IR 015000001/1999001
| ML20205Q304 | |
| Person / Time | |
|---|---|
| Site: | 015000001 |
| Issue date: | 04/08/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20205Q289 | List: |
| References | |
| 15000001-99-01, 15000001-99-1, NUDOCS 9904210160 | |
| Download: ML20205Q304 (8) | |
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U.S. NUCLEAR REGULATORY COMMISSION REGION ll
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Docket No.: 150-00001 l
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License No.: General License (10 CFR 150.20)) l Report No.: 150-00001/99-01 Licensee: Code Services, Inc., Madison, Alabama Location: NASA Marshall Space Flight Center, Huntsville, Alabama Field Office, Madison, Alabama inspection Date: March 17 and 18,1999 Inspector: Richard Gibson, Jr., Radiation Specialist j i
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Approved by: Mark S. Lesser, Chief l Materials Licensing / Inspection Branch 2 Division of Nuclear Materials Safety l
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Enclosure 1 9904210160 990408 PDR STPRG ESGAL PDR
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EXECUTIVE SUMMARY Code Services, In I NRC Inspection Report No. 150-00001/99-01 An unannounced reciprocity field inspection pursuant to 10 CFR 150.20 was conducted on March 17 and 18,1999, at NASA Marshall Space Flight Center (MSFC), Huntsville, Alabama, an area of exclusive Federal jurisdiction, and the Code Services, Inc., field office in Madison, l Alabama. The field inspection involved Code Services, Inc., a State of Alabama licensee, ;
conducting radiographic operations at the Marshall Space Flight Center under a general NRC 1 license pursuant to the reciprocity requirements of 10 CFR 150.20. The inspection included interviews with licensee representatives, selective examination of records, and direct observations of licensed activities. Areas inspected included: management oversight; j personnel radiation protection; observation of radiographic operations; and office inspectio The inspector determined that the licensee's management, which is new, appears to be directly involved with the radiation safety progra During the field inspection on March 17,1999, the inspector determined that licensee's activities were appropriate to support the radiographic operations being conducted and to ensure the safe use of radioactive materials. However, one apparent violation was identifie l Through interviews with cognizant licensee personnel at the temporary job site and field office, I and review of documentation, the inspector determined that on February 16,1999, at NASA MSFC, a radiographer's assistant entered a radiography boundary during the conduct of radiography without an alarm ratemeter. Further discussions and review of records with the State of Alabama Department of Public Health, Office of Radiation Control, indicated two similar events had occurred within the last year within the State of Alabama jurisdiction.
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REPORT DETAILS 1. Management Oversight (87120) Scope Code Services, Inc., was acquired by new management in October 1998. During that time, the licensee hired a new Radiation Safety Officer to oversee licensed activities and the radiation protection program. The new management had retained most of the radiographers and radiographer's assistants who were conducting radiography. The inspector interviewed knowledgeable licensee representatives to understand the licensee's management oversight in order to determine whether the organization and staffing were as required by the license and commensurate with the complexity of the radiation safety progra Observation and Findinas Through interviews with cognizant licensee representatives and review of records, the inspector determined that the licensee's management is actively involved with the radiation protection program. The inspector determined through interview with licensee representatives at the temporary job site that the Managing Partner and Technical Manager, who is also the Radiation Safety Officer, have performed regular job site visits since the company was taken over by new management. In addition, both managers are listed as persons to contact on the emergency procedures. The licensee has approximately 12 certified radiographers, one assistant radiographer and two helper Radiographic operations are conducted by the licensee at several locations in the State of Alabama and at federal facilities under the jurisdiction of the NR Radiographic operations at temporary job sites are conducted by at least one radiographer and a radiographer's assistant. The radiographer and radiographer's assistant are evaluated in the field during radiographic operations by either the Radiation Safety Officer, the Managing Partner or their designee every six months. During the time of this inspection, the licensee was conducting radiographic operations for Brown Mechanical, a contractor of NASA Marshall Space Flight Cente Conclusions The inspector deterrnined that the licensee's management and staffing were adequate. The inspector also determined that the licensee's management i appears to be directly involved with the radiation safety program.
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2. Personnel Radiation Protection (87120) Scope i
l Code Services, Inc., is licensed by the Alabama Department of Public Health, 1 Office of Radiation Control (license number 1075) to possess and use Iridium-192 for industrial radiography within the jurisdiction of the State of Alabama. On January 8,1999, the licensee filed an NRC Form 241 for an NRC generallicense I in accordance with 10 CFR 150.20 to conduct licensed activities at NASA Marshall Space Flight Center, Huntsville, Alabarn Observation and Findinas l l
During the inspection at the temporary job site and the licensee's field office, the inspector determined through interviews with a radiographer, radiographer's assistant and the Radiation Safety Officer for Code Services, Inc., that on February 16,1999, the MSFC RSO conducted a field audit of Code Services, Inc., performing radiography at the NASA Marshall Space Flight Center. The inspector determined through interviews with licensee personnel and review of
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records, that the MSFC RSO observed the radiographer's assistant enter the radiography boundary and approach the exposed source without an alarm ratemeter. This was immediately brought to the attention of the radiographer and corrected. NASA MSFC held a meeting on February 18,1999, with the managers of Code Services, Inc., to discuss the findings identified by the MSFC RSO. Code Services, Inc., responded to NASA MSFC in a letter dated February 22,1999, signed by the Managing Partner, addressing the findings identified by the MSFC RSO and their implementation of corrective action Performing radiographic operations without an operating alarm ratemeter on February 16,1999, is an apparent violation of 10 CFR 34.47(a), which states, in part, that the licensee may not permit any individual to act as a radiographer or a radiographer's assistant unless, at all times during radiographic operations, each individual wears, on the trunk of the body, an operating alarm ratemete The inspector determined that within the past year, the Alabama Department of I Public Health, Office of Radiation Control, had conducted a field inspection of Code Services, Inc., on May 4,1998, and an office inspection on October 8, 1998, following an incident that occurred on August 31,1998, with the license The State of Alabama on two occasions identified the licensee's failure to wear alarm ratemeters while performing radiography. The inspector dettrmined that Code Services, Inc., was cited for a violation by the State during en inspection on May 4,1998, in which a radiographer was wearing an alarm rate meter that was not turned on during radiography operations. On Oct6cer 8,1998, the State of Alabama cited Code Services for a violation relating tc an incident that occurred on August 31,1998, at a facility in Alabama, in which '.he raangrapher's alarm ratemeter was not turned r n at the time of the incidert, and the helper did not have an alarm ratemeter caring radiographic operatic ns. The incident involved the helper carrying the radiographic exposure device to the next set up locatio The source was not fully retracted and secured into its shield and the helper received a whole body dose of 1100 millire j l
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3 Conclusions The inspector concluded that recurring problems appear to exist regarding failure of licensee personnel to properly wear alarming ratemeters. An apparent violation was identified where on February 16,1999, the radiographer's assistant failed to wear an alarm ratemete ;
3. Observation of Radiographic Operations and Office inspection (87120) Scope The inspector observed the licensee perform a radiography operation, discussed plans for the operation, and reviewed selected records to determine if the licensee was operating safely and in accordance with NRC requirement Observation and Findinas On March 17 and 18,1999, the inspector conducted a reciprocity inspection of Code Services, Inc., performance of radiographic operations at a temporary job site located on NASA Marshall Space Flight Center, Huntsville, Alabama, and at the field facility in Madison, Alabama. The radiographic operations involved the licensee performing radiography on 3/4 inch piping, approximately nine shots, ,
outside the nitrogen building, S-4659. The work area was a pipe shed located '
approximately 30 yards from the nitrogen building. Radiographic operations were performed by a licensee's radiographer and a radiographer's assistan l The inspector observed the licensee set up the area for radiography by <
establishing a posted rope boundary around the shed prior to exposing the source. After ensuring that the area was free of unnecessary personnel and the individuals in the nitrogen building were informed of the radiography, the radiographer removed the camera, an Amersham Model 660B, S/N B-3410 containing 58 curies of irid'm-192, from the secured dark room of the vehicle and set it up in the area fc radiography. The radiographer assembled the camera with the necessary equipment and posted the high radiation area sign prior to performing radiography. While the radiographer was performing radiography, the radiographer's assistant was conducting confirmatory radiation surveys in unrestricted areas and maintaining surveillance of the roped boundary. The inspector observed that the radiographer and the radiographer's assistant each wore a combination of a current TLD, a calibrated self-reading pocket dosimeter and a calibrated operating alarm ratemeter during radiography, in addition, the inspector observed that the survey instruments possessed by the radiographer and the radiographer's assistant were calibrated and properly functionin At the completion of each radiography operation, the inspector observed the radiographer approach the camera from the rear with the survey meter and his
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alarm raiemeter on, survey the entire circumference of the camera and the guide
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tube and ensure that the source had been completely retracted. The inspector, on occasion performed independent radiation surveys at the roped boundary during radiographic operations and on the surface of the camera after the source had been retracted at tne completion of radiography. Independent measurements by the inspector indicated 0.7 mr/hr maximum along the roped boundary and approximately 30 to 35 mr/hr on the surface of the camera.
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4 l During the inspection at the field office of Code Services, Inc., the inspector interviewed the RSO and selectively reviewed records to determine certification and qualifications of the radiographer and radiographer's assistant who were conducting radiography at the temporary job site at NASA MSFC, Huntsville, Alabama. Through discussion with the RSO and review of records, the inspector
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determined that both the radiographer and radiographer's assistant received l required safety training. The inspector verified that the State of Alabama j approved the radiography training received by both the radiographer and the i radiographer's assistant and that they were certified under the State of Alabama. '
The inspector also reviewed records of audits and utilization logs of the radiographer and the radiographer's assistant and determined that they were audited by the RSO within the last six months and the utilization logs were properly completed and up to dat Conclusions From the observation of radiographic operations and the inspection at the field office, the inspector determined that the licensee conducted activities in accordance with the license conditions and NRC regulatory requirement EXIT MEETING SUMMARY An exit meeting was held with the licensee representative on March 18,1999. The overall findings from the inspection were discussed, including the concerns that were identified by the MSFC RSO and the associated apparent violation of 10 CFR 34.47(a). The licensee reemphasized that management is new to the radiation protection program; however, they expressed a commitment towards the support of the radiation protection program and compliance with NRC regulatory requirements. The licensee did not specify any information reviewed during the inspection as proprietary in natur l l
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ATTACHMENT 1. PERSONS CONTACTED Licensee
- Chris Chandler, Technical Manager and Radiation Safety Officer James Chandler, Radiographer Tim McMurry, Radiographer's Assistant
- Attended the March 18,1999, Exit Meeting 2 INSPECTION PROCEDURE USED IP 87120 Industrial Radiography Programs 3. ABBREVIATICNS USED CFR Code of Federal Regulation Ir-192 Iridium 192 MSFC Marshall Space Flight Center mci millicurie mrem /hr millirem per hour NASA National Aeronautics and Space Administration NRC Nuclear Regulatory Commission RSO Radiation Safety Officer
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l JPEN PREDECISIONAL ENFORCEMENT CONFER ' .f AGENDA CODE SERVICES, IN APRll 22,1999, AT 1:00 P.M.
l NRC REGION ll OFFICE, ATLANTA, GEORGIA OPENING REMARKS AND INTRODUCTIONS L. Reyes, Regional Administrator 1 NRC ENFORCEMENT POLICY A. Boland, Enforcement Officer Enforcement and Investigations Coordination Staff Il SUMMARY OF THE ISSUES L.Reyes l l
I STATEMENT OF CONCERNS / APPARENT VIOLATION D. Collins, Director Division of Nuclear Materials Safety LICENSEE PRESENTATION R. Lambert, Managing Partner Code Services, In V BREAK /NRC CAUCUS Vl NRC FOLLOWUP OUESTIONS Vill. CLOSING REMARKS L.Reyes
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Enclosure 3 i