMDS/SGPB

Attn: Capt Craig Refosco

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655 7th Street, B-207

Robins AFB, GA 31098-2227 j

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