Information Notice 1993-05, Locking of Radiography Exposure Devices

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
Issue date:	01/14/1993
From:	Cunningham R E NRC/NMSS/IMNS
To:
References
FOIA/PA-2015-0150 IN-93-005, NUDOCS 9301080120
Download: ML031080041 (9)

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

L4'6 fD C fe -2?- 0A Ik Cct

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

above the lift, the radiographer

had to move the camera to reach the locking mechanism.

He moved the camera by grasping the control cables with his right hand and locking the camera with his left hand. He continued

with his left hand to disconnect

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

approximately

10 centimeters

(4 inches) from the camera port. (Note: His alarming ratemeter

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

in Information

Notice 91-49: "Enforcement

of Safety Requirements

for Radiographers").

Reenactments

of the incident showed that when the radiographer

turned the device, the crank handle could drag on the ground, exposing the sealed source.The radiographer

was then able to lock the device over the drive cable, with the sealed source protruding

approximately

10 centimeters

(4 inches).Analysis of the locking mechanism

after the event did not identify any obvious defects with the mechanism.

Tests performed

showed that the device could still be locked with the source in the exposed position.NRC Evaluation:

The findings in both of these cases raised concern among NRC staff that, under certain conditions, radiographers

could have false confidence

in the locking mechanisms.

If exposure devices can lock when the source is outside of the shielded position, then radiographers

could incorrectly

believe that they are protected

from exposure when, in fact, the source is not in its fully shielded position.

We are also concerned

that exposure devices are moved while the drive cables are still connected.

To evaluate the effectiveness

of the locking mechanism

on radiography

exposure devices and to determine

whether radiographers

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

observed licensee equipment

tests and interviewed

radiography

personnel.

From the data collected, we determined

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

show that some exposure devices may be locked both when the source is not fully retracted

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

the locking-ball

feature. This may result in a source being positioned

where it is not fully shielded.Many radiographers

acknowledged

to NRC inspectors

that they often leave drive cables connected

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

job sites. In addition, some acknowledged

leaving the guide tube connected.

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

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

before locking the device.

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 93-03 92-84 92-72 Investigation

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

for Transporting

Radioactive

Materials Emergency

Response Information

Require-ments for Radioactive

Material Shipments Uranium Hexafluoride

Cylinders

-Deviations

in Coupling Welds Implementation

Date for the Revision to the EPA Manual of Protective

Action Guides and Pro-tective Actions for Nuclear Incidents Implementation

of the Deliberate

Misconduct

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

Commission

medical licensees.

All byproduct, source, and special nuclear material licensees.

All Nuclear Regulatory

Com-mission Medical Licensees.

All U.S. Nuclear Regulatory

Commission

Licensees.

All U.S. Nuclear Regulatory

Commission

Licensees.

All fuel cycle licensees.

All holders of OLs or CPs for nuclear power reactors, non-power

reactors and materials

licensees

author-ized to possess large quantities

of radioactive

material.All Nuclear Regulatory

Commission

Licensees.

92-58 92-38 92-37 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 93-03 93-02 Investigation

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

of A Pres-surizer Code Safety Valve Accuracy of Motor-Operated Valve Diagnostic

Equipment

Manufactures

by Liberty Technologies

Unexpected

Restriction

to Thermal Growth of Reactor Coolant Piping Potential

Failures of Emergency

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

Commission

medical licensees.

All byproduct, source, and special nuclear material licensees.

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

Commission

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

for Gas Binding of High-Pres- 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.questions

about this matter, please contact the appropriate

office or the personnel

listed below.If you have any NRC regional ( Richard E. Cunningham, Director Division Industrial

and Medical Nuclear Safety, NMSS Gary Shear, Region III (708) 790-5620 Technical

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

1. List of Recently 2. List of Recently Issued NMSS Information

Notices 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 2. List of Recently Issued NMSS Information

Notices 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: 93-05.IN DOCUMENT NAME:

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, 708-790-562C

Region III Charles Cain, Region IV 817-860-8186 Scott Moore, NMSS 301-504-2514 Attachments:

1. List of Recently 2. List of Recently Issued NMSS Information

Notices Issued NRC Information

Notices* -caP nyVauiniiC

anlnlnrranra

-Fe F 9- y ... _OFC IMOB I E NMSS I Nj IMOB I E IMAB lNAME *SMoore/sm/l1

• 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

IN 92-December , 1992 No written response is required by this information

notice.questions

about this matter, please contact the appropriate

office or the personnel

listed below.If you have any NRC regional 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 IIi I MNS IMNS NAME CH ge KRamsey = Uo X xJGreeves

RECunninghim

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