Information Notice No. 87-45:Recent Safety-Related Violations of NRC Requirements by Industrial Radiography Licensees

                                                       SSINS No.:  6835 
                                                          IN 87-45 

                                  UNITED STATES
                          NUCLEAR REGULATORY COMMISSION
                OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS
                             WASHINGTON, D.C.  20555

                               SEPTEMBER 25, 1987


Information Notice No. 87-45:  RECENT SAFETY-RELATED VIOLATIONS OF NRC 
                                   REQUIREMENTS BY INDUSTRIAL RADIOGRAPHY 
                                   LICENSEES 


Addressees: 

All NRC licensees authorized to possess and use sealed sources for industrial 
radiography. 

Purpose: 

This notice is being issued to inform recipients about recent safety-related 
violations of NRC requirements.  These occurred during industrial radiographic 
operations and could have been prevented by proper management control actions 
and attention to radiation safety procedures.  It is suggested that recipients 
review this information, evaluate their procedures, and consider actions, if 
appropriate, to ensure that proper management control and proper attention to 
radiation safety procedures are being practiced by all members of their 
organization.  However, suggestions contained in this information notice do 
not constitute NRC requirements; therefore, no specific action or written 
response is required. 

Description of Circumstances: 

As a followup to an allegation Region V received, the NRC regional offices and
eight Agreement States conducted numerous in-depth inspections of a single 
radiography firm.  These inspections were made from February 10 to June 2, 
1987, at the firm's many job sites, scattered across the United States.  These 
inspections identified numerous violations that had serious safety 
significance.  In summary, these violations included: 

Allowing individuals to act as radiographers and radiographers' 
     assistants without their completion of the training requirements 
     specified in 10 CFR 34.31(a)(3), 34.31(a)(4), 34.31(b)(3), and the 
     licensee's in-house training program.  In addition, training records 
     required by 10 CFR 34.31(c) to be maintained for three years were missing 
     or incomplete. 
     







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Personnel overexposures were not reported to the NRC, as required by 
     10 CFR 20.405.  In addition, adequate evaluations were not performed of 
     either the causes of the overexposure incidents or of the overexposure 
     doses personnel actually received during these incidents. 

Utilization logs were not completed, as required by 10 CFR 34.27. 

Radiation surveys did not meet the requirements of 10 CFR 34.43 or 
     20.201. 

High radiation areas were not maintained under the direct surveillance of
     radiographers or radiographers' assistants, as required by 10 CFR 34.41. 

Radiographers and radiographers' assistants were not audited, as 
     required by 10 CFR 34.11(d), or by specific license condition, or both. 

Daily and quarterly inspection and maintenance operations were not 
     performed on radiographic exposure devices, storage containers, or 
     source changers used by the licensee, as required by 10 CFR 34.28. 

Incompatible equipment was used during a source exchange. 

Records of personnel exposure and survey results were not maintained, as 
     required by 10 CFR 20.401(a) and (b), respectively. 

Due to the serious nature of these violations, NRC personnel concluded that 
stronger management control was needed to administer the dispersed and 
numerous activities of this licensee, to ensure the health and safety of the 
public and licensee personnel.  Therefore, an Order modifying this license was 
issued on June 17, 1987.  The provisions of the Order are summarized below: 

A responsible, qualified Radiation Safety Officer (RSO) must be appointed
     for each (continuing) job site or, in the case of temporary job sites, 
     for the centralized facility (field office) controlling licensed 
     activities at temporary job sites. 

All licensed material must be placed in secure storage until the RSO is 
     designated for the job site or field office. 

All required documentation must be maintained by the job site RSO or 
     field office RSO, with a copy sent to the corporate headquarters. 

The RSOs shall have authority, in writing, to suspend any activity which 
     is not in compliance with the license.  The overall responsibility for 
     implementing the radiation safety program rests with the corporate 
     headquarters. 

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The licensee shall obtain the services of one or more independent 
     consultant(s) to assess:  employee qualifications; organizational 
     structure; procedural implementation; records maintenance; and audit 
     results. 

The recommendations of the independent consultant(s) shall be submitted 
     to the NRC at the same time as they are submitted to the licensee. 
     Within 30 days after receipt of the reports, the licensee must submit 
     an implementation plan to the NRC. 

Discussion: 

These violations illustrate a significant breakdown in the management over-
sight and control of the licensee's radiation safety program.  This situation 
demonstrates the importance of: 

1.   Assuring that all radiographers and radiographers' assistants meet the 
     training criteria specified in 10 CFR 34.31 and as outlined in Attachment 
     1. 

2.   Assuring that the number of trained radiographers and radiographers' 
     assistants sent to each work location is sufficient to perform the 
     radiographic operations, perform all required surveys, and maintain 
     direct surveillance of all access points to high radiation areas.  
     Work assignments are also outlined in Attachment 1. 

3.   Conducting onsite audits of each radiographer and radiographer's 
     assistant, as required by 10 CFR 34.11(d) and specific license 
     condition. 

4.   Assigning a qualified, experienced radiographer to be responsible for 
     radiation safety at each field office and continuing job site.  This 
     individual would have the authority to suspend any activity not in 
     compliance with NRC regulations or the license. 

5.   Requiring that a person responsible for radiation safety at each field 
     office and continuing job site forwards records to the corporate head-
     quarters for prompt review and follow-up, if warranted. 

6.   Properly reviewing, evaluating, and reporting all incidents which may 
     have caused personnel exposures in excess of the limits stated in 
     10 CFR 20.101, 20.104, or 20.105. 

It is suggested that copies of this notice be distributed to each field office 
and continuing job site and that all radiography personnel be reminded of 
their responsibilities to assure safe operations at each work location. 

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No specific actions or written response is required by this Information 
Notice. If you have questions about this matter, please contact the 
appropriate NRC regional office or this office. 




                                   Richard E. Cunningham, Director
                                   Division of Industrial and 
                                     Medical Nuclear Safety
                                   Office of Nuclear Material Safety
                                     and Safeguards


Technical Contact:  J. Bruce Carrico, NMSS
                    (301) 427-4280

Attachments:
1.   Assignments and Training of Radiographers 
     and Radiographers' Assistants
2.   List of Recently Issued NRC Information Notices

.                                                            Attachment 1 
                                                            IN 87-45 
                                                            September 25, 1987


                    ASSIGNMENTS AND TRAINING OF RADIOGRAPHERS
                          AND RADIOGRAPHERS' ASSISTANTS


CATEGORIES OF WORK THAT MUST BE DONE BY A RADIOGRAPHER OR BY A RADIOGRAPHER'S 
ASSISTANT UNDER A RADIOGRAPHER'S PERSONAL SUPERVISION (REF. 10 CFR 34.44) 

Use of radiography camera, including positioning collimators; use of 
     sealed sources and handling tools; and use of radiation survey 
     instruments (ref. 10 CFR 34.44). 

Performance of required surveys (ref. 10 CFR 34.43). 

Maintenance of direct surveillance of all access points to high 
     radiation areas created by radiographic operations (ref. 10 CFR 34.41). 


REQUIRED TRAINING FOR RADIOGRAPHERS (REF. 10 CFR 34.31(a)) 

Instruction in radiation safety topics (ref. 10 CFR Part 34, 
     Appendix A); NRC regulations in 10 CFR Parts 19, 20, and 34; NRC 
     license under which the radiographer will work; the licensee's 
     operating and emergency procedures; AND 

Demonstrated competency in the use of the licensee's radiography 
     and radiation survey equipment; AND 

Successful completion of a written examination on radiation safety and 
     regulatory matters; AND 

Successful completion of a field (practical) examination. 

REQUIRED TRAINING FOR RADIOGRAPHERS' ASSISTANTS (REF. 10 CFR 34.31(b))     

Instruction in (and copies of) the licensee's operating and emergency 
     procedures; AND 

Demonstrated competency in the use, under the personal supervision of 
     a radiographer, of the licensee's radiography and radiation survey 
     equipment; AND 

Successful completion of an oral or written test and of a field 
     (practical) examination on the above subjects. 

TRAINING RECORDS (REF. 10 CFR 34.31(c)) 

Keep records of above training including copies of written tests and 
     dates of oral tests and field (practical) examinations. 

Keep records for three years.