ML20140G348

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Discusses Insp Rept 15000004/97-03 on 970418-0516 & Forwards Notice of Violation
ML20140G348
Person / Time
Site: 15000004
Issue date: 06/09/1997
From: Scarano R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Boykin S
AFFILIATION NOT ASSIGNED
Shared Package
ML20140G352 List:
References
15000004-97-03, 15000004-97-3, NUDOCS 9706160171
Download: ML20140G348 (3)


See also: IR 015000004/1997003

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June 9, 1997

Samuel A. Boykin, President

Industrial Marine Testing Laboratory, Inc.

1014 Coolidge Avenue

National City, California 91950-3225

SUBJECT: NRC INSPECTION 150-00004/97-03 AND NOTICE OF VIOLATION

Dear Mr. Boykin:

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On April 18 and 22,1997, the NRC conducted an inspection at your laboratory f acility in

National City, California. The findings of the inspection were initially discussed with you

on April 22,1997, and during a telephonic exit meeting on May 16,1997. Discussions

relative to the inspection were also held with you on May 13,1997.

Based on the results of the inspection, the NRC has determined that violations of NRC

requirements occurred. These violations are cited in the enclosed Notice of Violation

(Notice) and involved failures to: (1) provide an individual with copies of, and instruction I

in, NRC regulations befo.re permitting the individual to work as a radiographer; (2) properly

evaluate an individual by means of a written or oral test and field examination before

permitting the individual to work as an assistant radiographer; (3) audit the performance of

a radiographer during radiographic operations in each calendar quarter; (4) inspect and

maintain a radiographic exposure device at three month intervals; (5) post proper warning

signs to identify the presence of a high radiation area du'ing several radiographic

operations; (6) attach a label to a radiographic exposure device identifying the licensee's

name, address, and telephone number; and (7) comply w ith certain U.S. Department of

Transportation regulations involving shipp;ng papers, package markings, and labels for

radioactive material transported to temporary job sites.

You are required to respond to this letter and should follow the instructions specified in the

enclosed Notice when preparing your response. For your consideration and convenience,

NRC Information Notice 96-28, " SUGGESTED GUIDANCE RELATING TO DEVELOPMENT

! AND IMPLEMENTATION OF CORRECTIVE ACTION," is enclosed. The NRC will use your

i response, in part, to determine whether further enforcement action is necessary to ensure

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compliance with regulatory requirements.

In addition, another violation was identified involving a failure to determine the

occupational radiation dose received during 1996 for a part-time radiographer employee

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who had apparently received concurrent occupational exposure while working as a

l radiographer for Tidelands Testing Company, as required by 10 CFR 20.2104(a)(1). As

l discussed with you earlier, this determination is required to ensure that the radiographer

has not received a combined radiation exposure exceeding annual occupational dose limits. g

However, because this violation involved two California licensees (industrial Marine and

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Industrial Marine Testing Labs, Inc. -2- June 9, 1997

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Tidelands Testing) and to avoid duplication of effort, this violation is being referred to the

state of California for enforcement action.

We are concerned about the number of violations identified during our inspection. Most of

these violations appear to have resulted from a lack of specific knowledge of, and

management attention to, several NRC requirements applicable to the general license

pursuant to 10 CFR 150.20, under which radiography operations were being conducted.

Consequently, in addition to the responses required by the enclosed Notice, your reply

should describe those actions taken or planned to improve your training of licensee

personnel and to improve management oversight of your licensed program to prevent

violations of NRC requirements.

_

in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter,

its enclosures, and your response will be placed in the NRC Public Document Room (PDR).

To the extent possible, your response should not include any personal privacy, proprietary,

or safeguards information so that it can be placed in the PDR without redaction.

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Should you have any questions concerning this inspection, please contact

Mr. David D. Skov at (510) 975-0253 or Frank A. Wenslawski at (510) 975-0219.

Sincerely,

.

Ross A. Scarano, Director

Division of Nuclear Materials Safety

Docket No.: 150-00004

License No.: 2799-37 (California)

Enclosures:

1. Notice of Violation

2. NRC Information Notice 96-28

cc w/ enclosures:

California Radiation Program Control Director

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