Protecting People and the EnvironmentUNITED STATES NUCLEAR REGULATORY COMMISSION
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.
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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
