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Applus RTD USA, Inc. BO Lawrence Bell Dr Williamsville, New York 14221
A~plus® I T +1 716-853-2611 • F +1 716-634-5759 www.AoplusRID.com •_E-Mail: [email protected]
SECURITY RELATED INFORMATION
United States Nuclear Regulatory Commission Region IV 1600 E. Lamar Blvd Arlington, Texas 76011-4511
Reference:
September 19, 2016
DNMS
Response to Apparent Violation in NRC Inspection Report 030-38291/2016-001; EA-16-145
Attention: Director, Division of Nuclear Material Safety (Region IV)
To whom it may concern.
At this time Applus RTD USA, Inc. would like to address the 3 apparent violations noted during the NRC unannounced inspection on February gth and 11th, 2016 at our Manchester, Connecticut office. This response will include reason for the apparent violation, corrective actions, and the date of full compliance.
Apparent Violation 1 -Administer a practical examination to a radiographer, as required by Title 10 of the Code of Federal Regulations (10 CFR) 34.43(e)(2);
Reason for the apparent violation 1-During the process of trying to schedule the radiography job on a short notice the operation manager took a qualified radiographer with a current IRRSP card and used him. The operation manager did not fully understand the requirements and did not notify the RSO of his intentions.
Corrective Actions Taken -All radiographers at the Manchester office will have a practical examination performed immediately and a schedule will be made to ensure the 6 month regulation does not happen again.
Corrective Actions to ensure no re-occurrence-All Operation Managers (OPS) and Radiation Safety Officers (RSO) will be re instructed on the requirements of 10 CFR 34.43 (e) (2). The instruction will be first done by email and then followed up by the CRSO during the monthly conference call for the RSO's to ensure full compliance and urgency to this matter.
Full compliance for apparent violation will be completed by October 15\ 2016.
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Applus RTD USA, Inc. 80 Lawrence Bell Dr Williamsville, New York 14221 T +l 716-853-2611 • F +l 716-634-5759 www.ApplusRTD.com_• _E-Mail: [email protected]
SECURITY RELATED INFORMATION
Apparent Violation 2 -Ensure that a radiographers' assistant wore separate and independent forms of a direct reading dosimeter and alarming rate meter, which are used for personnel radiation-dose monitoring, as required by 10 CFR 34.47(a).
Reason for the apparent violation 2-The reason for this apparent violation was based on misunderstanding verbiage of 10 CFR 34.47 (a). No place in 10 CFR 34.47 (a) does it state that personnel monitoring equipment must be separate from each other, it just says you must wear a direct reading dosimeter, rate alarm and personnel dosimeter (Film Badge). The assistant radiographer that was used was from our South Portland, Maine office where this model of dosimeter is acceptable to be used.
Corrective Actions Taken -Immediate corrective action was done on February 15th, 2016 by the CRSO and Eastern Region RSO during the monthly conference call with all RSO's across the country. This corrective action was to notify all RSO that when working in NRC jurisdiction and other agreement states that do not recognize a combination (single) dosimeter/ rate alarm that separate units must be worn.
Corrective Actions to ensure no re-occurrence-All RSO and radiographers has been notified that single use dosimeters/rate alarms are not acceptable at this time in NRC jurisdiction. If and when this regulation changes in 10 CFR 34.47 (a) we will notify them. ASNT and NDTMA have on the NRC docket (PRM-34-7) asking for a rule change for dual functioning dosimeter/ rate alarm.
Full compliance was done on February 15th, 2016, but continued monitoring of this issue will be on going.
Apparent Violation 3 -Ensure that its radiographers have an understanding of its license and operating and emergency procedures before allowing them to act as radiographers, as required by 10 CFR 34.43(b)(2).
Reason for the apparent violation 3 -During the hiring process and indoctrination process the operation manger failed to provide the radiographer the operation and emergency manual for industrial radiography. Also during this time frame the site RSO was also preforming field radiography and was out of the office.
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Applus RTD USA, Inc. BO Lawrence Bell Dr Williamsville, New York 14221 T +1 716-853-2611 • F +1 716-634-5759 www.ApolusRTD.com • _E-Mail: [email protected]
SECURITY RELATED INFORMATION
Corrective Actions Taken -The radiographer in question has since been instructed on the Operating and Emergency Manual for Industrial radiography and has taken the required examinations.
Corrective Actions to ensure no re-occurrence-It has been instructed to all operation managers that if a qualified radiographer is hired they must ensure that the 0 & E manual is issued and the site RSO has time to administer the required examination prior to them going on any radiography jobs. This requirement will be reiterated during the monthly safety call.
Full compliance has been done since September 1st, 2016 ..
In conclusion we would like to say that Appl us takes all radiation safety and general safety of our employees very seriously. These apparent 3 violations addressed by the NRC inspection will only strengthen our radiation program to ensure the safety of our employees. Applus hopes our corrective actions above satisfy the NRC and that no further action is required. It is also important to note that the site RSO has been removed from that responsibility and a new site RSO has been appointed.
If you have any questions pertaining to this letter please do not hesitate to contact me at (716) 279-3528 or email [email protected]
s Miske / ASNT L vel 111 (84764)
Cc: Stacey Cress Cc: Alan Crawford Cc: John Nesselbush
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