IR 05000348/1989013

Insp Repts 50-348/89-13 & 50-364/89-13 on 890509-10. Violations Noted.Major Areas Inspected:Use of Contaminated Money to Catch Alleged Thief & Failure of Operator to Follow Procedural Requirements Re High Radiation Area

ML20247R537
Person / Time
Site:	Farley
Issue date:	06/05/1989
From:	Potter J, Shortridge R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20247R517	List: IR 05000348/1989013 ML20247R514 ML20247R524
References
50-348-89-13, 50-364-89-13, NUDOCS 8908080038
Download: ML20247R537 (8)

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tp uou UNITED STATES p 'o NUCLEAR REGULATORY COMMISSION

[ -E REGION 11 g j - 101 MARIETTA STREET, * t ATLANTA, GEORGI A 30323

\*****/ dllL 2 61989 Report Nos.: 50-348/89-13 and 50-364/89-13 Licensee: Alabama Power Company 600 North 18th Street Birmingham, AL 35291-0400 Docket Nos.: 50-348 and 50-364 License Nos.: NPF-2 and NPF-8 Facility Name: Farley 1 and 2 Inspection Conducted: May 9-10, 1989 Inspector: -

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1. Date S' ned

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R. B. Sh r' i-Appreved by: /

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J /P. Potter, Chief h/ f D(tySigned Facilities Radiation Protection Section Emergency Preparedness and Radiological Protection Branch Division of Radiation Safety and Safeguards SUMMARY Scope:

This was a special, unannounced inspection to review the circumstances surrounding: 1) the use of contaminated meney to catch an alleged thief and 2) the failure of an operator to follow procedural requirements when entering an area posted as a high radiation are Results:

In the areas inspected, an unresolved item was reclassified as an apparent violation and the failure of a licensee representative to follow a plant procedure was identified as an apparent violatio The unresolved item

, concerned the unauthorized use of radioactive material to identify an alleged i

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thie The inspector observed that temporary actions were taken to pr,clude i

recurrence until permanent corrective actions could be . implemented. Plant l

management also took temporary corrective actions to prevent recurrence for the event where a licensee employee violated radiation work permit requirements in entering an area posted as a high radiation area. The licensee stated that they would also review high radiation areas for overly conservative posting B0B0038 PDR ADOCK 0500 89072640 @

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l REPORT DETAILS Persons Contacted j Licensee 1 Employees

• 0. Graves, Health Physics Section Supervisor

• R. Hill, Assistant General Plant Manager ,D

• M. Mitchell, Health ~ Phy:;ics and Radwaste Supervisor 4

• D. Morey, . General Plant Manager

• C. Nesbitt, Technical Manager '

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• J. Osterholtz, Manager Operations

• J. Walden, Safety Audit Engineering Lead-Auditor Other licensee employees contacted during this' inspection included j operators, technicians and administrative personne '

Nuclear Regulatory Commission

• F. Cantrell, Region II Project Section Chief  !

• G. Maxwell, Senior Resident Inspector

• Miller, Resident Inspector  ;

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• 8ttended exit interview

' Onsite Followup of the Unauthorized Use of Contaminated Money to Catch an Alleged Thie ,

Facility Operating License Nos. NPF-2 and NPF-8, Sections 2.B(4), authorize Alabama Power Company to receive, possess, and'use'in amounts as required, l any byproduct, source or special nuclear _ material, without. restriction to its chemical or physical form, for sample analysis or instrument calibra-

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tion, or associated with radioactive apparatus or component Technical Specification 6.5.1.6.b requires that the PORC review (1) safet evaluations for tests or experiments to veri that such actions do not !

constitute an unreviewed safety question and 2) all programs ~' required by ;

Technical Specification 6.8 and changes theret .l Technical Specification 6.8.1 requires that written procedures ~ be estab--

lished, implemented, and maintained covering the activities referenced in Appendix A of Regulatory Guide 1.33, Revision 2,197.8. Appendix A, Regulatory Guide 1.33, Paragraph 7.e.(4) ' requires procedures for contam-ination contro ~

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Piant Procedure FNP-0-RCP-29, Contamination Guidelines, provides ,

contamination control guidelines that are used within the restricted aree )

of FNP and release guidelines ifor surface contamination released to .

unrestricted areas, q In addition, 10 CFR 19.12, Instruction to Workers, states in part that all individuals working .in or frequenting any portion of a restricted area:

shall be kept informed of the . storage, transfer, or;use of radioactive materials, or radiation in such portions of the restricted area; and shall-

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be instructed of their responsibility to report promptly to- the licensee any' condition. which may lead to or cause a violation of commission regulations ' and ' licenses. or unnecessary exposure to . radiation or radioactive material, i Description of Events

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On April 29, 1989, a' licensee health physics- (HP)' technician thbught -

.of the idea .to use contaminated money. to catch an alleged thie ,

Licensee representatives stated that approximately $2,000, in i material goods' and money had been stolen in the past several months {

from licensee and contractor personal clothing in the clean chang i room. A contractor HP technician assisted the licensee HP technician in fixing approximately 500,000 dpm with scotch-tape to a $1.00 bil As a test, the bill was shielded with 3/4 inch of credit cards. and

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was found to alarm the portal monitor at the exit to the radiologically l'

controlled area (RCA) of the auxiliary buildin The plan was discussed with both the acting HP foreman and HP foreman who agree ,

with the scheme. The bill with fixed contamination was placed in i different pants pockets in the clean change room over the nights 1 of April 29, 30, and May 1 but was 'not taken.. Licensee represent- ;

atives stated that during this time extra precautions were taken to a assure that all personnel exiting the RCA used.the portal monitor !

The contaminated dollar bill was stored in an HP technician's locker

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when not being used as bai On May 1,1989, a Waste and Decon (W&D) technician, after hearing complaints of money being stolen from the dress out area, enlisted the aid of another licensee HP technician to contaminate a $5.00 bill- .1 for use as bait to catch the alleged thie i Based on interviews with personnel involved in both events, the l inspector determined that neither the group with the $1.00 bill or ;

$5.00 bill were aware of each others scheme, i The W&D and HP technicians obtained two specks of metal reading (with an E-140 probe) approximately 20,000 dpm each, and attached them to opposite corners of the bill with super glue and tape. The bill was also identified by an underlined ~ word on the front of the bill. The '

$5.00 bill was sandwiched between two $1.00 bills, placed in a  !

wallet, and found to alarm the portal monitor. The wallet was then placed in a pants pocket in the dress out area. Between 3:00 a.m. and i

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5:00 a.m. the W&D technician found his wallet on the dress out area floor with the money missing. Between 5:00 a.m. and 6:00 a.m., a person was noted to alarm the portal monitor. The HP technician at the RCA exit control point, who was not aware of either scheme, proceeded to locate the source of contamination. During this period, the day shift HP supervisor arrived for shift turnover and was apprised of

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the $1.00 scheme to catch the alleged thief. The HP control point technician located the contaminated $5,00 dollar bill and proceeded to clip the fixed contamination from the corners and retained them at the control point. The HP foreman who had a serial number from the

$1.00 bill was confused when the saw a contaminated $5,00 bill. The contamination event was documented and the person, with money that was now surveyed as clean, was released from the RCA. The group responsible for the $5.00 scheme was informed later that the alleged thief had been caugh The day shift HP supervisor assembled all HP personnel and discussed problems and possible consequences of using radioactive material in an unauthorized manner. The night shift crew was released from the sit When licensee management was informed of the events of the previous nights, they called in all personnel involved in the events that could be reached by telephone. Statements regarding each individuals participation with the events were obtained and each individual was interviewed by HP management. After each interview, where HP management discussed the consequences of the inappropriate use of contamination with the technicians and foreman, the individuals were interviewed by the assistant plant manager and again instructed about the inappropriate use of radioactive material to apprehend an alleged thie The two metal specks on the $5.00 bill were later analyzed as predominately Ce-144 (15,400 dpm), Nb-95, and Zr-95 with a combined activity of about 107,000 dpm and weight of 0.1 g The contamination on the $1.00 bill was predominately Co-58 (323,400 dpm), and Co-60 (109,340 dpm) with a total activity of about 543,000 dp The worst case Annual Limit of Intake (ALI) for the

$5.00 bill specks is Ce-144 at 22,000,000 dp The worst case ALI for the $1.00 bill is Co-60 at 66,000,000 dp Assuming an acceptable adult public exposure of 10 percent of the occupational ALIs, it is apparent that even an offsite ingestion or inhalation of the contamination would not have caused an overexposure to an adult; or at 5 percent of the ALIs, a child.

, The licensee performed the following short term corrective actions in I

addition to the individual interviews: (1) a gamma isotopic analysis was performed on the corners of the $5.00 dollar bill and on the

$1.00 dollar bill to identify the various radionuclides and microcurie content, (2) times and configurations were obtained when

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both the $5.00 and $1.00 bills were in the possession of a person, l

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and (3) dose assessments were performed to the skin of the whole body. The results of the investigation showed that the money was

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. 4 possessed in various shielded and unshielded configurations for a total of approximately 41 hour4.74537e-4 days <br />0.0114 hours <br />6.779101e-5 weeks <br />1.56005e-5 months <br /> Using VARSKIN, the- $5.00 bill-distributed a local skin dose of about 2 mrem during this time and the

$1.00 bill 'about 0 mrem during this time, HP assigned the skin dose assessed to the individuals accordingly.- 3 I

The inspector conducted interviews with W&D and HP technicians, j foremen, supervisors, and with plant managemen Based on the . <

licensee's investigation report of the events, interviews, and discussions with other NRC staff, the inspector determined that the contamination was contained on the' money in. the radiologically

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controlled area of the plant the entire time, that licensee management has no prior knowledge - of _ the events to allow intercession, and that there was no apparent risk-to the safety an health of the public caused by the event The inspector concluded after a review of licensee radiation protection procedures, the HP Manual, and-training material, that precautions and/or instructions to- plant personnel did not address - ,

the unauthorized use of. radioactive material above the station's I administrative limit of 200 dpm/100 cmr and that station training j material was not sufficient to have prevented this even The inspector informed the licensee that radioactive material was. used in a manner that was not covered by ' procedures or authorized, and that they failed to properly train personnel. involved in _the events on the I

handling and control of radioactive materia After review by Region II NRC management, this event was changed from an Unresolved Item to a violatio The Facility Operating License Nos. NPF-2 and NPF-8, Section 2.B.(4),

authorizes Alabama Power Company to receive, possess, -and use in amounts as required any byproduct, source, or special nuclear material, without restriction as to chemical or physical ' form,' for sample j analysis or instrument calibration, or associated with radioactive !

apparatus or components. On April 29; 30, and May 1, 1989; licensee l personnel affixed byproduct material to United States currency in an -

effort to identify anticipated theft of the currency, a use. of byproduct material not authorized by the Operating ~ Licenses.- 1'

(50-348,~364/89-13-01)

3. _0nsite Followup of the Failure of an Operator to Follow Radiation' Work Permit (RWP) Requirements When Entering an' Area-Posted as A High Radiation-Are Technical Specification 6.11 states that procedures for personnel ,

radiation protection shall be prepared consistent with the requirements of j 10 CFR Part 20 and shall be approved, maintained, and adhered to for all operations involving personnel radiation exposure.-  !

Plant Procedure FNP-0-M-001, Health Physics Manual, Section 4.1.1.7,-  ;

states that the individual will know and follow the RWP requirements for i work being performed, j l

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a '. Description of Events On May 7,1989, a plant operator was observed by a NRC resident inspector making an entry into the Unit 2, B Residual Heat Removal <

(RHR) pump room, a posted high radiation area, without dosimetry required by RWP-0-89-0003-B. The RWP was issued to cover routine entries into high radiation areas to perform surveillance and valve operation S must have (a) an pecial Instruction alarming digital#6 requiresor dosimeter that (b)for entry a HP workers technician

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with a dose rate instrument who will survey the work area at the i start of the job and periodically thereafter. Special Instruction #2 stated that the requirements of this RWP may be changed as deemed fq necessary by HP Supervisio !

HP personnel conducted an investigation of the event and issued ,

Radiation Incident Report 89-0063. The comment section of the report '

stated that the operator called the HP office, and asked an ' unknown person, if he could go into a High Radiation Area with a high range dosimeter. The person answering the phone replied that he coul The operator interpreted this to mean that a high range dosimeter substituted for the alarming digital dosimeter and proceeded to enter the area on four occasions. A resident inspector making a tour of the plant on rounds observed that the individual had entered the area posted as a high radition area and that he did not meet the i radiological requirements posted on the RWP. The resident inspector l notified the HP office of the occurence. HP was sent to investigate I the event in the 2B, RHR pump room and noted the maximum dose rate in l the area was posted 500 mr/hr contact on the RHR pump, 80 mr/hr l general area (at 12 inches). The HP technician reported that the room did not meet the criteria for a high radiation area (100 mr/hr at  !

12 inches) but was posted conservatively. The operator was counseled  !

by his supervision on complying with RWP requirements. Also, the  !

plant manager conducted a briefing session with all operators on '

complying with radiological requirements, specifically entry into posted high radiation areas and following RWP requirement The inspector reviewed the posting on the 2B, RHR pump room and l observed that the High Radiation Area sign noted a reading of l 80 mr/hr at 12 inches on the RHR pump and read " varying levels."

Also that the apparent high radiation area was behind a rope barrier approximately 3 feet inside the door to the pump roo l

As a result of the event the assistant plant manager had both the operations department and health physics department survey their personnel as to actual practices used in requesting and granting access to high radiation area Each survey contained from 5 to l 10 questions. The inspector review the surveys and noted that HP replies indicated that HP responses to request for entry to high radiation areas never deviated from procedure requirements. However,

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a small percentage of operators responses (approximately 10 percent)

indicated that on occasion, operators were allowed to enter a high i

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radiation area without a digital alarming dosimeter or HP technician  !

coverag The inspector reviewed radiation surveys of 'the 28, RHR pump room for the past four months and noted that the highest genera area reading recorded was 60 mr/hr. The inspector interviewed-  ;

available operators and asked .what their actions would be, when

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accessing a high radiation area, where the actual high radiation area j was beyond the access door or access boundary. All operators  ;

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responded that they would comply with all requirements of the RWP an plant policy at the first boundar Some operators complained that j there were not enough digital alarming dosimeters available (the l license plans to implement a telemetered digital alarming dosimeter 1 system in 1990).

The inspector discussed with the-managers and supervisors, a concern j that high radiation area access requirements may have been deviated j from in the past, and that over conservatism in posting high  ;

radiation areas may be responsible for unnecessary requirements, and create a potential for more deviations from over conservative-postings by both operators and HP. The licensee representatives agreed that posting of high radiation areas needed additional revie The inspector informed the. licensee that the failure of the operator  ;

to comply with RWP requirements when~ entering a posted high radiation area was an apparent violation of TS 6.11 (50-348.-364/89-13-02). ,

4. Exit Interview I i

The inspector met with licensee representatives (denoted in Paragraph 1), 1 at the conclusion .of the inspection on May 10,1989. The inspector summarized the scope and finding's of the inspection and informed the licensee that the event regarding the use of radioactive material to catch an alleged thief would tentatively as an unresolved item, would be further reviewed by Region II management, and that the licensee would be notified of any changes in the status of the item. The inspector also discussed in ,

detail the violation of TS 6.11. The licensee did not identify any such -

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documents or processes as proprietary. The licensee had _ no: dissenting  :!

comment )

On June 5,1989, Roger Shortridge, NRC RII, notified Martin Mitchell, I Health Physics and Radwaste Supervisor by telephone, that after further 1 evaluation, NRC RII upgraded the event regarding the unauthorized use of-by-product material to a violatio :

Item Number Description and Reference i

50-348, 364/89-13-01 VIO - Violation for the use of byproduct  :

material in a manner not authorized by l the Operating License (Paragraph 2). I

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. 7 f 50-348, 364/89-13-02 VIO - Violation of TS 6.11 requirements for failure of a an operator to comply with RWP requirements when entering an area i a high radiation area (Paragraph 3) posted as

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