ML20335A256
| ML20335A256 | |
| Person / Time | |
|---|---|
| Site: | 03011772 |
| Issue date: | 12/03/2020 |
| From: | Michael Kunowski NRC/RGN-III |
| To: | Rogers T JAN X-ray Services |
| Craffey R | |
| References | |
| EA-20-140 IR 2020001 | |
| Download: ML20335A256 (3) | |
See also: IR 07200202/2000001
Text
December 3, 2020
Mr. Travis Rogers, President
JAN X-Ray Services, Inc.
8550 East Michigan Avenue
Parma, MI 49269
SUBJECT: NRC ROUTINE INSPECTION REPORT NO. 03011772/2020001(DNMS)
JAN X-RAY SERVICES, INC.
Dear Mr. Rogers:
On September 15 and 16, 2020, an inspector from the U.S. Nuclear Regulatory Commission
(NRC) conducted a routine inspection at your facility in Parma, Michigan, and at temporary job
sites of yours in Hemlock and Chesterfield, Michigan. The purpose of the inspection was to
review activities performed under your NRC license to ensure that activities were being
performed in accordance with NRC requirements. Mr. Ryan Craffey of my staff conducted a
final exit meeting by telephone with Mr. Timothy Frazee of your staff on November 9, 2020 to
discuss the inspection findings. This letter presents the results of the inspection.
During this inspection, the NRC staff examined activities conducted under your license related
to public health and safety. Additionally, the staff examined your compliance with the
Commissions rules and regulations as well as the conditions of your license. Within these
areas, the inspection consisted of selected examination of procedures and representative
records, observations of activities, and interviews with personnel.
Based on the results of this inspection, the NRC has determined that one Severity Level IV
violation of NRC requirements occurred. The violation was evaluated in accordance with the
NRC Enforcement Policy, which can be found on the NRCs website at
http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. The violation concerned
the failure to wear a personnel dosimeter during radiographic operations, as required by
Title 10 of the Code of Federal Regulations (CFR) Part 34.47(a), on two separate and limited
occasions since the last routine inspection.
Although the Enforcement Policy normally characterizes the failure to use personnel dosimeters
during radiographic operations as a Severity Level III violation, the NRC determines that this
violation is more appropriately characterized as a SLIV because: (1) you have an established
personnel monitoring program; (2) the radiographers failed to wear their personnel dosimeters
for only one radiographic exposure each; (3) the dosimeters fell off due to non-routine working
conditions; (4) each radiographer promptly identified and reported the matter to the radiation
safety staff on the day it occurred; (5) the dosimeters were promptly sent for processing after
the radiation safety staff was informed of the issue; and (6) your staff was still able to
reasonably estimate the dose of record for each radiographer using direct reading dosimeters.
Furthermore, the NRC determined that the violation met the following criteria from Section 2.3.2
of the Policy to be considered a Non-Cited Violation: (1) you identified the violation; (2) you
corrected or committed to correct the violation within a reasonable period of time; and (3) the
T. Rogers
2
violation was not considered repetitive or willful. Therefore, as a credit to your radiation safety
program in identifying and correcting such violations in a timely fashion, the NRC will not issue a
Notice of Violation on this matter.
The inspector determined that the root cause of the violation was an oversight by the
radiographers involved. The conditions of the job site appeared be a contributing factor, as the
need to climb over and under obstacles created increased opportunity for equipment to become
dislodged/detached from the body.
As corrective actions, on both occasions the staff involved promptly reported the fallen badges
and submitted them for processing. Your staff also requested to the dosimetry provider that the
reported dose be replaced with readings obtained from the radiographers direct reading
dosimeters. After the first occasion, your staff discussed the incident and best practices for
securing the badge with the radiographer involved. After the second occasion, you discussed
the incident and best practices with the radiographer involved and added the topic to the next
round of refresher safety training for radiographers and assistants.
The NRC has concluded that information regarding the reason for the violation, the corrective
actions taken and planned to correct the violation and prevent recurrence, and the date when
full compliance will be achieved is already adequately addressed on the docket in this letter.
Therefore, you are not required to respond to this letter unless the description herein does not
accurately reflect your corrective actions or your position. In that case, or if you choose to
provide additional information, you should follow the instructions specified in the enclosed
Notice.
In accordance with the NRCs Rules of Practice in 10 CFR 2.390, a copy of this letter and any
response you provide will be made available electronically for public inspection in the NRCs
Public Document Room or from the NRCs Agencywide Documents Access and Management
System (ADAMS), accessible from the NRCs website at http://www.nrc.gov/reading-
rm/adams.html. To the extent possible, any response should not include any personal privacy,
proprietary, or safeguards information so that it can be made publicly available without
redaction.
Please feel free to contact Mr. Craffey of my staff if you have any questions regarding this
inspection. Mr. Craffey can be reached at 630-829-9655 or Ryan.Craffey@nrc.gov.
Sincerely,
Michael Kunowski, Chief
Materials Inspection Branch
Division of Nuclear Materials Safety
Docket No. 030-11772
License No. 21-16560-01
cc: Timothy Frazee, Radiation Safety Officer
State of Michigan
Michael A. Kunowski
Digitally signed by Michael A.
Kunowski
Date: 2020.12.03 08:43:00 -06'00'
T. Rogers
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Letter to Travis Rogers from Michael Kunowski, dated December 3, 2020
SUBJECT: NRC ROUTINE INSPECTION REPORT NO. 03011772/2020001(DNMS)
JAN X-RAY SERVICES, INC.
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DATE
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12/03/20
11/30/20
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