Information Notice No. 91-49: Enforcement of Safety Requirements for Radiographers

                               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. 
.

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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
.