ML20217N004

Insp Rept 15000010/98-01 on 970401-14.Apparent Violations Being Considered for Escalated Enforcement Action.Major Areas Inspected:Radiographic Operations Conducted by Licensee

ML20217N004
Person / Time
Issue date:	04/24/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20217M940	List: ML20217M937 ML20217N004
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

PDR 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

10 CFR 150.20(b)(5).

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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

) 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- I

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) 1

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l 10 CFR 30.3 requires that no person shall possess or use byproduct

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issued by the NRC.

10 CFR 150.20(a) states, in part, that any person who holds a

specific license from an Agreement State is granted a Nuclear

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Regulatory Commission (NRC) general license to conduct the same

activity in non-Agreement States subject to the provisions of

10 CFR 150.20(b).

The inspectors reviewed licensing do u mentation including a '

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 i

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 i

facility outside of the area of exclusive Federal jurisdiction. '

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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.2. FACILITIES AND EQUIPMENT l

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 ,

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 J

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 )

area located at the temporary job site. The inspectors concluded  !

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that this identified weakness contributed to the violations

regarding proper posting of restricted areas documented in

Paragraph 4.

3. MATERIALS USE. TRANSPORTATION AND CONTROL

a. Insoection Scone (87120) i

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

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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 i

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 i

a period of approximately 5 - 10 minutes before surveillance was l

re-established by licensee personnel. Upon questioning, the

radiographer stated that he had thought that the issoectors would ,

maintain control and surveillance of the camera. Tne inspectors

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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 i

surveillance of licensed materials was identified as an apparent i

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 i

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 ,

operating procedures related to area radiation surveys and l

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 . j

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. i

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Condition No. 24 of Georgia Radioactive Materials License l

No. 1308-01 required that licensed activities be conducted in j

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 1

area signs be posted at all accessible entrances to the restricted '

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 i

restricted area boundary, the inspectors found an unmarked gap in  ;

the boundary of the licensee's restricted area. This gap was '

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 ,

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. The i

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. The

inspectors remained near this access point during the remainder of 1

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 j

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 l

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 ,

adequate. Licensee radiation survey equipment was found to be )

operational and properly calibrated. Licensee personnel were

observed to be wearing all required radiation dosimetry.

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l Independent survey measurements made by the inspectors

I demonstrated that the radiation icvels at the restricted area ,

boundary did not exceed two millirem in any one hour. j

Measurements were made with a Ludlum Model 2401-EC2 geiger-mueller j

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 )

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 I

procedures tr decide whether radiographic operations being )

perfcrmed at RAFB were being done by properly trained individuals. J

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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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states. , 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 ,

radiographers of the licensee's " emphasis on safely and properly performing '

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 j

to verify the proper placement of I

restricted area boundaries. l

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150-00010/98-01-05 Open EEI - Failure to ensure radiographic  !

personnel were trained in accordance

with licensee procedures.

LIST OF ACRONYMS

CFR Code of Federal Regulations

EEI Escalated Enforcement Item

IP Inspection Procedure

NRC Nuclear Regulatory Commission

O&E Operating and Emergency

RAFB Robins Air Force Base