ML20247M908
| ML20247M908 | |
| Person / Time | |
|---|---|
| Issue date: | 09/18/1989 |
| From: | Caniano R, Jeffery Lynch, Mallett B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20247M877 | List: |
| References | |
| REF-QA-99990003-890919 99990003-89-05, 99990003-89-5, NUDOCS 8909260080 | |
| Download: ML20247M908 (8) | |
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, U. S. NUCLEAR REGULATORY COMMISSION
- REGION III
-Report No. 999-90003/89005(DRSS)
Docket'No. 999-90003 North Dakota License No. 33-14907-01
- Licensee: Midwest Industrial X-Ray, Inc.
'4102 7th Avenue North Fargo,'ND 58107 Inspector: J. L. Lynch h4N L F-d5 - 8 7
< Radiation Specialist .
< Date
-- Reviewed By: R. J. Caniano, Chief '
N OM ~[9 Nuclear Materials Safe Date Section 2
- Approved By: Bruce
/ llgy42 hS-allett, Ph.D., Chief 7-// d')
Nuclear Materials Safety Branch Date Inspection Summary Inspection on August 10-11, 1989 (Report No. 999-90003/89005(DRSS))
Areas Inspected: This was an unannounced special inspection conducted at a
. field location in Becker, Minnesota in response' to Region III's receipt of allegations concerning radiography operations in Minnesota. The inspection
~ included a field review of licensee records and procedures, and interviews of licensee representatives.
Results: One of the three allegations was substantiated and four apparent violations of NRC requirements were identified, (1) Failure to submit reciprocity requests, 10 CFR 150.20(b)(1) (Section 4); (2) Failure to post restricted areas,10 CFR 34.42 (Section 6); (3) Failure to recharge dosimeter, 10 CFR'34.33(a) (Section 6); ai -) Failure to use calibrated survey instrument, 10 CFR 34.24 (Secti , 6) .
l 8909260000 890919 REG 4 GA999 EEC*****
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ii DETAILS
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- 1. Persons Contacted-
+ Michael Manger-President, Radiation Safety Officer
- Kenneth Kolb-Radiographer Richard Peterson-Contract Consultant, Northern States Power (NSP)
Wayre Kolstad-Operations Supervisor, NSP
-+Ervin Woodard-Instructor, Southeast Community College Dana Mount-North Dakota Department of Health William Breitenstein-Minnesota Department of Health Rhonda Sanders-fexas Department of Health
- Attended exit interview on August 10, 1989.
+ Contacted by telephone on August 15, 1989.
.2. . Licensed Program Midwest Industrial X-Ray,'Inc. (Midwest) performs industrial radiography using sealed sources of iridium-192 and cobalt-60. The company is
-licensed out of North Dakota (License No. 33-14907-01) and Iowa, both
' Agreement States.
The' radiation' safety program is managed by Michael Manger, Radiation Safety'0fficer and company president. . Midwest employs seven raciographers and one radiographer's-assistant. The operations reviewed during this inspection were being conducted at a field site.in Becker, Minnesota under reciprocity with the North Dakota license . The reciprocity is granted under a general license in 10 CFR 150.20(a).
- 3. Purpose of Special Inspection This special inspection was initiated by receipt of allegations by letter on July 27, 1989 and by telephone on July 31, 1989. The allegations --
concerned onsite health and safety at temporary radiography sites. The specific allegations.were as follows:
Two minor children are helping a Midwest radiographer perform radiography at Becker, Minr;esota.
A licensee employee on a radiography job in Minnesota does not have appropriate radiation safety training.
The NRC was not notified of radiography jobs performed by Midwest in Minnesota. '
In addition to the above, the following peripheral issues were also identified by the alleger.
Radiography cameras have high dose rates.
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l Vehicles do not have transportation warning placards.
Radiography cables are badly worn.
p Similar allegations and concerns were provided to the North Dakota Department of Health (NDDOH) who oerformed an inspection of Midwest on July 25,1989. Inspection results relating to the NDDOH inspection are identified in Sections 4, 5 and 6 of this report.
- 4. Allegation Followup Allegation No. 1: Two minor children are helping a Midwest radiographer perform radiography at Becker, Minnesota.
Clarification of this allegation was obtained in a telephone conversation with the alleger on August 7, 1989, who stated that the children, a
- laughter and son of Michael Manger, were not performing radiography, but, were carrying shielded cameras containing iridium-192. Manger, in an August 15, 1989 telephone conversation, denied that his children ever carried or worked with radiography cameras. He stated that the children do work for him on radiography sites, but not in radiation areas.
The children, said Manger, work in the darkroom at the jobsite, processing film. He said that the children have also travelled with him in vehicles carrying radiography sources, but on every occasion he insured that radiation levels in the passenger compartment were not above background.
He stated that records of these vehicle surveys are maintained at the North Dakota office. The children referenced in the allegation were the 13 year-old son and the 17 year-old daughter of Michael Manger.
Neither the children or Manger were present at the radiography site during the inspection.
Kenneth Kolb, the only radiographer present during the inspection, stated that he had observed the children working in darkrooms on jobsites during his two month employment with Midwest. He raid that he had never seen the children using or carrying radiography cameras.
The NDDOH inspection of Midwest also looked into this allegation and could not substantiate it. NDDOH interviewed Manger and other Midwest employees and also reviewed radiography camera use records during the inspection.
The allegation was not substantiated and no violations of NRC requirements were identified.
Allegation No. 2: A licensee employee on a radiography job in Minnesota does not have appropriate radiation safety training.
The employee referenced in the allegation is Kenneth Kolb. He was interviewed during the inspection. Kolb stated that he was schooled in radiography at Southeast Community College, Milford, Nebraska, graduating in 1987.
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4 His enrollment in'the non-destructive testing (NDT) program at Southeast was' confirmed by Ervin Woodard, an instructor at the school. Woodard stated that Kolb received approximately 150 hours0.00174 days <br />0.0417 hours <br />2.480159e-4 weeks <br />5.7075e-5 months <br /> in classroom training in all aspects of NDT. 'The NRC Regulatory Guide 10.6' suggests that
-radiographer receive'40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of classroom training.
Kolb also stated.that he was certified in 1987 by the Texas Department of Health as a radiographer while he was working in that state. His completion of the-Texas radiography examination was confirmed by Rhonda Sanders of that' organization. His certification is valid until June 1992.
Kolb stated that prior to his; employment with Midwest, he performed radiography for other companies and that in June 1989 he received one week of on-the-job training from Michael Manger and passed a written
- radiographer examination. ' Manger confirmed that h9 provided the field
- training and examination to Kolb.
The NDDOH performed a review of training records maintained at Midwest's Fargo, North Dakota facility. No discrepancies regarding Kolb's training were identified during that review.
The evidence gathered during this inspection indicates that Kenneth Kolb '
has received adequate classroom and-field training in radiography procedures and radiation safety, meeting NRC training requirements.
The allegation was not substantiated and no violations of NRC requirements were identified.
A11ecation No'. 3: The NRC was not notified of radiography jobs performed in Minnesota.
10 CFR 150.20(b)(1) dictates reciprocity criteria for an Agreement State licensee using radioactive materials in a non-Agreement State under a general-license. It requires that the licensee shall, at least three days before engaging in such activities, file copies of NRC .
Form-241 and the Agreement State license with the NRC Region in which the
. Agreement State is located. The NRC Region in which North Dakota is located is Region IV, Arlington, Texas.
The NRC Region IV office had not, prior to August 7,1989, received any reciprocity requests from Midwest for work-in Minnesota since June 1985.
Region III did not receive any reciprocity requests from Midwest since at least 1987.
Michael Manger stated that radiography had been performed in Minnesota by his company in both 1988 and 1989 on a regular basis. Manger
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said that the notifications had been overlooked but that he would comply with the requirement in the future. He thought that his former partner was providing notifications to the NRC as required by 10 CFR 150.20. His partner has been deceased since January 1989.
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. L-He submitted a Form-241 to Region IV on August 2, 1989 (received August 7,1989) for three jobs ongoing in Minnesota, including the ' job reviewed during this inspection. The Becker, Minnesota job began in June 1989 but the NRC was not notified until the August 2,1989 filing.
Ma'nger said that he was made aware of the requirement by the NDDOH during their inspection on July 25, 1989. The NDDOH. representative stated that the licensee is. in violation of State regulations for failing to report these radiography operations to the NRC. . Midwest was also founa t. be in violation: of Minnesota Department of Health regulations for not reg %ering with the. State prior to using radioactive material in Minnesota, uccording to William Breitenstein of that agency.
The failure by the licensee to file copies of NRC Form-241 and its Agreement State license with the NRC within at least three days prior.
to engaging in radiography in Minnesota on numerous occasions during 1988 and 1989 constitutes an apparent violation of- 10 CFR 150.20(b)(1).
The allegation was substantiated and one apparent violation of NRC requirements was identified.
- 5. Peripheral Issues Followup
-Peripheral Issue No. 1: Radiography cameras have high dose rates.
One radiography camera was present ah the Becker, Minnesota radiography site during the inspection. It was a Source Production and Equipment Company, Inc. (SPEC) Model 2-T, containing approximately 50 curies of i ridi um-192. Maximum radiation levels on the surface of the camera (200 curie-iridium-192 capacity) were measured at approximately 66 mR/hr with NRC instruments SMAC 252B and Xetex 305B. Similar. readings were measured with.the licensee's Victoreen 492 survey instrument. These measurements are well within the 200 mR/hr-surface limit in 10 CFR 34.21.
The. alleger stated in a telephone conversation that the high readings were identified when one of the camera's plugs was removed to hook up a cable. Radiation levels would be expected to increase dramatically when a plug is removed. When this occurs, operating procedures are required to be in place including the use of dosimetry by the radiographer.
10 CFR 34.21 does not apply to a radiography camera which is not in a fully shielded orientation. Radiation measurements were not made by the ;
inspector with the plug removed as the results of those surveys would not i justify additional exposure to the individuals involved. The radiographer demonstrated knowledge of proper plug removal procedures and precautions to the inspector.
No violations c,f NRC requirements or excessive camera radiation levels were identified. The North Dakota Department of Health came to an identical conclusion after the July 25, 1989 inspection.
Peripheral Issue No. 2: Vehicles do not have transportation warning placards.
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Warning placards were seen on the Midwest radiography truck at Becker, Minnesota. The placards were not in use, however, as the radiography camera is transported under a Yellow-II transportation label. When in a transport mode, the camera is carried in an overpack as authorized in 49 CFR 173.25. That overpack is labeled with a Yellow-II transportation label and is printed with required information as stated in 49 CFR 173.25.
Vehicle placarding is not required under these conditions.
The. concern was not substantiated and no violations of NRC requirements were identified in that vehicle placards are in place, but not required to be used. The NDDOH identified similar transportation systems used by Midwest outside of Minnesota.
Peripheral Issue No. 3: Radiography cables are badly worn.
The cables used at the Becker, Minnesota field site were found to be worn but not unacceptably so. It was noticed that a small amount of sand had accumulated in the crank attached to the cables which, left uncorrected, could cause a cable jam. The radiographer was aware of the sand accumulation, however, and was in preparation to take the crank and cables apart for cleaning and lubrication.
Michael Manger stated that all of the cables had undergone a full inspection and maintenance within the last three months as required by 10 CFR 34.28. The NDDOH reviewed equipment maintenance records during their inspection of Midwest and found no violations regarding the equipment used in Minnesota.
The concern was not substantiated and no violations of NRC requirements were identified. The radiography cables were found to be worn but not badly worn as was alleged.
- 6. Other Inspection Results In addition to reviewing the allegations, the inspector also reviewed operating procedures at the Becker, Minnesota site. The object of the radiography was a natural gas pipeline being installed by Northern States Power (NSP). The radiographer was observed from several hundred feet away for a period of time prior to approach. The radiographer was not observed actually performing radiographic exposures, as these were accomplished earlier in the day. He was, however, observed handling and maintaining radiography equipment. Problem areas identified during the inspection are detailed below.
The radiographer, Kenneth Kolb, was asked to demonstrate procedures used during radiography shots performed that day (without exposing the source).
During this review the individual was questioned about posting radiation and high radiation areas around the radiography operation. Kolb stated that during some shots, such as those Se performed that day, radiation and high radiation areas are not posted as required by 10 CFR 20.
Appropriate signs were available on the field site. Kolb stated that he 6
did not post the area because he had good control over the site and no other persons were present. The shots were performed on a pipeline in a ditch.
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10 CFR 34.42 requires that notwithstanding any provisions in 10 CFR 20.204(c), areas in which radiography is being performed shall be
. conspicuously posted as required by 10 CFR 20.203(b) and (c)(1).
10 CFR 20.203(b) requires that each radiation area be posted with a sign or sign' kaaring the radiation caution symbol and the words
" Caution - Re ,ation Area." 10 CFR 20.203(c)(1) requires that each high radiation area be posted with a sign or signs bearing the radiation caution symbol and the words " Caution - High Radiation Area."
The failure to post " Caution - Radiation Area" and " Caution - High Radiation Area" signs during radiography operations at the Becker, Minnesota field site on August 10, 1989 constitutes an apparent violation of 10 CFR 34.42.
10 CFR 34.33(a) requires that pocket dosimeters be worn by radiographer and be recharged at the start of each shift.
Kolb was wearing a Dosimeter Corporation Model 883 pocket dosimeter (500 millirem range). The dosimeter was reading between 30 and j 40 millirem during the inspection. Kolb stated that he had the ;
capability to recharge the dosimeter but had not recharged it prior to i doing radiography that day.
The failure to recharge the radiographer's pocket dosimeter at the start of the August 10, 1989 shift uat the Becker, Minnesota site, constitutes an apparent violation of 10 CFR 34.33(a).
10 CFR 34.24 requires that each radiation survey instrument be calibrated at intervals not to exceed three months and after each instrument servicing.
Kolb had in his possession, on the field site, a Victoreen 492 GM survey instrument. The instrument was last calibrated on May 1, 1989 and was due for calibration on August 1, 1989. Kolb stated that he was aware that the ,
instrument was overdue for calibration and that Michael Manger was sending a replacement instrument to him. Manger said that he simply forgot to get the calibrated instrument to his radiographer until it was past due.
The licensee's instrument was compared to the NRC SMAC and Xetex instruments. Radiation ievels detected were comparable with all three instruments.
The failure to use a survey instrument during radiographic operations j which was calibrated within the previous three month period constitutes l an apparent violation of 10 CFR 34.24. !
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1 In addition to the areas above, the inspector also reviewed leak test records, transportation papers, utilization logs, film badge usage, security and radiation survey records. No violations of NRC requirements were identified in these areas.
Three apparent violations of NRC requirements were identified.
- 7. Exit Interview On August 10, 1989, an exit interview was held with Kenneth Kolb at the Becker, Minnesota field site. On August 15, 1989, Michael Manger was contacted and informed of the specific allegations and NRC findings. No written material was left with the licensee. In addition, no proprietary information is included in this inspection report.
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