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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September 25, 1987
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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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September 25, 1987
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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.
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