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UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS WASHINGTON, D.C. 20555 August 15, 1991 Information Notice No. 91-49: ENFORCEMENT OF SAFETY REQUIREMENTS FOR RADIOGRAPHERS Addressees: All Nuclear Regulatory Commission (NRC) licensees authorized to use sealed sources for industrial radiography. Purpose: This information notice is being issued to alert licensees to new safety requirements, to remind licensees to perform required radiation safety surveys, and to describe related changes to NRC's Enforcement Policy. New rules went into effect on January 10, 1991, that, among other items: (a) require radiographers to wear audible alarm ratemeters, in addition to using survey meters; (b) provide for new reporting requirements; and (c) specify performance requirements for radiography equipment. It is expected that licensees will review this notice, distribute it to responsible staff, and consider actions, as appropriate, to ensure compliance with NRC requirements. Suggestions contained in this information notice do not constitute any new NRC requirements. However, you are responsible for ensuring that radiographic operations are performed in a safe manner, in accordance with license conditions and NRC regulations. No written response to this information notice is required. Background: On January 10, 1990, NRC published a final rule in the Federal Register (55 FR 843), establishing additional safety requirements for industrial radiography equipment (see Attachment 1). The rule requires use of audible alarm ratemeters (Section 34.33) and establishes reporting requirements for certain incidents (Section 34.30), and became effective on January 10, 1991. The rule also establishes new safety requirements for radiography equipment (Sections 34.20 and 34.21), which will be phased in from 1992 to 1996. In addition to the new radiography safety requirements, the final rule also modified NRC's Enforcement Policy (10 CFR Part 2, Appendix C) to reflect the regulatory changes. Specifically, the modified Enforcement Policy put licensees on notice that the failure to implement the requirements for dosimetry and equipment by the required date will be considered a serious violation. Licensees who fail to use required radiation safety equipment and personnel monitoring devices will now be cited with a Severity Level III violation, which may lead to a civil penalty (monetary fine) or other appropriate enforcement action. 9108090210 . IN 91-49 August 15, 1991 Page 2 of 3 Finally, licensees are reminded of the existing requirements to conduct radiation surveys, as stated in 10 CFR 34.43 and 20.201(b). Failure to survey will be now cited as a serious violation under the modified Enforcement Policy. Compliance with the 10 CFR Part 34 radiation safety survey requirements is critical for safe radiography operations. Discussion: NRC wants to emphasize to licensees that it is extremely important to perform appropriate surveys and use appropriate personnel monitoring equipment when using radiography sources. A number of significant overexposure incidents occurred in this past year, that might have been avoided if proper surveys had been performed and if alarming ratemeters had been worn (see Information Notice 91-23, "Accidental Radiation Overexposures to Personnel due to Industrial Radiography Accessory Equipment Malfunctions"). Since the final rule became effective on January 10, 1991, the use of alarm ratemeters is now required. You should be aware that NRC staff takes strong enforcement action for failures to perform adequate surveys. In the past 18 months, NRC removed six radiographers from licensed activities for, among other reasons, failing to perform radiation surveys and willfully violating NRC regulations. In some cases, these violations caused significant overexposures or led to unnecessary exposure to a member of the general public. We issued orders suspending or modifying licenses for these failures, and we proposed substantial civil penalties. The Enforcement Policy now gives the following example of a Severity Level III violation, which could lead to a civil penalty or other strong enforcement action: "Failure, during radiographic operations, to have present or use radiographic equipment, radiation survey instruments, and/or personal monitoring devices as required by Part 34." In cases of willfulness, concealment, or repetition of similar serious violations, we will consider actions stronger than civil penalties, such as orders to modify, suspend, or revoke radiography licenses. Based on inspections in the past year, we are concerned that radiographers working independently in the field are not always complying with regulations and license conditions. These lapses in radiation safety concern us, and we will take appropriate, strong enforcement action to prevent continued degradations in safety. To ensure that your radiography sources are used safely, we recommend that management conduct audits of your field radiography programs, in addition to the audits already required by 10 CFR 34.11(d). Licensee management should also meet with licensee radiographers to discuss management expectations and NRC's heightened concern regarding the safe use of these sources. . IN 91-49 August 15, 1991 Page 3 of 3 Radiography involves relatively large quantities of radioactive material that can be dangerous if not properly controlled. Performing radiography requires constant attention to detail and vigilant care because of its repetitive nature, frequently in difficult field conditions. Through strong internal radiation safety programs, including management audits, you can ensure that licensed material is being used in a safe manner. No specific action or written response is required by this information notice. If you have any questions about this matter, please contact the technical contact listed below or the appropriate regional office. Richard E. Cunningham, Director Division of Industrial and Medical Nuclear Safety Office of Nuclear Material Safety and Safeguards Technical Contact: Scott W. Moore, NMSS 301-492-0514 Attachments: 1. 10 CFR Part 34 2. List of Recently Issued NMSS Information Notices 3. List of Recently Issued NRC Information Notices .
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