IR 05000232/1957001

Ack Receipt of 880825 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp of License 50-23257-01

ML20207M744
Person / Time
Site:	05000232, 03020423
Issue date:	10/12/1988
From:	Jonathan Montgomery NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Russell L INSPECTION SERVICES & TESTING, INC. (FORMERLY INSPECT
References
NUDOCS 8810180353
Download: ML20207M744 (1)

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l OCT 121999

License No. 50-23257-01

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Inspection Services and Engineering 611 30th Avenue l P. O. Box 61179 Fairbanks, Alaska 99706

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Attention: Larry Russel ;

Vice President

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Gentlemen: ' !

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Thank you for your letter'of August'25,'1988, iri response to our Notice of -

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Violation dated August 12,1988, 'itifouning us of the steps you have taken to correct the items which we brought to your attentio The Notice of Violation '

and other inspection findings were also discussed by R. Thomas, Region V with you during a Management Conference on September 15, 1988. Your corrective '

y actions will be verified during a future inspectio i  !

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Your cooperation with us is appreciate t

Sincerely,

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! James L. Montgomery, Chief

Nuclear Matertals Safety and

Safeguards Branch -

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u oo-l. ,.'::." ."1.... SEP I A9:46 aan urso 32 August 25, 1988 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Subject: Reply to a Notice of Violation License No. 50-23257-01 Document No. 030.20423 Gentlemen:

In response to the Notice of Violation: dated August 12, 1988, inspection Services submits the following statements and explanations: CFR 34.43(b) requires tnat the entire circumference of the radiographic exposure device be surveyed with a calibrated and operable radiation survey instrument after each exposure to deter-mine that the sealed source has been returned to its shielded positio Contrary to the above requirement, a licensee radiographer did not survey around the entire circumference of the Gamma Century SA exposure device (serial number 2834) following the return of a 48 curie iridium-192 sealed source to its shielded position in the exposure device during field radiography nn July 29, 1988 at Eielson Air Force Base, Alask Statement: The radiographer did perform a survey of the source tube and the front of the exposure device to ascertain that the source had been retracted to the same positio Radiation readings did confirm thi _Gorrective Steps: Radiographic personnel have been instructed to survey the length of the source tube and the total circumference of the exposure device after each exposure is completed as stated in 10CFR 34.43(b) and IS&E Radiation Safety Manual, Section 5., Page 9, Para. 3(N). This matter was discussed in detail at a safety meet-ing held on August 3, 198 Full Compliance Achieved: Immediately - August 3, 1988 License Condition 14 states that the licensee may transport licensed material in accordance with the provisions of 10CFR 4 Part 71, "Packaging and Transportation of Radioactive Material". I 10 CFR 71.5(a) states that each licensee who transports licensed material outside the confines of its plant or other place of use, I g<g-

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. U.S. Nuclear Regulatory Commission (Page 2)

or who delivers licensed material to a carrier for transport, shall comply with the applicable requirements of the regulations of the Department of Transportation in 49 CFR Parts 170 through 189 appropriate to the mode of transport., CFR 177.842(d) states that packages containing radioactive materia 1 must be so blocked and braced that they cannot change positions during conditions normally incident to transportatio Also, item 5, Section 5 of the Radiation Safety Manual, included by reference in License Condition 15, requires that exposure devices transported to field locations be securely positioned in a lockable steel ' source box' which is bolted to the vehicl Contrary to the above requirements, on July 29, 1938 at Eielson Air Force Base, Alaska, the licensee transported a radiographic exposure device (SPEC 2-T serial number 318 containing a 48 curie iridium-192 sealed source) outside of the vehicle ' source box', and without any blocking or oracing of the exposure de-vic . 49 CFR 173.475(1) states that before each shipment of any radioactive materials package, the shipper shall ensure by examination or appropriate tests, that external radiation levels are within the allowable limits specified in this sub-chapte Contrary to the above requirement, on July 29, 1988, the radiation levels at the surface and at one meter from packages containing licensed material were not measured prior to ship-ment of the packages by private carrier betwaen Fairbanks and Eielson air Force Base, Alask Statement di: Radiographic personnel did transport the exposure device secured in the steel lead lined ' source box' from the IS&E Fairbanks facility to the job site (Eielson Air Force Base). After making the exposures at one location, the device was placed in the self con-tained darkroom mounted on a pickup truck and transported from one manhole to the next location (approximately one mile) without ' lace-ment in the ' source box'.

Corrective Steps: All radiographic personnel employed at IS&E are aware of the requirements pertaining to proper placement and locking procedure, this violation was caused by neglect on the radiographer's part and definitely not acceptable practic The radiographer was informed that another violation on his part would result in termination of employment with IS& Full ComDliance Achieved: Imediately - August 3,1988

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. U.S. Nuclear Regulatory Commission (Page 3)

Statement #2: The requirements for examination of radiation levels was discussed with the radiographic personnel the day following this audit. He did state that he had surveyed the exterior surface of the darkroom prfor to leaving the IS&E Fairbanks facility and that radiation levels were well below 2mr. He.did not document the surve Corrective Steps: Survey requirements were discussed in great detail at the safety meeting held on August 3,198 Audits will be increased by the Radiation Safety Officer and Radiation Safety Supervisors to assure full complianc Full Compliance Achieved: Immediately - August 3, 1988 CFR 172.403 requires appropriate "Radioactive" category labels  :

that identify the activity and radioactive contents of packages '

containing radioactive material. Determination of the p aper label is based on the radiation dose rates at the surface and at one meter (transport index) from the packag Contrary to the above requirement, on July 29, 1988, radiographic exposure devices containing licensed material were transported by private carrier between Fairbanks and Eielson Air Force Base, Alaska, without any "Radioactive" category label ;

Statement: All IS&E vehicles have placards displaying "Radioactive" but have not utilized category label Corrective Ste,p_s: All vehicles now have "Radioactive" category Tabels affixed to the source storage box. these are completed prior to movement of the radioactive material. This was discussed during the safety meeting held August 3, 198 i 1 Full Compliance Achieved: Immediately - August 3, 1988 4 49 CFR 172.200(a) requires that each person who offers a hazard-ous material for transportation shall describe the hazardous material on a shipping paper in a manner prescribed by Subpart C of 49 CFR Part 172. 49 CFR 172.101 classifias radioactive

, material as a hazardous material for the purpose of transportatio Contrary to the above requirement, on July 29, 1988, radiographic

exposure devices containing licensed material were transported

by private carrier between Fairbanks, Alaska and Eielson Air i

Force Pase, Alaska, without any shipping papers describing the hazardous materia Statement: No shipping papers were completed during this radio-graphic operation located at Eielson Air Force Base (approximately 25 miles from the IS&E facility).

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U.S. Nuclear Regulatory Commission (Page 4)

Corrective Step: Shipping papers are now affixed to clip boards in 1 the venicles and completed prior to movement of radioactive material This was discussed at the safety meeting held on August 3, 198 Full Compliance Achieved: Immediately - Sugust 3, 1988

CFR 34.31(c) requires the lican';ee to maintain, for three years, j records of training of radiographers and assistant.radiographers, '

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including copies of written tests and dates of oral tests and I field examination , Contrary to the above requirement, at the time of inspection, the licensee had not maintained records of the written examination of a radiographer on December 11, 1986, nor of a field examin-ation of another radiographer on April 28, 1988. Also, records were not maintained of the licensee's training nor field'examin- .

ations of two assistant radiographers during approximately June,  !

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198 Statement: Examinations were completed on all personnel as required by 10 CFR 34.31(c) and IS&E safety manuals.

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i Records could not be located for the December 11, 1986 and April 28, i i 1988 exams. Records had not been completed on the training and field examinations of the two assistant radiographers. This was the second day of employment for the two assistants. A field audit was conducted on their first day of employment by L. Russell, RS !

Corrective Steps: Retests were administered on August 3, 1988 to

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replace missing exams, t Check sheets are being closely reviewed to verify timely and com- i plete documentation is achieve !

Full Complianc_e Achieved: No later than August 31, 1988 I License Condition 15 requires that the licensee conduct its program in accordance with the statements, representations, ,

and procedures contained in the application dated December 30, [

1986, Item 0, Section E of the Radiation Safety Manual, contained i in the application dated December 30, 1986, states that

records of all training of radiography personnel conducted by the licensee will be maintained on fil Contrary to the above requirement, at the time of inspection, the licensee had not maintained records of the licensee's r retraining of radiography personnel on May 1, 1988 and May 20, 198 l t

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U.S. Nuclear Regulatory Commission (Page 5)

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Statement: Retraining is an ongoing way of life with IS& Person-nel are always short term even though some have worked for IS&E since l inception. Example: E. Nunn worked approximately 20 days during H the first half of 1987, none of the second half, and approximately I 15 days on radiography in the first half of 1988, et Corrective Steps: Retraining sessions will be conducted and docu-mented each calendar quarter for personnel employed at that time.

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Full Compliance Achieved: No later than September, 15, 1988

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i Item F.1, Section F of the Radiation Safety Manual, included in the application dated December 30, 1986, requires that the radiographer record the results of the daily inspection of radiographic equipment prior to its use for field radiograph Contrary to the above requirement, a licensee radiographer had not recorded the results of the daily inspection of a SPEC Mo' del 2-T exposure device (serial number 318) prior to its use for field radiography on July 29, 1988 at Eielson Air Force Base, Alask Statement: All radiography personnel are well aware of this requirement. This radiographer evidently neglected to complete the documentation as require Corrective Steps: Documentation and survey requirements were dis-

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, cussed at great length at the safety meeting held August 3, 1988 and the radiographer cited in this instance was informed of dis-c:plinary (termination of employment) action to be taken if an additional violation was noted.

Full Compliance Achieved: Imediately - August 3,1988

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It is IS&E's intent to provide safe equipment and guidelines for all radioactive operations and I will add to my radiation safety staff a Radiation Safety Manager to assure that no further violations or  !

documentation delays occu If additional information is needed, please contact m

Sincerely, Lawrence Russell

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Radiation Safety Officer cc: U.S. Nucle *r Regulatory Commission Region V

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