Information Notice No. 84-25: Recent Serious Violations of NRC Requirements by Radiography Licensees

                                                           SSINS No.: 6835 
                                                           IN 84-25        

                               UNITED STATES 
                       NUCLEAR REGULATORY COMMISSION 
                    OFFICE OF INSPECTION AND ENFORCEMENT 
                           WASHINGTON, D.C. 20555 

                               APRIL 16, 1984 

Information Notice No. 84-25:   RECENT SERIOUS VIOLATIONS OF NRC 
                                   REQUIREMENTS BY RADIOGRAPHY LICENSEES 

Addressees: 

All byproduct materials licensees authorized to possess and use byproduct 
materials in industrial radiography and manufacturers who distribute devices
that incorporate sealed sources for such use. 

Purpose: 

To bring to the attention of radiography licensees the large number of 
recent cases involving serious violations of NRC license conditions, to 
point out the common causes of these violations, and to describe their 
consequences. 

Discussion: 

From January 1 to December 1, 1983 there have been 26 cases in which the NRC
has taken escalated enforcement action against byproduct materials 
licensees. Nineteen of these cases involved a civil penalty, six involved 
Orders to suspend the license or to show cause why the license should not be 
revoked, and one involved both a suspension Order and a civil penalty. These 
escalated enforcement actions were taken because various serious violations 
of NRC license requirements occurred. These violations included employees 
being overexposed to radiation and members of the public being unnecessarily
exposed to radiation. In addition, the financial consequences to the 
affected licensees have been significant because of the loss of income from 
the payment of civil penalties, and from the suspension or revocation of the
license. 

An analysis of the causes of these escalated enforcement cases shows that 
there were three common causes for the serious violations and their 
consequences. These causes were: 

(1)  Failure to read and understand the conditions of the license. 
(2)  Failure to train employees in the conditions of the license including 
     the radiation safety procedures that are incorporated into the license.
(3)  Failure to control operations including failure of licensee employees 
     to follow approved radiation safety procedures. 

Attached are summaries of three radiography cases. They illustrate the 
causes arid consequences of the serious violations that the NRC has found 
during inspections of this class of byproduct materials licensees. 
.

                                                           IN 84-25        
                                                           April 16, 1984  
                                                           Page 2 of 2     

One of the principal causes of violations is the fact that some licensees 
are not cognizant of all the conditions of their license. NRC has found 
during inspections that some licensees have never read,the license or have 
little understanding of its conditions. Conditions and commitments in the 
license form the basis for the issuance of the license, and are necessary to 
protect the health and safety of the public. NRC therefore expects licensees 
to abide with all the conditions and commitments of their license. 

Two other principal causes of violations are the failure to properly train 
the workforce and the failure to control the radiation-safety aspects of the
licensee's operation. Licensee management is responsible for ensuring that 
employees receive proper training, that the proper radiation monitoring 
instrumentation and personnel dosimetry is available and used, and that 
employees comply fully with all the conditions of the license and associated
radiation safety procedures. 

The licensee's responsibility for control of its operations also extends to 
consultants and contractors. In certain circumstances the NRC encourages 
licensees to seek qualified assistance when the licensee does not possess 
the necessary experience, training, equipment, or personnel dosimetry to 
perform particular activities; e.g., to handle problems arising from an 
accident or unusual occurrence. However, the responsibility for the safety 
of the operations and compliance with NRC requirements remains with the 
licensee. 

Licensees should review the conditions of their license to ensure that they 
understand their responsibilities under the license. This should include an 
examination of the details of their radiation safety program to verify that 
the program complies with all requirements. As a result, licensees can avoid
the serious consequences to their employees and the public and the 
significant financial costs that can result from failure to follow NRC 
requirements. 

No response to this information notice is required. If you have any 
questions regarding this matter, please contact the Administrator of the 
appropriate Regional Office or this office. 


                              J. Nelson Grace, Director  
                              Division of Quality Assurance, Safeguards, 
                                and Inspection Programs 
                              Office of Inspection and Enforcement 

Technical Contacts: J. R. Metzger, IE  (301) 492-4947 
                    E. D. Flack, IE    (301) 492-9823

Attachments:
1.  Selected Cases Involving Serious
    Violations of NRC Requirements
2.  List of Recently Issued IE Information Notices