Protecting People and the EnvironmentUNITED STATES NUCLEAR REGULATORY COMMISSION
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
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August 15, 1991
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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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IN 91-49
August 15, 1991
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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
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