ML20217N004
| ML20217N004 | |
| Person / Time | |
|---|---|
| Issue date: | 04/24/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20217M940 | List: |
| References | |
| 15000010-98-01, 15000010-98-1, NUDOCS 9805050186 | |
| Download: ML20217N004 (11) | |
See also: IR 015000010/1998001
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U. S. NUCLEAR REGULATORY COMMISSION
REGION II
Docket No.-
150-00010
License No.,
General License (10 CFR 150.20)
Report No.
150-00010/98-01
Licensee:
Unified Testing Services. Inc.
Location:
189 Cobb Parkway. N.W.
Marietta, Georgia 30062
Date:
April 1 - 14, 1997
Inspectors:
Shannon Rohrer, Radiation Specialist
John M. Pelchat. Senior Radiation Specialist
Approved by:
Mark S. Lesser. Chief
Materials Licensing /I.ispection Branch 2
Division of Nuclear Materials Safety
9805050186 900424
STPRQ ESQAL
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EXECUTIVE SUMMARY
On April 1. 1998. Nuclear Regulatory Commission (NRC) inspectors conducted a
routine unannounced inspection of radiographic operations conducted by Unified
Testing Services. Inc., a Georgia state licensee , working under reciprocity at
a temporary job site located at Robins Air Force Base (RAFB). The inspection
included discussions with cognizant licensee representatives, review of
-documentation and direct observation of licenced activity. The areas
inspected included, scope of licensee program. facilities materials
transportation and control, training, radiation surveys and posting. The
inspectors also reviewed records of reciprocity activities maintained in the
licensee's Marietta. Georgia office.
This report covers licensed activity
conducted between January 19 and April 1. 1998.
Scope of Licensee Prooram
The scope of the licensee's program was generally limited to those activities
authorized by its State of Georgia radioactive materials license.
For the
purposes of this report the activities were further limited to those
authorized under the provisions of 10 CFR 150.20 by NRC Form 241 #000388 dated
January 15. 1998.
Facilities and Eouioment
The inspectors found that licensee personnel had not brought a sufficient
amount of rope and radiation area signe to adequately designate and post the
boundaries of the restricted area locaud at the temporary job site.
This
contributed to the apparent violations regarding proper posting of restricted
areas discussed below.
Materials Transoortation and Control
The licensee's procedures for transporting licensed materials from the storage
facility to the temporary job site were adequate.
The inspectors observed
that the licensee failed to maintain constant surveillance of, and restrict
from unauthorized access or removal. licensed material that was in an
unrestricted area and that was not in storage at the temporary job site.
This
was identified as an apparent violation of 10 CFR, Parts 20.1801 and 20.1802.
Trainina
Licensed activities at the temporary job site were carried out by two
radiographers. The inspectors found that neither radiographer had been
trained in accordance with the licensee's radiation safety training
procedures.
This was identified as two examples of an apparent violation of
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Radiation Surveys and Postina
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The inspectors observed the licensee's surveys of radiographic equipment
during radiography operations and found that thef were adequate.
The
inspectors performed. independent surveys of Restricted Area boundaries and
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found that area radiation levels were within regulatory limits.
However,
radiography personnel failed to perform these surveys as required by licensee
procedure.
Licensee personnel also failed to adequately post the Restricted
Area with " Caution Radiation Area" signs, and failed to maintain adequate
visual surveillance of the Restricted Area during radiographic operations.
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These were identified as three apparent violations of 10 CFR 150.20(b)(5)
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Attachment-
List of Persons Contacted
Inspection Procedures Used
List of Items Opened. Closed, and Discussed
List of Acronyms
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REPORT DETAILS
1.
SCOPE OF LICENSEE PROGRAM
a.
Insoection Scope (87120)
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10 CFR 30.3 requires that no person shall possess or use byproduct
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material except as authorized by a specific or general license
issued by the NRC.
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10 CFR 150.20(a) states, in part, that any person who holds a
specific license from an Agreement State is granted a Nuclear
Regulatory Commission (NRC) general license to conduct the same
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activity in non-Agreement States subject to the provisions of
The inspectors reviewed licensing do u mentation including a
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properly filed NRC Form 241. the Georgia State Licence No. 1308-1
and portions of the license application. The scope of this
inspection included only those activities that were conducted
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under reciprocity in areas of exclusive Federal jurisdiction
within an Agreement State. This involved reviewing material and
conducting interviews related to such activities at a permanent
facility outside of the area of exclusive Federal jurisdiction.
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b.
Observations and Findinos
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Unified Testing Services Inc. (Unified Testing) is licensed by the
State of Georgia to possess sealed sources of iridium 192 (Ir-192)
[ maximum'140 curies per source] and cobalt 60 [ maximum 33 curies
per source] for use in Amersham exposure devices for industrial
radiography. On January 15, 1998, the licensee filed an NRC
Form 241, " Report of Proposed Activities in Non-Agreement States,"
to report proposed radiography activities involving Ir-192 (not to
exceed 140 curies) to be conducted on Robins Air Force Base (RAFB)
between January 19 and July 17 of 1998. The request was
authorized and assigned the tracking number 000388.
Unified
Testing was conducting radiographic operations at RAFB un62r a
general license granted by 10 CFR Part 150.20 that requires that
licensees comply with all terms and conditions of the specific
license issued by an Agreement State as well as applicable Federal
regulations.
c.
Conclusions
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The licensee *s activities on RAFB were authorized by the NRC.
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FACILITIES AND EQUIPMENT
a.
Insoection Scoce (87120)
The inspectors observed facilities a5d equipment as they related
to performance of licensed activities located at a temporary job
site located at RAFB.
b.
Observations and Findings
The temporary job site at RAFB was cluttered with construction
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equipment, materials, and debris that included two semi-tractor
trailers which interfered with the ability of licensee personnel
to maintain visual surveillance of the Restricted Area.
The
inspectors observed that the radiographers had not brought a
sufficient amount of rope and radiation area signs to adequately
designate and post the boundaries of the restricted area located
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at the temporary job site.
In some places, the radiography crew
used lengths of masking tape suspended between two objects in lieu
of rope or other visually distinct barricading materials.
c.
Conclusions
Overall
licensee equipment at the temporary job site was not
adequate.
Specifically, the inspectors found that licensee
personnel had not brought a sufficient amount of materials to
adequately designate and post the boundaries of the restricted
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area located at the temporary job site.
The inspectors concluded
that this identified weakness contributed to the violations
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regarding proper posting of restricted areas documented in
Paragraph 4.
3.
MATERIALS USE. TRANSPORTATION AND CONTROL
a.
Insoection Scone (87120)
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NRC inspectors observed the transportation and set up of
radiography equipment at a temporary job site on RAFB.
The
vehicle was inspected for proper labeling and securing of licensed
material. Control of licensed material was observed.
b.
Observations and Findings
The inspectors arrived at RAFB before the licensee 2,nd waited at
the temporary job site.
Upon the arrival of licensee personnel,
the inspectors took surveys, and visually inspected the trailer
used to transport licensed materials to verify that coplicable
transportation requirements had been met.
The inspectors observed
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equipment set up, including transfer of the camera from the
trailer to a cable spool, and establishment of Restricted Area
boundaries.
10 CFR 20.1801 requires that the lic6nsee secure from unauthorized
removal or access licensed materials that are stored in
unrestricted areas.
10 CFR 20.1802 requires that the licensee
control and maintain constant surveillance of licensed material
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that is in an unrestricted area and that is not in storage. As
defined in 10 CFR 20.1003, unrestricted area means an area, access
to which is neither limited nor controlled by the licensee
At the radiographer's request, the inspectors relocated their
vehicle since it was parked in the area that the radiographer
intended to establish as a restricted area. After relocating
their vehicle, the inspectors saw the assistant radiographer had
left the area.
The inspectors also observed that the radiographer
was also out of sight.
In an attempt to find the radiographer,
one of the inspectors tried to open the locked door of the dark
room and was able to hear the muffled voice of the radiographer
inside. At this time the camera, containing 35 curies of Ir-192.
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was sitting outdoors on a spool with no licensee surveillance, for
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a period of approximately 5 - 10 minutes before surveillance was
re-established by licensee personnel.
Upon questioning, the
radiographer stated that he had thought that the issoectors would
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maintain control and surveillance of the camera. Tne inspectors
pointed out that they had not been' asked to maintain control and
surveillance of the camera nor would they have been ole to, since
the licensee was responsible for the security of licensed
materials.
The failure to maintain adequate control and
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surveillance of licensed materials was identified as an apparent
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violation of 10 CFR 20.1801 and 10 CFR 20.1802. (EEI 150-00010/98
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01-01)
c.
Conclusions
Licensed material was transported in accordance with applicable
Federal regulations.
The inspectors identified a violation of
10 CFR, Parts 20.1801 and 20.1802. in which licensed material was
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left unattended and unsecured in a restricted area.
4.
AREA RADIATION SURVEYS AND POSTING
a.
Insoection Scone (87120)
The inspectors observed radiographic operations and reviewed
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operating procedures related to area radiation surveys and
posting.
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b.
Observations and Findinas
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10 CFR 150.20(a) provides. in part, that any person who holds a
specific license from an Agreement State is granted an NRC general
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license to conduct the same activity #in'non-Agreement States
subject to the provisions of 10 CFR 150.20(b).
10 CFR 150.20(b)(5) requires that any person engaged in licensed
activities pursuant to 10 CFR 150.20(a). shall comply with all
terms and conditions of the specific license issued by an
Agreement State except when such terms or conditions are contrary
to the requirements of this section.
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Condition No. 24 of Georgia Radioactive Materials License
No. 1308-01 required that licensed activities be conducted in
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accordance with the statements, representations, and procedures
contained in the license application dated November 14, 1995, and
in the letters dated December 11. 1995, and September 12. 1997.
The licensee's operating and emergency (0&E) pracedures
(Revision 0, dated November 1. 1995), were submitted as part of
the license application dated November 14, 1995.
Section 5 of the
O&E procedures described the licensee's procedures for
establishing restricted areas at temporary job sites.
Item 5.1 of the 1.censee's 0&E procedures required that radiation
area signs be posted at all accessible entrances to the restricted
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area.
Item 5.2 of the licensee's O&E procedures required that
radiation area signs be posted at intervals as necessary to be
readily seen.
During a survey of radiation levels at the
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restricted area boundary, the inspectors found an unmarked gap in
the boundary of the licensee's restricted area.
This gap was
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found along one long side of the rectangularly shaped restricted
area.
This entrance to the restricted area was out of view to
licensee personnel when the radiography source was in the exposed
position.
The inspectors also observed that licensee personnel did not post
" Caution Radiation Area" signs on the plastic erosion control
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barrier that formed the opposing long side of the rectangular
controlled area. The inspectors pointed this out to the
radiographer. who stated that he had run out of signs.
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failure to properly post the restricted area boundaries and the
entrance to the restricted was an apparent violation of
10 CFR 150.20(b)(5). (EEI 150-00010/98-01-02)
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Item 5.3 of the licensee's 0&E procedures requires that restricted
areas at temporary job sites be visually controlled by radiography
personnel.
The inspectors observed that the radiographer and his
assistant stood together during the first three exposures. . From
their location, approximately one fo6rth of the restricted area
was blocked from vi.sual surveillance by the two semi-trailers
located within the restricted area.
During a tour of the
restricted area perimeter, the inspectors verified the apparent
blind spot.
One of inspectors was able to enter the Restricted
Area through the unmarked gap in the boundary and noted that the
entrance was not within the view of the radiograph.y crew.
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inspectors remained near this access point during the remainder of
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the two minute exposure.
The inspectors discussed this finding
with licensee personnel who then adjusted their positions 50 that
they would be possible to view the other side of the semi trailers
and ensure that no persons could enter the restricted area without
their knowledge.
The failure to properly maintain visual
surveillance of the restricted area during radiography operations
was an apparent violation of 10 CFR 150.20(b)(5). (EEI 150-
00010/98-01-03)
Item 6.3 of the licensee's O&E procedures require that the
restricted area be surveyed during radiographic operations and the
restricted area boundaries be adjusted as necessary.
Section 5 of
the licensee's O&E procedures stated that a restricted area
boundary must be established with radiation levels no greater than
two millirem in any one hour. Section 5 also included a table
that provided the apprcximate dimensions of a restricted area
based on the effective strength of the radiography source to be
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used as a guide by radiography personnel.
The table included a
note that stated that the table was be used as a guide only and
was not to be relied upon without making a complete survey to
verify the boundaries of the restricted area.
The inspectors observed that licensee personnel did not make any
surveys of radiation levels at the boundaries of the restricted
area during the first three radiographic exposures made. The
failure to perform radiation surveys to verify the proper
placement of restricted area boundaries was an apparent violation
of 10 CFR 150.20(b)(5). (EET 150-00010/98-01-04)
The inspectors observed the licensee's surveys of radiographic
equipment during radiography operations and found that they were
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adequate.
Licensee radiation survey equipment was found to be
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operational and properly calibrated.
Licensee personnel were
observed to be wearing all required radiation dosimetry.
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Independent survey measurements made by the inspectors
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demonstrated that the radiation icvels at the restricted area
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boundary did not exceed two millirem in any one hour.
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Measurements were made with a Ludlum Model 2401-EC2 geiger-mueller
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survey instrument (serial no. 133268' calibration date October 7.
1997). The inspectors found that the radiation level along one
boundary measured approximately 15 millirem per hour and
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4 millirem per hour uiong another boundary.
The licensee was
averaging about two exposures per hour during the inspection: each
exposure lasted two minutes. The maximum resultant exposure to an
individual standing in the 15 millirem per hour field at the
restricted area boundary would have been about 1.0 millirem in any
one hour.
The inspectors discussed this result with licensee
personnel and noted that if the licensee were to increase the
number of exposures to greater than four per hour, the resultant
exposure rate at the restricted area boundary would exceed two
millirem in any one hour.
Licensee personnel elected to adjust-
the new boundaries where the dose rates had exceeded two millirem
per hour during radiographic exposures.
c.
Conclusions
The licensee displayed a weakness in performing area radiation
surveys and in establishing a Restricted Area.
The inspectors
identified three apparent violatirrs of the licensee's operating
procedures that involved failure to arvey the Restricted Area,
failure to control the Restricted Area visually and failure to
post " Caution Radiation Area ~ signs at intervals necessary to be
readily seen.
Licensee personnel implemented short-term
corrective actions when these findings were identified by the
inspectors.
5.
TRAINING
a.
Insoection Scooe (871201
NRC inspectors reviewed Unified Testing's training records and
procedures tr decide whether radiographic operations being
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perfcrmed at RAFB were being done by properly trained individuals.
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b.
Observati .5.3nd Findings
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Condit4n
4.B of Georgia Radioactive Materials License No.1308-1
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part, that licensed activities shall only be performed
by individuals trained in accordance with the licensee's training
procedures entitled " Radiation Safety Training Procedure and
History." described in a letter dated December 11. 1995.
The
licensee's training procedures stated that radiographers shall
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have successfully completed the Georgia Radiographers Examination,
or equivalent. and have received certification from the Georgia
Department of Natural Resources. Radioactive Materials Program.
Review of training records and discussions with the radiography
crew and the licensee's RSO revealed'that neither of the two
licensee employees involved in performing radiography at the
temporary job site located at RAFB had successfully completed the
Georgia Radiographers Examination or any other equivalent
examination. This finding was identified on April 14. 1998, when
the inspectors received a complete copy of the license from the
State of Georgia. The failure to ensure that radiography was
performed by individuals trained in accordance with the licensee's
training procedures was two examples of an apparent violation of
10 CFR 150.20(b)(5). (EEI 150-00010/98-01-05)
c.
Conclusions
The inspectors concluded that the requirements of the licensee's
training procedures were not being satisfied.
Two examples of an
apparent violation of 10 CFR 150.20(b)(5) were identified.
EXIT MEETING SUMMARY
The findings were discussed with the RSO and more information was requested
from him during a conference call on April 2.1998.
The inspectors, their
branch chief, and the RSO had an exit meeting via telephone at 2:05 p.m. on
April 2.1998, during which the apparent violations regarding the security of
licensed materials; and posting and maintenance of restricted areas were
discussed.
In a letter to the NRC dated April 7. 1998, licensee management
described additional corrective actions that included termination of one of
the radiographer's employment as of April 6.1998, and reminding other
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radiographers of the licensee's " emphasis on safely and properly performing
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radiographic operations." An additional apparent violation regarding the
training of radiography personnel was discussed with the RS0 during a
telephone conversation on April 20, 1998.
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ATTACHMENT
LIST OF PERSONS CONTACTED
Licensee
- Jessie Smith. Operations Manager. Radiation Saf(ty Officer
Richard Brook. Radiographer
Joseph Menina Radiographer
- Attended April 2. 1998 Telephonic Exit Meeting
INSPECTION PROCEDURES USED
IP 87100 - Licensed Materials Program
IP 83822 - Radiation Protection
LIST OF ITEMS OPENE3 CLOSED. AND DISCUSSED
Item Number
Status
Descriotion
150-00010/98-01-01
Open
EEI - Failure to maintain adequate control
and surveillance of licensed
materials in an unrestricted area.
150-00010/98-01-02
Open
EEI - Failure to adequately post
restricted area boundaries and
entrances.
150-00010/98-01-03
Open
EEI - Failure to maintain adequate visual
surveillance of a restricted area.
150-00010/98-01-04
Open
EEI - Failure to perform radiation surveys
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to verify the proper placement of
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restricted area boundaries.
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150-00010/98-01-05
Open
EEI - Failure to ensure radiographic
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personnel were trained in accordance
with licensee procedures.
LIST OF ACRONYMS
CFR
Code of Federal Regulations
Escalated Enforcement Item
IP
Inspection Procedure
NRC
Nuclear Regulatory Commission
O&E
Operating and Emergency
RAFB Robins Air Force Base