ML20249C628
| ML20249C628 | |
| Person / Time | |
|---|---|
| Issue date: | 05/05/1998 |
| From: | Cleave V, Williamson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20249C612 | List: |
| References | |
| FOIA-98-228 4-97-064, 4-97-64, NUDOCS 9806300441 | |
| Download: ML20249C628 (15) | |
Text
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CASE No. 4-97-064 Af.. %,A s
<a United States Nuclear Regulatory Commission
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Report of Investigation H&G INSPECTION, INC.:
DELIBERATE VIOLATION OF REO.UIRED RADIOGRAPHY PRACTICES i
Office of Investigations l
Reported by 01: RIV l
Mfor;.mtio i i:t !!d; rncrd ms deieted
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-Title:
H&G INSPECTION,' INC.:
DELIBERATE VIOLATION OF REQUIRED RADIOGRAPHY PRACTICES Licensee:
Case No.: 4-97-064
-H&G~ Inspection. Inc.
Report Date: May 5, 1998 9315 Summer Bell
. Houston, TX 77074 Control Office:
01:RIV Docket No.:
Status: CLOSED Reported by:
Reviewed and Approved by:
>~
[
hSk VirgiTria Van Cleave. Sr. Special Agent E. L. Williamson. Director
.0ffice of Investigations Office of Inve.stigctions Field Office. Region IV.
Field Office, Region IV-WARNING LSSE PU UME DISCUSS THE S0 IS REP OF INVES GATION DE NRC WITH0' THORITY APPR ING OFF AL OF THI REPORT.
NA THORIZED DISCLOS MAY RES' IN ADVERSE. ADMINISTRATIVE ACTI0ri AND CRIMINAL PROSE '
ON.
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SYNOPSIS L:
This investigation was initiated on November 12, 1997, by the Nuclear Regulatory Commission. Office of Investigations. Region IV. to determine if radiographer at H&G Inspection. Inc. (H&G) deliberately violated required radiography practices.
Based on the evidence developed during this investigation, testimony, and
-document review, the allegation that radiographer at H&G deliberately violated required radiography practices was not substantiated.
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TABLE OF CONTENTS Eagt SYN 0PSIS.....................................................
1 LIST OF. INTERVIEWEES........................................
5 DETAILS OF INVESTIGATION.......................................
7 Allegation (Deliberate Violation of Required Radiography Practices.................................
7 Appl i ca bl e Regul a ti ons..................................
7 Purpose of Investigation................................
7 Background........................................
7 Intervi ew of Al l eger.....................................
8 Coordination with NRC Staff......................
9 Documentation Review.....................................
10 Testimony / Evidence......................................
11 Agent's Analysis..............................
12 Concl u s i on s..............................................
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. LIST OF EXHIBITS..................................
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LIST OF INTERVIEWEES Exhibit H&G.
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H&G....................
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no0VA N (,I 0FFICE DIjECTOR OFFICE F INVEST TIONS, REST'lN IV l
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DETAILS OF INVESTIGATION Allecation Deliberate Violation of Required Radiography Practices Acolicable Regulations 10 CFR 19.13: Notifications and Reports to Individuals (1997 Edition) 10 CFR 30.9: Completeness end Accurdcy of IrifUlllidllUll (1996 Edillun) 10 CFR 30.10:
31iberate Misconduct (1996 Edition) 10 CFR 34.33:
Personnel Monitoring (1996 Edition) 10 CFR 34.C: Radiation Surveys (1996 Edition) i 10 CFR 34.42:
Posting (1996 Edition)
Puroose of Investigation This investigation was initiated on November 12, 1997, by the Nuclear Regulatory Commission (NRC). Office of Investigations (01). Region IV (RIV),
to determine if radiographer at H&G Inspection. Inc. (H&G) deliberately violated required radiography practices (Exhibit 1).
i Backaround
_ On October 2 1997 Christi HERNANDE.7, Radiation Specialist NRC:RIV, was ta db ith H&G, Evanston, Wyoming.
i tat he had been fired by the license which subsequently refused e him with a report of his radiation exposure data as required, urther stated that H&G employees do not always use survey instruments per nd-dosimetry or establish required boundaries while performing radiography. On November 10. 1997, an NRC:RIV Allegation Review Board requested that 01:RIV and the Division of Nuclear Materials Safety (DNMS).
RIV, interview the alleger to obtain additional information about his concerns.
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Case No. 4-97-064 1
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/_X Interview with Allecer/ -
i(Exhibit 2) k
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asinterviewedonNovember15.199).by01andDNMS,RIV,andrelated 7
e fol wing informatio in substance:
.)
I said he worked for H&G as
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Manager of,H&G's Evanston office, cause h did not help FRANKLIN move into his residence.
I said he had tried repeatedly to obtain a copy of hi ra tion vxposu history from H&G but still had not received it.
said when he talked to Harry GIBSON, President. H&G, about his radia ion e osure history report GIBSON told him he had been terminated f char ng cersonal expenses and unauthorized items on his H&G credit card.
ecause "you gotta eat."
In addition, aid H&G's truck blew a tire t ummer of 1997, which he replaced and charge to H&G without H&G's approval.
aid GIBSON told him he had to repay his personal charges to H&G's credit ca said his first H&G job was a pipeline outside of Rawllns, omin.
He was assigned to wo with whose 1
't name he believed was from H&G's South Carol a office.
said ever use survey meter and left his film badge on the v' or of 1s truck, told him it was not n essa to survey anything because they re wearing larming rate meters.
said he knew that was not right because during his H&G training, he s to to survey and wear all required dosimetry.
f i M aid he badge, pocket dosimeter, and rate meter at all t7mes.
e said !
used a pocket dosimeter and recorded its g
readi onthepaperworkas equired, but he did not wear his film badge.
V aid he belie ed the pocket dosimeter readings recorded were accurate.
oweve.
recorded survey eter adings which were falsified because never used survey meter.
'd he always surveyed prior to beginning adiog aphy even though did not survey or post boundaries.
said he did not post boundar es using barricades or signs NO O
B D C SUR IH APP V 0F F D FF DI CTO 0FF OF IN EST
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l because he had been ht that s up to the radiographer. M said H&G provided signs, but lwa left them in the tr k wit the two survey me provid y H&G.
aid when he performed radiography, sometime observe im a sometimes e was the darkroom.
He said nev left the job site when he was performing radio aphy, so h was available although not always observing him.
(
ecalled a second H&G job assignment, i when he Worked on a job p Farm gton, New Mexico, with' fromy&G's Houston office. I said at the beginning o this job, sometimes i
failed to survey, st t boundaries and signs, or wear al equi /ed osimet He said sometime in the darkroom while he performed diography, but never left the job site while s " shooting." Shortly aft e
b starte Joe ERRACE. H&G's i
fice anager,beganshowingupatthejobsite,Jan began using all l
dosimetry, surveying, posting, and complying with requ emen l
Although initially said " lots of guy " did at use dosimetry, he was only able to cite the two above incidants.
said he did not believe l
GIBSON was aware of these incidents because was o far away, and he provided all required equipment and expected his employees to se it.
said he did not believe Lloyd
. Man r H&G wa aware f actions or TERRACE was aware of actions.
s he never mentioned the radiographer' fa re to c ply with regulations to anyone.
Coordination with NRC Staff l
Richard LEONARDI. Radiation Specialist, NRC:RIV, conducted an inspection of I
H&G's Evanston. Wyoming, office the week of November 17, 1997.
At that time, l
l he learned the records had been sent to H&G's main office in Houston. Texas, l
and he was unable to review the Wyoming use records.
I LEONARDI conducted a follow-up inspection at H&G's Houston office on l
January 9, 1998 (Exhib 3).
cording to LEONARDI during that inspection.
l GIBSON said H&G mailed n exposure termination notification letter on l
July 28, 1997, but it returned undeliverable.
In addition. GIBSON provided a copy of a letter he sen to th NRC on September 23, 1997, which l
described H&G's attempt to provide with his exposure termination i
report (Exhibit 5).
According to L ONARD. this letter was not contained in NRC's docket file for H&G.
NO OR UL DI OSU ITH APP TAL F [EL FI t
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During his January 9,1998, inspection. LEONARDI reviewed H&G's Utilization Records, Source Records, Daily Radiation Job Sheets, and TLD/ Dosimeter i
Comparison Records for the radiography performed near Rawlins, Wyoming, in 1997. From a re iew these r
- s. LEONARDI determined that ad worked with and not in Wyoming. The records indicated at re ricted area boun ari were pos
, surveys were performed, and readings were recorded, which were consistent wit what uld be expected from routine surveys. There was a discrepancy between pocket dosimeter readings,iwhich indicated 72 mrem for October 12-1997 and his TLD recorded dose which indicated 'O' mrem for the entire month of t
1997.
LEONARDI stated, based on this difference, it was possible that ore his pocket dosimeter but not his ILD badge, However, d1tterences in is amount were inconclusive due to the short time period involved and the relative inaccuracy of pocket dosimeters.
During hi ins ion at H&G, LEONARDI also reviewed records, which#{
ndicat orked out of H&G's Farmington, New exico, office in b
he worked only in New Mexico (Exhibit 4).
Consequently, i
s work fel nder H&G's New Mexico license and not under NRC jurisdiction.
Documentation Review Letter from GIBSON to NRC. dated Seotember 23. 1997 (Exhibit 5)
This letter stated that H&G sent ermina ot'ce to him on em July 28, 1997, but it was returne undeli erable.
ent a letter to I
H&G dated September 16, 1997, requesting a copy o is r diation history, but provided no retcrn address.
Daily Radiation Job Sheets Various Dates (Exhibit 6)
These sheets reflect survey and dosimeter readings fo in 7 Rawlins, Wyoming, from October 14-26, 1996, and are si ed by I
i TLD/ Dosimeter Comparisons from October 11 to November 10. 1996 (Exhibit 7)
-This document reflects tha pocket dosimeter indicated 83 mrem for g{
this period, but his TLD in ated 0" mrem.
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Testimonv/ Evidence
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Interview o -
(Fxhibit 8) was interviewed on by 01:RIV, about his employment with G a d related the follow g informa on in substance:
said he has worked in radiog off and on since 1972.
He worked ut of H& 's South Carolina office from
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The time he worked an H&G ob W ming was r
d his helper on the Wyoming job as rimaril a " kid" ose name he cou not recall.
When asked if that was tated "yes."
recalled that he kept_all his dosimetry, includi his TLD, rate meter.
and pocket dosimeter, in his coat pockets in Wyoming.
emphatically I
stated that he always wore all his dosimetry during eve H&
b.
He always took his dosimetry from the truck, and when in o
, asked
'if he had his dosinetry before they left the truck.
said at irst e
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performed radiography shots, worked in the darkroom, ead the pocket ime rs and survey meters, and rec ed t results. After he trained in some areas of radiography, read his own pocket dosimeter nd re rded the result,
ormed s e-ra gr sh s, and developed some film in the darkroom.
said he never lef in the darkroom alone nor 1d he allow him t shoo alone.
i aid he always posted ea with signs and ropes, as required, even When h was working a said he always surveyed the area before every hot. He showe t
se a survey meter. and sometimes erformed the surveys.
said he completed all required survey
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l ter a pocket dosime r fo
, an the data recorded on e
s was l
truthful and accurate.
enied falsifying any data.
said H&G provided signs, ropes, a d tw fully charged and calibr ed vey meters on all trucks and expected the radiographer to use them.
aid was i
audited on one occasion, and the only problem identifie was t at he did not have the correct H&G Wyoming state license with him.
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Said he never worked with any other H&G radiographer. and he had no k'nowle.dge of. any problems at H&G.
He never heard any radiographer compl61n Case No. 4-97-064 11 l
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about H&G except to say they were overworked.
aid, in his opinion, F)b GIBSON believed in safety i?st, was conscienti s, atd H&G was better than most radiography companies.
Aaent's Analysis alleged H&G refused to provide him with his radiogr ex sure
' story. GIBSON showed he had at to provide this to so the allegation was unsubstantiated.
initially stated "1 s~
H&G q
radi sf led to wear dos try whe asked for specifics named
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only nd ta worked in New Mexico, and the recor reviewed indicated at ked in New Mexico, which is not under NRC's jurisdiction.
enie failing to survey post, or wear all required dosimetry, and st d
never falsified any records.
Records lfeview at H&G appeared to be completed correctly. Although a comparison of q
pocket dosimeter and TLD records indicates a possible discrepancy.
- he NR inspector wa h nable to draw a conclu on th the TLD was not used.
Consequently, llegations regarding ere not substantiated by testimony or ords.
Conclusions Based on the evidence developed during this investigation, testimony, and document review. the allegation that radiographer at H&G deliberately violated required radiography practices was not substantiated.
i TOT 0 PUB ( DIS OSU ITH0 PPRO 0F FI 0FFICE
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LIST OF EXHIBITS i
Exhibit No.
Description 1
Investigation Status Record, d ed Nove ber 12. 1997.
2 Report of Interview wit datedi(
n 3
Memorandum from LEONARDI to 01:RIV dated February 9, 1998.
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E-mail from LEON /RDI to 01:RIV. dated April 14. 1998.
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Letter from GIBSON to NRC dated September 23, 1997.
6 Daily Radiation Job Sheets. Various Dates.
7 TLD/ Dosimeter Comparisons from October 11. 1996, to November 10, 1997.
8 Report of Interview wit date
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