IR 05000073/1990002
| ML20034B749 | |
| Person / Time | |
|---|---|
| Site: | Vallecitos Nuclear Center |
| Issue date: | 04/13/1990 |
| From: | Louis Carson, Wenslawski F, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20034B748 | List: |
| References | |
| 50-073-90-02, NUDOCS 9004300292 | |
| Download: ML20034B749 (8) | |
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NUCLEAR REGULATORY COMMISSION
REGION V
Report No. 50-73/90-02 License No. R-33 Licensee:
General Electric Nuclear Energy 175 Curtner Avenue San Jose, California 95125 Facility Name:
General Electric Nuclear Test Reactor (NTR)
Inspection at:
Vallecitos Nuclear Center
Inspection Conducted: March 22-3, 1990 Inspector:
f//l8 L.
- arsorT II, adiati 5pecialist Date Signed.
.Y GV '
W/?bO F. A. Wenslawski, Chie" DWte Signed Facilities Radiological Protection Section Approved by:
O.
Mub.
9 l# 31' D G. P.
s Chief Date 55gned Emergen Preparedness and Radiolo cal Protection Branch
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Summary:
Areas Inspected:
This was an unannounced special inspection.by two regionally based
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inspectors, to review an allegation (RV-90-A-0012) involving the adequacy of radiological protection practices applied to contract workers visiting
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the facility.
Results:
Although certain facts alleged by the individuals were found to be true, the essence of the allegations involving improper radiation protection practices was not substantiated.
One non-cited violation-involving recordkeeping was identified (see section 5.b).
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DETAILS 1.
Persons Contacted Licensee Personnel
- R. W. Darmitzel, Manager, Irradiation Processing Operation
- J. H. Cherb, Manager,ior Licensing Engineer Nuclear Safety G. E. Cunningham, Sen D. R. Smith, Manager, Nuclear Test Reactor B. M. Murray, Radiological-Engineer (RE)
M. Springsteen, Radiation Monitor Technician J. P. Conway, Facilities Maintenance / Contractor Relations Coordinator (FM/ CRC)
State of California J. R. Curtis, Associate Health Physicist
- Denotes those persons attending the exit interview on March 23, 1990.-
i In addition to the individuals noted above, the inspectors set and held discussions with other members of the licensee's staff.
2.
Background On February 5,-1990, NRC Region V received a telephone call from an attorney representing two Wividuals (individuals A & B).
The attorney-stated that his clients had been contract workers at the General--Electric Vallecitos Nuclear Center (GE-VNC), and on January 15, 1990 contamination.
was discovered on a door on which the individuals were working and on the-individuals' clothes'.
A whole body count-(WBC) was performed on the workers but the technician who performed the count would not reveal the results to the individuals.
The individuals were subsequently given radiation training and dosimeters and sent-back to work.
Several days later both workers complained of illness.
The attorney also provided inform: tion on other unrelated contamination events which had been
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reported to the two individuals.
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3.
Contact With the A11eoers On February 8, 1990, Region V was able to contact one of the two
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individuals by telephone (individual A).
Individual A was-questioned regarding the specifics of the allegations.
He stated that he and his
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co-worker had been tasked to remove and replace a damaged 2-foot section
of slats from the bottom of a rollup door in Building 105.
Both individuais were being escorted during the work.
After removal, the damaged portion of the door was surveyed and the inner side of the door,
" had a lot of clicks on the Geiger-Counter." The two individuals were frisked and, "the Geiger-Counter went off again." At this point the two individuals were told to receive a WBC.
Both workers were then shown a-training film on radiation, issued dosimetry and escorted back to the job.
At the end of the day they were again given WBCs and sent home.
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They returned the following day to complete work on the door and received
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i a third WBC at the completion of their work.
Individual A was disturbed that activities (which he described as " processing X-rays")' continued
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"the whole time" they had worked on the door.
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4.
State Involvement-
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Because other portions of the allegation involved activities licensed by
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the State of California, NRC notified the Department of Health Services, i
Radiological Health. Branch of the allegation. The-State elected to send
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a State inspector at the time of the NRC inspection.
Findings of the
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State inspection are unrelated to work performed by-the two individuals j
and are not part of this report.
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NRC Findings
a)
Prejob Planning The inspectors examined the licensee's procedures governing radiationprotectionofvisitors{VNCSafetyStandardNo.6.1,
" Radiation Protection of Visitors' and VNC Safety Standard No. 8.2,
" Radiation Training for Visitors." Procedure 6.1 states that, "The'
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Escort is responsible for planning the sequence of events that is to occur during the visit and for coordinating the visit with Security, Nuclear Safety, and the Area Manager (s)." This procedure further states that film badges, pocket dosimeters, training or bioassay are not required if no posted radiation areas will.be entered and the visitors will be under continuous escort by a VNC employee familiar
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with all area alarms and evacuation actions.
The escort is to then familiarize the' visitor with the area alarms and advise the visitor
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that his/her travels onsite are restricted.. The. licensee's rocedures regarding the above are consistent with 10 CFR 19.12, p' Instruction to workers," in that 10 CFR 19.12 allows the extent of instructions to be commensurate with potential radiological health protection problems.
According to the licensee, individuals A&B had been at GE-VNC on.
L January 9, 12, 15, 16, and 24 of this year.
Individuals A&B were on.
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site originally to perform maintenance on doors located on Building 105 and 106, and the work scope was later increased to Building-102E.
The extent-of the work included repairing broken doors, i
resetting limit switches, replacing a 2-foot section on a door
bottom, and ' repairing operating mechanisms in non-radiological areas l-of GE-VNC.
The responsibility for directing the above work (as well as any work involving contractor repair of facilities) rests with the Facilities Maintenance /ContractorRelationsCoordinator(FM/ CRC).
The FM/ CRC had worked at GE-VNC for fifteen years.
When interviewed by the inspectors he appeared knowledgeable'in VNC procedures 6.1 and 8.2 as well as general radiological protection practices.
The FM/ CRC stated that he had evaluated all areas in which
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individuals A&B would be working, and with the exception of building 105D, concluded that dosimetry and training were not necessary.
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Since the personnel access door, adjacent to the roll-up door on
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building 105D where the personnel would be workin, was posted as a high radiation area (i.e. >100 mrem /hr), the FM/C C consulted with
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the area manager respons_ibTe for the facility.regarding radiation l
protection requirements.
Procedure 6.1 assigns the area manager the
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responsibility to assure-that all visitors comply with VNC Safety
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Standards.
The area manager informed the FM/ CRC that a radiation-
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area did not-exist at the rollu) door and that he would establish-
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the radiation area boundary wit 11n building 105D anc' nat work on
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the door could occur without entering a radiation M 2.
Since the FM/ CRC had intended to continuously escort individuals A&B,- he concluded specific radiation protection training, issuance of dosimetry and_an entry whole body count were not required. The FM/ CRC stated that he verbally ~ instructed individuals A&B on area alarms and general on site travel restrictions upon their initially reporting to work.
He further stated that when work began at building 105D he instructed them to the meaning of the posted
radiation area within the building and of the requirement to not'
enter the posted area.
The inspectors concluded that the actions taken by the FM/ CRC were'
consistent with the licensee's procedures, and the instructions plus continuous escort provided to the workers. met the intent of 10 CFR 19.12.
b.
Buildina 105D and Area Manager's Actions-Building 105D is the north exposure room for the NTR reactor
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facility.
The center of the south wall of the. room contains a large
concrete shielding block, which the licensee refers to as the
" monument." The concrete shield has shielded slots to allow access
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Neutron radiography.
continued while the workers worked on the.rollup dcor, and the radiography constituted wbGt individual A described as " precessing
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l x-rays.
The inspectors reviewed radiation / contamination survey records for building 105D.
With the reactor operating at full
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power, the shutter to the monument open and the shielded access slots open, dose rates typically were about one rem /hr (neutron / gamma) directly in front of the open slots and fell to
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about 75 mrem /hr at a distance of six feet.
The rollup door is about 20-25 feet from the monument and the access slots are angled away from the direction of the door.
Daily contamination surveys for the period January 1-22, 1990 disclosed no loose surface contamination above the licensee's detection limits of 500 dpm beta / gamma or 200 dpm alpha.-
The area manager for the NTR stated that the extent of radiation levels in building 105D were well established.
He stated that radiation levels by the rollup door were less than 2 mrem /hr and the
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personnel access door was posted as a high radiation area because of the dose rates in the vicinity of the " monument." Posting was made at the door as a matter of convenient access control.
He also stated that loose contamination is currently not found in the l
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L facility out some work activities, long ago discontinued,,did result
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in loose contamination.
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The. area manager confirmed that the FM/ CRC had contacted him-
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regarding work on the rollup door.
He informed the FM/ CRC that he would establish a-radiation area boundary more representative of'
actual conditions and work could' proceed without the need to enter a posted radiation area (note 10 CFR 20 defines a radiation area as >
5 mrem /hr.).
The-area manager stated that he conducted a radiatioii survey around the rollup door and established a rope and posted barrier about six feet inside of the building, w/hr.
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levels at the barrier being approximately 2 mrem The area manager stated that he did not document the survey.
The failure to
documentthesurveyrepresentsaviolationof10CFR20.401(b)Iteria i
however, the violation is not being cited (NCV) because the cr-in 10 CFR 2 Appendix C, Section V.A is satisfied. 'It is also noted that VNC Safety Standard 5.1, " Area Classification" requires area managers to involve the Nuclear Safety Department when declassifying a radiation area.
The area manager had been manager of the NTR facility for eight years and has worked at VNC for twenty four years.
He stated that he was aware of the VNC requirements for
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declassifying a radiation area but his close familiarity with the NTR facility and the radiological conditions " lulled" him into declassifying the area around the rollup door without.the i
involvement of the Nuclear. Safety Department.
The area manager's
failure to involve Nuclear Safety wen he changed the posting status of the 105D rollup door area represents-a violation of internal VNC procedures but in this particular case is not considered a' violation of NRC requirements.
The licensee's internal investigation of allegations made by individuals A&B identified this shortcoming and appropriate re-instruction of the area manager had already occurreu at the time of the inspection.
Had the area manager followed
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procedure 5.1, it is likely that the survey used to declassify the area would had been documented.
Because a detailed, documented survey was not available showing the radiation levels in the vicinity of the rollup door, the inspector requested a survey be performed in'his presence.
This survey was performed on March 23, 1990 with the NTR at' full power, the shutter to the monument open, the exposure doors (slots) open and a cassette in the exposure beam.
Theseconditionsresultinthehighest i
worst case" radiation levels within Building 105D and represent the conditions to which the workers would have been exposed.
The results were as follows:
Location.
Gamma D.R.
Neutron D.R.
Total D.R.
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a)
Contact on Monument 450 mR/hr 550 mrem /hr 1000 mrem /hr (at open access slots)
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Roped Boundary 0. 5 1. 5 2.0 c)
Roll-up door 0.3 0.75 1.05
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Reading (b) represents the highest dose rates six' feet from the rollup door-inside Building 105D, at the location closest to the H
cassette monument.
Reading (c) represents the area in which individuals A&B were working.
During actual radiography operations, the shield doors to the cassette slots are closed,-thereby reducing radiation levels from those identified above and the shutter to the monument is periodically closed which essentially eliminates anj significant radiation levels in room 105D.-
It is noted that 10 CFR 20.202 " Personnel Monitoring" does not
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require personnel monitoring devices ~ unless a person is likely to receive a dose in a calendar quarter in excess of 312 mrem.
Considering the low dose rates and the short time-(a few hours)
expected for the' work, NRC regulations would have not required dosimetry equipment for work on the rollup door, c.
-Contamination Discovery 1990, individuals A&B beheet high and used foran repair work on l
On January 15 dooratBuilding1050.
The door is 18 shipping and receiving.
The lower portion of the door _had been-damaged.
Individuals A&B were to remove and replace a 2-foot
section of slats and repair the associated door parts.
The NTR was j
operating at full power during the time individuals A&B were l
working.
Also, an escort (the FM/ CRC) was with individuals A&B
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during the time of the job. -After the 2-foot lower section of the-
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door was removed, the FM/ CRC as-a matter of general practice
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requested that the Nuclear Safety Department survey the 2-foot-door
section prior to disposing of~it.
The results of the survey disclosed that a small area of the door's lower section was-contaminated with fixed teta gamma activity of 1250 dpm.
A security detector and conduit for the door were also found to have slight fixed beta gamma contamination at 1000 dpm.
No. loose contamination was detected.
Because individuals A&B had come in contact with the' door, the FM/ CRC had the radiation protection monitor technicians (RPM) frisk them for personnel contamination.
The RPM was on extended military leave during the inspection and not available for interview.
However, the FM/ CRC was present during the frisking and he stated a
that he was certain that no contamination was idsntified on the
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individuals.
The absence of removable' contamination and the low level of fixed contamination found on the door would' tend to' support
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the FM/ CRC's statement.
The FM/ CRC. stated that because contamination was discovered at the work site and to provide further assurance that the individuals-were not contaminated, he sent them to be whole body counted (WBC).
He also considered the situation appropriate to enter the individuals into-the VNC radiation dosimetry program, which involved. attending the " Initial Radiological Safety Orientation" (IRS 0) training session and the issuance of film badges.
Upon completion of the WBC, training and issuance of film badges, the individuals returned to finish work for the day. At the end of the day (January 15th)
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both individuals were instructed by the FR/ CRC-to again be WBC (as a matter of1 prudence) before leaving the site.
Both individuals
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returned on January 16th to briefly perform minor adjustments on the 105D rollup door and were again WBC prior to leaving the sitet
The inspector interviewed the technician who performed the WBC regarding the alleged resistance _on his part to disclose the
.results.
He' stated that he did not remember either of the-
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individuals specifically requesting the results and if they had, he.
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would have told them.
It should.be noted that all WBC results:are forwarded to the. radiological engineer for official interpretation of the data,-although the technician-is sufficiently knowledgeable
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to recognize and roughly interpret-a positive result.
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inspectors examined the data printouts for each WBC_ performed on
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each individual and discussed-the results with the radiological-a engineer.
No activity above background was identified on any of the l
WBCs.
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The' inspectors also reviewed the licensee's vendor supplied
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dosimetry results for the film badges issued to individuals ~A&B.
No-measurable radiation dose was reported. -The licensee also stated-
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that the FM/ CRC's film badge results also showed no measurable dose--
for the exposure period inclusive of the time'he spent as the individuals' escort.
The licensee had on file copies of letters l
sent to both individuals reporting the radiation dose and bioassay
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_(WBC) results.
Both letters were issued within the time constraints
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(30 days from the-time a request is made or within 30 days after the exposure of the individual has been determined, whichever is later)
of 10 CFR 19.13(c).
(Note, the letters are dated 2/14/90 and the=
licensee's film badge report from his vendor is dated'2/7/90).
d.
Conclusions
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ortion of the f
building 105D west rollup door.It is.a fact that contamination was identi Statements by the FM body counting results and the low' level and' fixed nature of the.
contamination all indicate that personnel contamination did not
occur.
Personnel dosimetry was not issued nor did personnel attend the IRSO training course prior to start of work.- Fundamental instruction regarding alarms and on site travel restriction were
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provided by the escort at the. start of work.
This was consistent with the licensee's-procedures and adequate to meet NRC requirements.
Dosimetry and bioassay (WBC) results, although not provided immediately, were provided within the time constraints of NRC regulations.
Film badge and whole body counting results-indicate no measurable radiation exposure.
Survey records of the -
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work area and door support the negative dosimetry /WBC results.
The-licensee's action upon-identification of the contamination appeared consistent with good health physics practices.
No cited violations l
of NRC requirements were' identified.
One NCV concerning record keeping was identified.
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6.
Exit Interview
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The inspector met with the individuals identified in paragraph (1) at conclusion of the inspection.
The scope and findings of the inspection were sumarized.
The licensee was informed of the apparent NCV
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identified.in paragraph 5 b.
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