Information Notice 1993-05, Locking of Radiography Exposure Devices: Difference between revisions

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| issue date = 01/14/1993
| issue date = 01/14/1993
| title = Locking of Radiography Exposure Devices
| title = Locking of Radiography Exposure Devices
| author name = Cunningham R E
| author name = Cunningham R
| author affiliation = NRC/NMSS/IMNS
| author affiliation = NRC/NMSS/IMNS
| addressee name =  
| addressee name =  
Line 15: Line 15:
| page count = 9
| page count = 9
}}
}}
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY
{{#Wiki_filter:UNITED STATES


COMMISSION
NUCLEAR REGULATORY COMMISSION


===OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS===
OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS
WASHINGTON, D.C. 20555 January 14, 1993 NRC INFORMATION


NOTICE NO. 93-05: LOCKING OF RADIOGRAPHY
WASHINGTON, D.C. 20555 January 14, 1993 NRC INFORMATION NOTICE NO. 93-05:     LOCKING OF RADIOGRAPHY EXPOSURE


EXPOSURE DEVICES
DEVICES


==Addressees==
==Addressees==
:
:
All Nuclear Regulatory
All Nuclear Regulatory Commission industrial radiography licensees
 
Commission
 
industrial
 
radiography
 
licensees


==Purpose==
==Purpose==
This information
This information notice is intended to: (a) alert licensees that the locking


notice is intended to: (a) alert licensees
mechanisms on certain industrial radiography exposure devices can be locked


that the locking mechanisms
with the sealed source in the exposed position; and (b) emphasize the


on certain industrial
importance of ensuring that the source is secure in a shielded position before


radiography
moving the device. We expect that licensees will review this notice, distribute it to responsible staff, and consider actions, if appropriate, to


exposure devices can be locked with the sealed source in the exposed position;
verify that the source is properly secured at the conclusion of radiographic
and (b) emphasize


the importance
operations. However, suggestions contained in this notice do not constitute


of ensuring that the source is secure in a shielded position before moving the device. We expect that licensees
any new NRC requirements, and no written response is required.


will review this notice, distribute
==Description of Circumstances==
Case 1: A radiographer was overexposed in an incident involving a


it to responsible
disconnected source when he failed to conduct a survey after each exposure.


staff, and consider actions, if appropriate, to verify that the source is properly secured at the conclusion
After investigating the incident, it was discovered that the radiographer had


of radiographic
approached the device without a survey instrument, locked the device, disassembled the source guide tube, and left the drive controls connected


operations.
before moving the device from one location to another. The radiographer had


However, suggestions
incorrectly assumed that in locking the exposure device, he had secured the


contained
source in a shielded position. In fact, the sealed source remained in the


in this notice do not constitute
guide tube because the pigtail had disconnected from the drive cable. The


any new NRC requirements, and no written response is required.Description
radiographer's error was further compounded when the drive cable was not


of Circumstances
removed before moving the device, which would have allowed him to identify the


Case 1: A radiographer
absence of the source pigtail within the shielded assembly.


was overexposed
Case 2: A radiographer was performing radiographic exposures of welds on a


in an incident involving
series of pipelines that were located approximately 6.1 meters (20 feet) above


a disconnected
ground. The radiographer used a 1.8-meter (6-foot) guide tube with collimator


source when he failed to conduct a survey after each exposure.After investigating
and a 7.6-meter (25-foot) control cable. The radiographer hung the device


the incident, it was discovered
from the pipeline to perform the work with the control cables hanging down to


that the radiographer
the ground. After an exposure, the radiographer retracted the source, placed


had approached
the control cables on the ground, and used a hydraulic lift to get to the


the device without a survey instrument, locked the device, disassembled
camera.


the source guide tube, and left the drive controls connected before moving the device from one location to another. The radiographer
9301080120        C      L4'6 fD


had incorrectly
fe                      -2?- 0A


assumed that in locking the exposure device, he had secured the source in a shielded position.
Ik


In fact, the sealed source remained in the guide tube because the pigtail had disconnected
Cct


from the drive cable. The radiographer's
IN 93-05 January 14, 1993 Because the camera was suspended above the lift, the radiographer


error was further compounded
the camera to reach the locking mechanism. He moved the camera        had to move


when the drive cable was not removed before moving the device, which would have allowed him to identify the absence of the source pigtail within the shielded assembly.Case 2: A radiographer
the control cables with his right hand and locking the camera      by  grasping


was performing
hand. He continued with his left hand to disconnect the guide  with  his  left


radiographic
camera. At this point, he noticed that the sealed source was      tube    from  the


exposures
approximately 10 centimeters (4 inches) from the camera port.    protruding


of welds on a series of pipelines
alarming ratemeter did not sound because it was not turned on. (Note: His


that were located approximately
of 10 CFR 34.33, which can result in a civil penalty, is addressed  This violation


6.1 meters (20 feet) above ground. The radiographer
Information Notice 91-49: "Enforcement of Safety Requirements          in


used a 1.8-meter
Radiographers").                                                 for


(6-foot) guide tube with collimator
Reenactments of the incident showed that when the radiographer


and a 7.6-meter
device, the crank handle could drag on the ground, exposing      turned the


(25-foot)
the
control cable. The radiographer


hung the device from the pipeline to perform the work with the control cables hanging down to the ground. After an exposure, the radiographer
The radiographer was then able to lock the device over the drive sealed source.


retracted
the sealed source protruding approximately 10 centimeters (4        cable, with


the source, placed the control cables on the ground, and used a hydraulic
inches).


lift to get to the camera.9301080120
Analysis of the locking mechanism after the event did not identify
L4'6 fD C fe -2?- 0A Ik Cct


IN 93-05 January 14, 1993 Because the camera was suspended
defects with the mechanism. Tests performed showed that the            any obvious


above the lift, the radiographer
still be locked with the source in the exposed position.      device      could


had to move the camera to reach the locking mechanism.
NRC Evaluation:
The findings in both of these cases raised concern among NRC


He moved the camera by grasping the control cables with his right hand and locking the camera with his left hand. He continued
certain conditions, radiographers could have false confidence staff that, under


with his left hand to disconnect
mechanisms. If exposure devices can lock when the source is in the locking


the guide tube from the camera. At this point, he noticed that the sealed source was protruding
shielded position, then radiographers could incorrectly believeoutside of the


approximately
protected from exposure when, in fact, the source is not in        that they are


10 centimeters
its


(4 inches) from the camera port. (Note: His alarming ratemeter
position. We are also concerned that exposure devices are moved fully shielded


did not sound because it was not turned on. This violation of 10 CFR 34.33, which can result in a civil penalty, is addressed
drive cables are still connected.                                   while the


in Information
To evaluate the effectiveness of the locking mechanism on


Notice 91-49: "Enforcement
radiography exposure


of Safety Requirements
devices and to determine whether radiographers commonly move


for Radiographers").
drive cables still connected, NRC inspectors observed licenseethe devices with


Reenactments
and interviewed radiography personnel. From the data collected,equipment tests


of the incident showed that when the radiographer
that a majority of exposure devices can be locked when the source we determined


turned the device, the crank handle could drag on the ground, exposing the sealed source.The radiographer
variety of positions, rather than only when the source pigtail        is in a


was then able to lock the device over the drive cable, with the sealed source protruding
seated, with the source in the fully shielded position. Many      is  properly


approximately
include a "locking ball," designed to prevent the source from source pigtails


10 centimeters
when the lock is engaged; however, our observations show that moving forward


(4 inches).Analysis of the locking mechanism
devices may be locked both when the source is not fully retractedsome exposure


after the event did not identify any obvious defects with the mechanism.
the drive cable is seated under the locking pin, thereby circumventing and while


Tests performed
locking-ball feature. This may result in a source being positioned            the


showed that the device could still be locked with the source in the exposed position.NRC Evaluation:
is not fully shielded.                                                   where    it
The findings in both of these cases raised concern among NRC staff that, under certain conditions, radiographers


could have false confidence
Many radiographers acknowledged to NRC inspectors that they


in the locking mechanisms.
often leave drive


If exposure devices can lock when the source is outside of the shielded position, then radiographers
cables connected when moving an exposure device from one location


could incorrectly
at temporary job sites. In addition, some acknowledged leaving        to another


believe that they are protected
connected. One licensee stated that this practice had resulted      the  guide tube


from exposure when, in fact, the source is not in its fully shielded position.
being forced out of the exposure device while the device was        in a  source


We are also concerned
carried to a new


that exposure devices are moved while the drive cables are still connected.
location at a temporary job site. This licensee noted that


To evaluate the effectiveness
the device was


of the locking mechanism
locked at the time, but the source had not been fully retracted


on radiography
the device.                                                        before locking


exposure devices and to determine
Attachment 1 IN 93-05 January 14, 1993 LIST OF RECENTLY ISSUED


whether radiographers
NMSS INFORMATION NOTICES


commonly move the devices with drive cables still connected, NRC inspectors
Information                                Date of


observed licensee equipment
Notice No.            Subject              Issuance    Issued to


tests and interviewed
93-04        Investigation and Re-          01/07/93  All U.S. Nuclear Regulatory


radiography
porting of Misadministra-                  Commission medical


personnel.
tions by the Radiation                      licensees.


===From the data collected, we determined===
Safety Officer
that a majority of exposure devices can be locked when the source is in a variety of positions, rather than only when the source pigtail is properly seated, with the source in the fully shielded position.


Many source pigtails include a "locking ball," designed to prevent the source from moving forward when the lock is engaged; however, our observations
93-03        Recent Revision to              01/05/93  All byproduct, source, and


show that some exposure devices may be locked both when the source is not fully retracted
10 CFR Part 20 and                          special nuclear material


and while the drive cable is seated under the locking pin, thereby circumventing
Change of Implementa-                      licensees.


the locking-ball
tion Date to


feature. This may result in a source being positioned
January 1, 1994
92-84        Release of Patients            12/17/92  All Nuclear Regulatory Com- Treated with Temporary                    mission Medical Licensees.


where it is not fully shielded.Many radiographers
Implants


acknowledged
92-72        Employee Training              10/18/92  All U.S. Nuclear Regulatory


to NRC inspectors
and Shipper Registra-                      Commission Licensees.


that they often leave drive cables connected
tion Requirements for


when moving an exposure device from one location to another at temporary
Transporting Radioactive


job sites. In addition, some acknowledged
Materials


leaving the guide tube connected.
92-62        Emergency Response            08/24/92    All U.S. Nuclear Regulatory


One licensee stated that this practice had resulted in a source being forced out of the exposure device while the device was carried to a new location at a temporary
Information Require-                      Commission Licensees.


job site. This licensee noted that the device was locked at the time, but the source had not been fully retracted
ments for Radioactive


before locking the device.
Material Shipments


Attachment
92-58        Uranium Hexafluoride          08/12/92    All fuel cycle licensees.


1 IN 93-05 January 14, 1993 LIST OF RECENTLY ISSUED NMSS INFORMATION
Cylinders - Deviations


NOTICES Information
in Coupling Welds


Date of Notice No. Subject Issuance Issued to 93-04 93-03 92-84 92-72 Investigation
92-38        Implementation Date for        05/12/92   All holders of OLs or CPs


and Re-porting of Misadministra- tions by the Radiation Safety Officer Recent Revision to 10 CFR Part 20 and Change of Implementa- tion Date to January 1, 1994 Release of Patients Treated with Temporary Implants Employee Training and Shipper Registra-tion Requirements
the Revision to the EPA                    for nuclear power reactors, Manual of Protective                      non-power reactors and


for Transporting
Action Guides and Pro-                    materials licensees author- tective Actions for                       ized to possess large


Radioactive
Nuclear Incidents                          quantities of radioactive


Materials Emergency
material.


Response Information
92-37        Implementation of the          05/08/92    All Nuclear Regulatory


Require-ments for Radioactive
Deliberate Misconduct Rule                Commission Licensees.


===Material Shipments Uranium Hexafluoride===
Attachment 2 IN 93-05 January 14, 1993 LIST OF RECENTLY ISSUED
Cylinders


-Deviations
NRC INFORMATION NOTICES


in Coupling Welds Implementation
Information                                  Date of


Date for the Revision to the EPA Manual of Protective
Notice No.            Subject                Issuance  Issued to


Action Guides and Pro-tective Actions for Nuclear Incidents Implementation
93-04          Investigation and Re-         01/07/93  All U.S. Nuclear Regulatory


of the Deliberate
porting of Misadministra-                Commission medical


Misconduct
tions by the Radiation                    licensees.


Rule 01/07/93 01/05/93 12/17/92 10/18/92 08/24/92 08/12/92 05/12/92 05/08/92 92-62 All U.S. Nuclear Regulatory
Safety Officer


Commission
93-03          Recent Revision to            01/05/93  All byproduct, source, and


medical licensees.
10 CFR Part 20 and                        special nuclear material


All byproduct, source, and special nuclear material licensees.
Change of Implementa-                    licensees.


All Nuclear Regulatory
tion Date to


Com-mission Medical Licensees.
January 1, 1994
93-02          Malfunction of A Pres-        01/04/93  All holders of OLs or CPs


===All U.S. Nuclear Regulatory===
surizer Code Safety                      for nuclear power reactors.
Commission


Licensees.
Valve


===All U.S. Nuclear Regulatory===
93-01          Accuracy of Motor-            01/04/93  All holders of OLs or CPs
Commission


Licensees.
Operated Valve Diagnostic                for nuclear power reactors.


All fuel cycle licensees.
Equipment Manufactures


All holders of OLs or CPs for nuclear power reactors, non-power
by Liberty Technologies
 
reactors and materials
 
licensees
 
author-ized to possess large quantities
 
of radioactive
 
material.All Nuclear Regulatory


Commission
92-86          Unexpected Restriction        12/24/92  All holders of OLs or CPs


Licensees.
to Thermal Growth of                      for nuclear power reactors.


92-58 92-38 92-37 Attachment
Reactor Coolant Piping


2 IN 93-05 January 14, 1993 LIST OF RECENTLY ISSUED NRC INFORMATION
92-85          Potential Failures of          12/23/92  All holders of OLs or CPs


NOTICES Information
Emergency Core Cooling                    for nuclear power reactors.


Date of Notice No. Subject Issuance Issued to 93-04 93-03 93-02 Investigation
Systems Caused by


and Re-porting of Misadministra- tions by the Radiation Safety Officer Recent Revision to 10 CFR Part 20 and Change of Implementa- tion Date to January 1, 1994 Malfunction
Foreign Material Blockage


of A Pres-surizer Code Safety Valve Accuracy of Motor-Operated Valve Diagnostic
92-84          Release of Patients            12/17/92  All Nuclear Regulatory


Equipment
Treated with Temporary                    Commission Medical Licensees
 
===Manufactures===
by Liberty Technologies


Unexpected
Implants


Restriction
88-23,        Potential for Gas              12/18/92  All holders of OLs or CPs


to Thermal Growth of Reactor Coolant Piping Potential
Supp. 4        Binding of High-Pres-                    for nuclear power reactors.


Failures of Emergency
sure Safety Injection


Core Cooling Systems Caused by Foreign Material Blockage 93-01 01/07/93 01/05/93 01/04/93 01/04/93 12/24/92 12/23/92 12/17/92 12/18/92 All U.S. Nuclear Regulatory
Pumps during A Design


Commission
Basis Accident


medical licensees.
OL = Operating License


All byproduct, source, and special nuclear material licensees.
CP = Construction Permit


All holders of OLs or CPs for nuclear power reactors.All holders of OLs or CPs for nuclear power reactors.All holders of OLs or CPs for nuclear power reactors.All holders of OLs or CPs for nuclear power reactors.All Nuclear Regulatory
K)
                                                            IN 93-05 January 14, 1993 Discussion:
All licensees are reminded of the importance of ensuring that the sources used


Commission
in radiography exposure devices are properly secured and fully shielded before


Medical Licensees All holders of OLs or CPs for nuclear power reactors.92-86 92-85 92-84 Release of Patients Treated with Temporary Implants 88-23, Supp. 4 Potential
moving the device. Radiographic exposure devices manufactured and new


for Gas Binding of High-Pres- sure Safety Injection Pumps during A Design Basis Accident OL = Operating
equipment acquired by licensees after January 10, 1992, must meet new design


License CP = Construction
requirements in 10 CFR 34.20. These require that, among other safety


Permit
features, the device must automatically secure the source assembly when it is


K)IN 93-05 January 14, 1993 Discussion:
cranked back into the fully shielded position within the device. However, many radiographic exposure devices currently in use do not include the newer
All licensees


are reminded of the importance
safety features, and licensees are not required to use devices that comply


of ensuring that the sources used in radiography
with 10 CFR 34.20 requirements until after January 10, 1996. Certaih


exposure devices are properly secured and fully shielded before moving the device. Radiographic
radiogiraphv exposure devices still in use today may be able to be locked with


exposure devices manufactured
the source in the exposed position.


and new equipment
Experience has shown that when an older exposure device is in use, the locking


acquired by licensees
mechanism is not an indicator that the source is fully retracted and secured.


after January 10, 1992, must meet new design requirements
The use of engineered safety features, like the lock mechanism, MUST BE


in 10 CFR 34.20. These require that, among other safety features, the device must automatically
coupled with a proper survey (10 CFR 34.43) AND use of an alarm ratemeter


secure the source assembly when it is cranked back into the fully shielded position within the device. However, many radiographic
(10 CFR 34.33), to prevent the unintentional exposure of personnel. Surveys


exposure devices currently
must be sufficient to detect a change in exposure readings taken at the source


in use do not include the newer safety features, and licensees
tube outlet, to determine whether the source is fully retracted to a shielded


are not required to use devices that comply with 10 CFR 34.20 requirements
position (10 CFR 34.43). Alarm ratemeters serve as an additional warning


until after January 10, 1996. Certaih radiogiraphv
method. Additionally, it is recommended that radiographers disassemble the


exposure devices still in use today may be able to be locked with the source in the exposed position.Experience
source guide tube, remove the drive controls, and install the safety plugs or


has shown that when an older exposure device is in use, the locking mechanism
covers, before moving the radiography exposure device to another location.


is not an indicator
The failure to do so has been identified as a contributing factor in the


that the source is fully retracted
unintended exposure of personnel, as well as in incidents where radiographers


and secured.The use of engineered
failed to notice that the source was not retracted into the device.


safety features, like the lock mechanism, MUST BE coupled with a proper survey (10 CFR 34.43) AND use of an alarm ratemeter (10 CFR 34.33), to prevent the unintentional
Sealed sources for radiography are capable of delivering significant exposures


exposure of personnel.
to radiography personnel and to members of the general public, when handled by


Surveys must be sufficient
individuals who are inattentive to radiation safety procedures. It is


to detect a change in exposure readings taken at the source tube outlet, to determine
recommended that all workers understand the consequences of improperly


whether the source is fully retracted
handling radiographic devices, and that workers be encouraged to use necessary


to a shielded position (10 CFR 34.43). Alarm ratemeters
precautions when working with these devices.


serve as an additional
IN 93-05 January 14, 1993 No written response is required by this information notice. If you have any


warning method. Additionally, it is recommended
questions about this matter, please contact the appropriate NRC regional


that radiographers
office or the personnel listed below.


disassemble
( Richard  E. Cunningham, Director


the source guide tube, remove the drive controls, and install the safety plugs or covers, before moving the radiography
Division Industrial and


exposure device to another location.The failure to do so has been identified
Medical Nuclear Safety, NMSS


as a contributing
Technical contacts:  Gary Shear, Region III


factor in the unintended
(708) 790-5620
                    Charles Cain, Region IV


exposure of personnel, as well as in incidents
(817) 860-8186 Scott Moore, NMSS


where radiographers
(301) 504-2514 Attachments:.


failed to notice that the source was not retracted
1. List of Recently Issued NMSS Information Notices


into the device.Sealed sources for radiography
2. List of Recently Issued NRC Information Notices


are capable of delivering
IN 93-05 January 14, 1993 No written response is required by this information notice. If you have any


significant
questions about this matter, please contact the appropriate NRC regional


exposures to radiography
office or the personnel listed below.


personnel
Richard E. Cunningham, Director


and to members of the general public, when handled by individuals
Division Industrial and


who are inattentive
Medical Nuclear Safety, NMSS


to radiation
Technical contacts:    Gary Shear, Region III


safety procedures.
(708) 790-5620
                                Charles Cain, Region IV


It is recommended
(817) 860-8186 Scott Moore, NMSS


that all workers understand
(301) 504-2514 Attachments:
          1. List of Recently Issued NMSS Information Notices


the consequences
2. List of Recently Issued NRC Information Notices


of improperly
* =  see Drevious concurrence


handling radiographic
OFC      IMOB    I E      NMSS        I


devices, and that workers be encouraged
N        IMOB        EIMABe          n


to use necessary precautions
NAME  *SMoore/sm/11        *EKraus              *CJones            *JGlenn


when working with these devices.
DATE      11/30/92          10/19/92            12/08/92            12/09/92 OFC        SCDB  I  E        IMOB                IMOB    l El      IMNS        IMNS


IN 93-05 January 14, 1993 No written response is required by this information
NAME      *CHaughney          *KRamsey            *FCombs        *JGreeves    *RECunningham


notice.questions
DATE        12/10/92    1      01/05/93    1      12/08/92        01/06/93        01/07/93 C: COVER          E: COVER & ENCL.         N:  NO COPY


about this matter, please contact the appropriate
OFFICIAL RECORD COPY:
DOCUMENT NAME: 93-05.IN


office or the personnel
IN 93- January , 1993 No written response is required by this information notice. If you have any


listed below.If you have any NRC regional ( Richard E. Cunningham, Director Division Industrial
questions about this matter, please contact the appropriate NRC regional


and Medical Nuclear Safety, NMSS Gary Shear, Region III (708) 790-5620 Technical
office or the personnel listed below.


contacts: Charles Cain, Region IV (817) 860-8186 Scott Moore, NMSS (301) 504-2514 Attachments:.
Richard E. Cunningham, Director


1. List of Recently 2. List of Recently Issued NMSS Information
Division Industrial and


Notices Issued NRC Information
Medical Nuclear Safety, NMSS


Notices
Technical Contacts:                Gary Shear, Region III


IN 93-05 January 14, 1993 No written response is required by this information
708-790-562C


notice. If you have any questions
Charles Cain, Region IV


about this matter, please contact the appropriate
817-860-8186 Scott Moore, NMSS


NRC regional office or the personnel
301-504-2514 Attachments:
            1. List of Recently Issued NMSS Information Notices


listed below.Richard E. Cunningham, Director Division Industrial
2. List of Recently Issued NRC Information Notices


and Medical Nuclear Safety, NMSS Technical
*  - caP  nyVauiniiC      anlnlnrranra


contacts: Gary Shear, Region III (708) 790-5620 Charles Cain, Region IV (817) 860-8186 Scott Moore, NMSS (301) 504-2514 Attachments:
- F    Fe y 9-   .          ..                                       _
1. List of Recently 2. List of Recently Issued NMSS Information
  OFC          IMOB        I E        NMSS     I  Nj        IMOB        I E        IMAB        l


Notices Issued NRC Information
NAME      *SMoore/sm/l1                *EKraus                  *CJones                  *JGlenn


Notices* = see Drevious concurrence
nATr


OFC IMOB I E NMSS I N IMOB EIMABe n NAME *SMoore/sm/11
Unsu    I   11 12n iog                IllnQ/I2 II-IU
*EKraus *CJones *JGlenn DATE 11/30/92 10/19/92 12/08/92 12/09/92 OFC SCDB I E IMOB IMOB l El IMNS IMNS NAME *CHaughney


*KRamsey *FCombs *JGreeves
12/08/92
                                                                - ~ - ~ -v-S ~  ~      12/09/92
                                                                                          -  -r~
  OFC          SCDB          I E          IMOB      ,            IM0B      I E        IMNS            _    NS


*RECunningham
NAME        *CHaughney                    KRamsey K 4            *FCombs                    y


DATE 12/10/92 1 01/05/93 1 12/08/92 01/06/93 01/07/93 C: COVER E: COVER & ENCL.N: NO COPY OFFICIAL RECORD COPY: 93-05.IN DOCUMENT NAME:
Aves                  ham
IN 93-January , 1993 No written response is required by this information


notice. If you have any questions
DATE          12/10/92                    I/        3 ,f


about this matter, please contact the appropriate
E 91q            12/8/92        ____I/        3 ___ I___ /    a :_I


NRC regional office or the personnel
C:  COVER              E:  COVER & LNCL.            N:    NU WLI


listed below.Richard E. Cunningham, Director Division Industrial
OFFICIAL RECORD COPY: G:LOCKING.SWM


and Medical Nuclear Safety, NMSS Technical
IN 92- December , 1992 No written response is required by this information notice. If you have any


Contacts: Gary Shear, 708-790-562C
questions about this matter, please contact the appropriate NRC regional


Region III Charles Cain, Region IV 817-860-8186 Scott Moore, NMSS 301-504-2514 Attachments:
office or the personnel listed below.
1. List of Recently 2. List of Recently Issued NMSS Information


Notices Issued NRC Information
Richard E. Cunningham, Director


Notices* -caP nyVauiniiC
Division Industrial and


anlnlnrranra
Medical Nuclear Safety, NMSS


-Fe F 9- y ... _OFC IMOB I E NMSS I Nj IMOB I E IMAB lNAME *SMoore/sm/l1
Technical Contacts:              Gary Shear, Region III
*EKraus *CJones *JGlenn nATr IllnQ/I2 1 1 12n iog 12/08/92 12/09/92 Unsu I II-IU ---v -S ~ ~ ~ ~ --r~OFC SCDB I E IMOB , IM0B I E IMNS _ NS NAME *CHaughney


KRamsey K 4 *FCombs y Aves ham DATE 12/10/92 I/ E 91q 3 ,f 12/8/92 I / ____ 3 I_ _ / __ __ a :_ I C: COVER E: COVER & LNCL.N: NU WLI OFFICIAL RECORD COPY: G:LOCKING.SWM
708-790-5620
                                  \m      Charles Cain, Region IV


IN 92-December , 1992 No written response is required by this information
817-860-8186 cott Moore, NMSS


notice.questions
01-504-2514 Attachments:
          1. List of Recently Issued NHSS Information Notices


about this matter, please contact the appropriate
2. List of Recently Issued NR                nformation Notices


office or the personnel
OFC          HQ      IEI          M A          INI    -AIEI                      AB    IA


listed below.If you have any NRC regional Richard E. Cunningham, Director Division Industrial
NAME            ro      I    _I ______I____/_                          I_____
  DATE    ii/o30/92                10/19/92              /A/I/92\          6  I,9I1/92 OFC            SCDB                  IM                    Io                  I  MNS


and Medical Nuclear Safety, NMSS Technical
IIi        IMNS


Contacts:
NAME          CH ge                    KRamsey          =      xJGreeves
Gary Shear, Region III 708-790-5620
\m Charles Cain, Region IV 817-860-8186 cott Moore, NMSS 01-504-2514 Attachments:
1. List of Recently Issued NHSS Information


Notices 2. List of Recently Issued NR nformation
Uo    X                    RECunninghim


Notices OFC HQ IEI M A INI -AIEI AB IA NAME ro I _I ______I____/_
DATE      It/la    /92     j9/             /92           81I                    /_/92        _2
I_____DATE ii /o30/92 10/19/92/A/ I/92\6 I,9I1/92 OFC SCDB IM Io IIi I MNS IMNS NAME CH ge KRamsey = Uo X xJGreeves
                                                                                                  //92_
C:  COVER          E:  COVER & ENCL.              N:  NO COPY


===RECunninghim===
OFFICIAL RECORD COPY: G:LOCKING.SWM}}
DATE It/la /92 j9/ /92 81I _2 /_/92 //92_C: COVER E: COVER & ENCL.N: NO COPY OFFICIAL RECORD COPY: G:LOCKING.SWM}}


{{Information notice-Nav}}
{{Information notice-Nav}}

Latest revision as of 04:19, 24 November 2019

Locking of Radiography Exposure Devices
ML031080041
Person / Time
Site: Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Mcguire, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Kewaunee, Catawba, Harris, Wolf Creek, Saint Lucie, Point Beach, Oyster Creek, Watts Bar, Hope Creek, Grand Gulf, Cooper, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Three Mile Island, Braidwood, Susquehanna, Summer, Prairie Island, Columbia, Seabrook, Brunswick, Surry, Limerick, North Anna, Turkey Point, River Bend, Vermont Yankee, Crystal River, Haddam Neck, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Duane Arnold, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Yankee Rowe, Maine Yankee, Quad Cities, Humboldt Bay, La Crosse, Big Rock Point, Rancho Seco, Zion, Midland, Bellefonte, Fort Calhoun, FitzPatrick, McGuire, LaSalle, Fort Saint Vrain, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant  Entergy icon.png
Issue date: 01/14/1993
From: Cunningham R
NRC/NMSS/IMNS
To:
References
FOIA/PA-2015-0150 IN-93-005, NUDOCS 9301080120
Download: ML031080041 (9)
v • d • e


UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS

WASHINGTON, D.C. 20555 January 14, 1993 NRC INFORMATION NOTICE NO. 93-05: LOCKING OF RADIOGRAPHY EXPOSURE

DEVICES

Addressees

All Nuclear Regulatory Commission industrial radiography licensees

Purpose

This information notice is intended to: (a) alert licensees that the locking

mechanisms on certain industrial radiography exposure devices can be locked

with the sealed source in the exposed position; and (b) emphasize the

importance of ensuring that the source is secure in a shielded position before

moving the device. We expect that licensees will review this notice, distribute it to responsible staff, and consider actions, if appropriate, to

verify that the source is properly secured at the conclusion of radiographic

operations. However, suggestions contained in this notice do not constitute

any new NRC requirements, and no written response is required.

Description of Circumstances

Case 1: A radiographer was overexposed in an incident involving a

disconnected source when he failed to conduct a survey after each exposure.

After investigating the incident, it was discovered that the radiographer had

approached the device without a survey instrument, locked the device, disassembled the source guide tube, and left the drive controls connected

before moving the device from one location to another. The radiographer had

incorrectly assumed that in locking the exposure device, he had secured the

source in a shielded position. In fact, the sealed source remained in the

guide tube because the pigtail had disconnected from the drive cable. The

radiographer's error was further compounded when the drive cable was not

removed before moving the device, which would have allowed him to identify the

absence of the source pigtail within the shielded assembly.

Case 2: A radiographer was performing radiographic exposures of welds on a

series of pipelines that were located approximately 6.1 meters (20 feet) above

ground. The radiographer used a 1.8-meter (6-foot) guide tube with collimator

and a 7.6-meter (25-foot) control cable. The radiographer hung the device

from the pipeline to perform the work with the control cables hanging down to

the ground. After an exposure, the radiographer retracted the source, placed

the control cables on the ground, and used a hydraulic lift to get to the

camera.

9301080120 C L4'6 fD

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Ik

Cct

IN 93-05 January 14, 1993 Because the camera was suspended above the lift, the radiographer

the camera to reach the locking mechanism. He moved the camera had to move

the control cables with his right hand and locking the camera by grasping

hand. He continued with his left hand to disconnect the guide with his left

camera. At this point, he noticed that the sealed source was tube from the

approximately 10 centimeters (4 inches) from the camera port. protruding

alarming ratemeter did not sound because it was not turned on. (Note: His

of 10 CFR 34.33, which can result in a civil penalty, is addressed This violation

Information Notice 91-49: "Enforcement of Safety Requirements in

Radiographers"). for

Reenactments of the incident showed that when the radiographer

device, the crank handle could drag on the ground, exposing turned the

the

The radiographer was then able to lock the device over the drive sealed source.

the sealed source protruding approximately 10 centimeters (4 cable, with

inches).

Analysis of the locking mechanism after the event did not identify

defects with the mechanism. Tests performed showed that the any obvious

still be locked with the source in the exposed position. device could

NRC Evaluation:

The findings in both of these cases raised concern among NRC

certain conditions, radiographers could have false confidence staff that, under

mechanisms. If exposure devices can lock when the source is in the locking

shielded position, then radiographers could incorrectly believeoutside of the

protected from exposure when, in fact, the source is not in that they are

its

position. We are also concerned that exposure devices are moved fully shielded

drive cables are still connected. while the

To evaluate the effectiveness of the locking mechanism on

radiography exposure

devices and to determine whether radiographers commonly move

drive cables still connected, NRC inspectors observed licenseethe devices with

and interviewed radiography personnel. From the data collected,equipment tests

that a majority of exposure devices can be locked when the source we determined

variety of positions, rather than only when the source pigtail is in a

seated, with the source in the fully shielded position. Many is properly

include a "locking ball," designed to prevent the source from source pigtails

when the lock is engaged; however, our observations show that moving forward

devices may be locked both when the source is not fully retractedsome exposure

the drive cable is seated under the locking pin, thereby circumventing and while

locking-ball feature. This may result in a source being positioned the

is not fully shielded. where it

Many radiographers acknowledged to NRC inspectors that they

often leave drive

cables connected when moving an exposure device from one location

at temporary job sites. In addition, some acknowledged leaving to another

connected. One licensee stated that this practice had resulted the guide tube

being forced out of the exposure device while the device was in a source

carried to a new

location at a temporary job site. This licensee noted that

the device was

locked at the time, but the source had not been fully retracted

the device. before locking

Attachment 1 IN 93-05 January 14, 1993 LIST OF RECENTLY ISSUED

NMSS INFORMATION NOTICES

Information Date of

Notice No. Subject Issuance Issued to

93-04 Investigation and Re- 01/07/93 All U.S. Nuclear Regulatory

porting of Misadministra- Commission medical

tions by the Radiation licensees.

Safety Officer

93-03 Recent Revision to 01/05/93 All byproduct, source, and

10 CFR Part 20 and special nuclear material

Change of Implementa- licensees.

tion Date to

January 1, 1994

92-84 Release of Patients 12/17/92 All Nuclear Regulatory Com- Treated with Temporary mission Medical Licensees.

Implants

92-72 Employee Training 10/18/92 All U.S. Nuclear Regulatory

and Shipper Registra- Commission Licensees.

tion Requirements for

Transporting Radioactive

Materials

92-62 Emergency Response 08/24/92 All U.S. Nuclear Regulatory

Information Require- Commission Licensees.

ments for Radioactive

Material Shipments

92-58 Uranium Hexafluoride 08/12/92 All fuel cycle licensees.

Cylinders - Deviations

in Coupling Welds

92-38 Implementation Date for 05/12/92 All holders of OLs or CPs

the Revision to the EPA for nuclear power reactors, Manual of Protective non-power reactors and

Action Guides and Pro- materials licensees author- tective Actions for ized to possess large

Nuclear Incidents quantities of radioactive

material.

92-37 Implementation of the 05/08/92 All Nuclear Regulatory

Deliberate Misconduct Rule Commission Licensees.

Attachment 2 IN 93-05 January 14, 1993 LIST OF RECENTLY ISSUED

NRC INFORMATION NOTICES

Information Date of

Notice No. Subject Issuance Issued to

93-04 Investigation and Re- 01/07/93 All U.S. Nuclear Regulatory

porting of Misadministra- Commission medical

tions by the Radiation licensees.

Safety Officer

93-03 Recent Revision to 01/05/93 All byproduct, source, and

10 CFR Part 20 and special nuclear material

Change of Implementa- licensees.

tion Date to

January 1, 1994

93-02 Malfunction of A Pres- 01/04/93 All holders of OLs or CPs

surizer Code Safety for nuclear power reactors.

Valve

93-01 Accuracy of Motor- 01/04/93 All holders of OLs or CPs

Operated Valve Diagnostic for nuclear power reactors.

Equipment Manufactures

by Liberty Technologies

92-86 Unexpected Restriction 12/24/92 All holders of OLs or CPs

to Thermal Growth of for nuclear power reactors.

Reactor Coolant Piping

92-85 Potential Failures of 12/23/92 All holders of OLs or CPs

Emergency Core Cooling for nuclear power reactors.

Systems Caused by

Foreign Material Blockage

92-84 Release of Patients 12/17/92 All Nuclear Regulatory

Treated with Temporary Commission Medical Licensees

Implants

88-23, Potential for Gas 12/18/92 All holders of OLs or CPs

Supp. 4 Binding of High-Pres- for nuclear power reactors.

sure Safety Injection

Pumps during A Design

Basis Accident

OL = Operating License

CP = Construction Permit

K)

IN 93-05 January 14, 1993 Discussion:

All licensees are reminded of the importance of ensuring that the sources used

in radiography exposure devices are properly secured and fully shielded before

moving the device. Radiographic exposure devices manufactured and new

equipment acquired by licensees after January 10, 1992, must meet new design

requirements in 10 CFR 34.20. These require that, among other safety

features, the device must automatically secure the source assembly when it is

cranked back into the fully shielded position within the device. However, many radiographic exposure devices currently in use do not include the newer

safety features, and licensees are not required to use devices that comply

with 10 CFR 34.20 requirements until after January 10, 1996. Certaih

radiogiraphv exposure devices still in use today may be able to be locked with

the source in the exposed position.

Experience has shown that when an older exposure device is in use, the locking

mechanism is not an indicator that the source is fully retracted and secured.

The use of engineered safety features, like the lock mechanism, MUST BE

coupled with a proper survey (10 CFR 34.43) AND use of an alarm ratemeter

(10 CFR 34.33), to prevent the unintentional exposure of personnel. Surveys

must be sufficient to detect a change in exposure readings taken at the source

tube outlet, to determine whether the source is fully retracted to a shielded

position (10 CFR 34.43). Alarm ratemeters serve as an additional warning

method. Additionally, it is recommended that radiographers disassemble the

source guide tube, remove the drive controls, and install the safety plugs or

covers, before moving the radiography exposure device to another location.

The failure to do so has been identified as a contributing factor in the

unintended exposure of personnel, as well as in incidents where radiographers

failed to notice that the source was not retracted into the device.

Sealed sources for radiography are capable of delivering significant exposures

to radiography personnel and to members of the general public, when handled by

individuals who are inattentive to radiation safety procedures. It is

recommended that all workers understand the consequences of improperly

handling radiographic devices, and that workers be encouraged to use necessary

precautions when working with these devices.

IN 93-05 January 14, 1993 No written response is required by this information notice. If you have any

questions about this matter, please contact the appropriate NRC regional

office or the personnel listed below.

( Richard E. Cunningham, Director

Division Industrial and

Medical Nuclear Safety, NMSS

Technical contacts: Gary Shear, Region III

(708) 790-5620

Charles Cain, Region IV

(817) 860-8186 Scott Moore, NMSS

(301) 504-2514 Attachments:.

1. List of Recently Issued NMSS Information Notices

2. List of Recently Issued NRC Information Notices

IN 93-05 January 14, 1993 No written response is required by this information notice. If you have any

questions about this matter, please contact the appropriate NRC regional

office or the personnel listed below.

Richard E. Cunningham, Director

Division Industrial and

Medical Nuclear Safety, NMSS

Technical contacts: Gary Shear, Region III

(708) 790-5620

Charles Cain, Region IV

(817) 860-8186 Scott Moore, NMSS

(301) 504-2514 Attachments:

1. List of Recently Issued NMSS Information Notices

2. List of Recently Issued NRC Information Notices

  • = see Drevious concurrence

OFC IMOB I E NMSS I

N IMOB EIMABe n

NAME *SMoore/sm/11 *EKraus *CJones *JGlenn

DATE 11/30/92 10/19/92 12/08/92 12/09/92 OFC SCDB I E IMOB IMOB l El IMNS IMNS

NAME *CHaughney *KRamsey *FCombs *JGreeves *RECunningham

DATE 12/10/92 1 01/05/93 1 12/08/92 01/06/93 01/07/93 C: COVER E: COVER & ENCL. N: NO COPY

OFFICIAL RECORD COPY:

DOCUMENT NAME: 93-05.IN

IN 93- January , 1993 No written response is required by this information notice. If you have any

questions about this matter, please contact the appropriate NRC regional

office or the personnel listed below.

Richard E. Cunningham, Director

Division Industrial and

Medical Nuclear Safety, NMSS

Technical Contacts: Gary Shear, Region III

708-790-562C

Charles Cain, Region IV

817-860-8186 Scott Moore, NMSS

301-504-2514 Attachments:

1. List of Recently Issued NMSS Information Notices

2. List of Recently Issued NRC Information Notices

  • - caP nyVauiniiC anlnlnrranra

- F Fe y 9- . .. _

OFC IMOB I E NMSS I Nj IMOB I E IMAB l

NAME *SMoore/sm/l1 *EKraus *CJones *JGlenn

nATr

Unsu I 11 12n iog IllnQ/I2 II-IU

12/08/92

- ~ - ~ -v-S ~ ~ 12/09/92

- -r~

OFC SCDB I E IMOB , IM0B I E IMNS _ NS

NAME *CHaughney KRamsey K 4 *FCombs y

Aves ham

DATE 12/10/92 I/ 3 ,f

E 91q 12/8/92 ____I/ 3 ___ I___ / a :_I

C: COVER E: COVER & LNCL. N: NU WLI

OFFICIAL RECORD COPY: G:LOCKING.SWM

IN 92- December , 1992 No written response is required by this information notice. If you have any

questions about this matter, please contact the appropriate NRC regional

office or the personnel listed below.

Richard E. Cunningham, Director

Division Industrial and

Medical Nuclear Safety, NMSS

Technical Contacts: Gary Shear, Region III

708-790-5620

\m Charles Cain, Region IV

817-860-8186 cott Moore, NMSS

01-504-2514 Attachments:

1. List of Recently Issued NHSS Information Notices

2. List of Recently Issued NR nformation Notices

OFC HQ IEI M A INI -AIEI AB IA

NAME ro I _I ______I____/_ I_____

DATE ii/o30/92 10/19/92 /A/I/92\ 6 I,9I1/92 OFC SCDB IM Io I MNS

IIi IMNS

NAME CH ge KRamsey = xJGreeves

Uo X RECunninghim

DATE It/la /92 j9/ /92 81I /_/92 _2

//92_

C: COVER E: COVER & ENCL. N: NO COPY

OFFICIAL RECORD COPY: G:LOCKING.SWM


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