IR 05000927/2010017
| ML20141G244 | |
| Person / Time | |
|---|---|
| Site: | 03020952, 05000927 |
| Issue date: | 11/09/1985 |
| From: | Axelson W, Lasuk S, Paul R, Sreniawski D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20141G235 | List: |
| References | |
| 30-20952-85-03, 30-20952-85-3, NUDOCS 8601100078 | |
| Download: ML20141G244 (7) | |
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. o U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 030-20952/85003(DRSS)
Docket No. 030-20952 License No. 29-02477-09 Category C(1) Priority I Licensee: United States Testing Co.,-In Park Avenue Hoboken, New Jersey 07030 '
Inspection At: Illinois Power Company's Clinton Power Station R.R. No. 3. Box 228 Clinton, IL 61727 Inspection Conducted: From September 25 to October 17, 1985 Inspectors:
S. R. Lasuk
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. A. Pau // d Date'
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Reviewed By: D. J ren'awski, hie l b Nuc ear Materials Safety Se i 2 Dfte[
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Approved By: h
. A'xelson, Chief It ' [( b b
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Nuclear Materials Safety Date and Safeguards Branch Inspection Summary Inspection from September 25 to October 17, 1985 (Report No. 030-20952/85003(DRSS))
Areas Inspected: This was an announced special inspection to review the allegations of several craft workers concerning a radiography incident on May 29, 1985. The inspection included a reenactment of the radiography operation involving the allegers to estimate their radiation dose Results: One apparent violation (unauthorized personnel were allowed to enter a restricted area during a radiographic operation - Section 7) was identifie Intentional falsification of information provided by the licensee to the ~
individuals concerned, as alleged, was not substantiate ~
8601100078 851231 REG 1 LIC30 29-02477-09 PDR
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DETAILS ' Persons Contacted Illinois Power Company Dave Hillyer, Director, Plant Radiation Protection Fred Wolking, Supervisor, Plant Radiation Protection John Funk, Supervisor, Radiological Operations Glenn Bell, Director, Construction & Procurement Quality Assurance Rich Krauth, Technician, Radiation Protection (On May 29, 1985, he was employed by U.S. Testing as a Radiation Operations Supervisor at the Clinton Power Station). United States Testing Co., In J. Grimm, Radiation Protection Officer R. Paxton, Radiographer Craft Workers Individual A Individual B Individual C
- Purpose of Inspection l
On August 27, 1985, two craft workers expressed concerns to an NRC resident inspector regarding their involvement in a radiography incident which occurred on May 29, 1985. On that date, these individuals and two other craft workers were inadvertently allowed to enter a restricted area esta)lished by the licensee during radiographic operations in the reactor cont.iinment building. They stated they received inadequate and incorrect docurientation from U.S. Testing (UST) concerning the event and their radii. tion exposures (which w' as reportedly less than one millirem (mrem)
each). They also stated that written information promised to them by Illinois Power (IP) concerning the event had not as yet been issued. Both men felt that UST and IP were " hiding something" and requested that the NRC tell them how much radiation they truly receive After a review of various UST and IP documentation regarding this event and interviews with selected involved personnel, the resident inspector felt that the matter warranted further investigation / inspection by the NRC to determine: (1) if there was falsification of the event"by UST, (2) if there was a violation of NRC requirements, and (3) the radiation exposures received by the four craft worker This inspection was conducted from September 25 to October 17, 1985, by personnel from the Region III office in cooperation with personnel from UST, IP, the NRC Resident Inspector's office, and three of the four craft workers (Individual 0 was unavailable).
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3. Licensed Program NRC Materials License No. 29-02477-09 is a radiography, Category C1, Priority I license which was issued on February 22, 1984. The latest amendment (No. 1) was issued on September 6, 1985. Box 5 on the basic license makes reference to another license (No. 37-15445-02). The material authorized under this license includes up to 100 curies per iridium-192 source and up to 200 curies per cobalt-60 source for industrial radiography; the material may be used at 1415 Park Avenue, Hoboken, New Jersey and at temporary job sites in the United State Copies of the license and documents referenced in the tie-down condition of the license, including the licensee's Radiation Safety Program, were provided by Region I for this inspectio . Onsite Inspection Activities The inspectors met with the resident inspector at the Clinton Power Station (CPS) during the afternoon of September 25 and then with Messrs. Hillyer and Grimm to review matters pertaining to the May 29 incident and to discuss the needs for a reenactment scheduled for the following morning. The inspectors were then escorted by IP personnel to the area within the containment building where the radiography operation was conducted and to the area where the four workers were located during the operatio The Reenactment On September 26, at 6:00 a.m., the reenactment was performed under the same reported conditions as those which occurred on May 29 when the craft workers entered the restricted area. Included in the -
reenactment was a rope barrier with a high radiation area (HRA)
sign' located at the bottom of the stairway leading to the 778' level to designate the HRA bour.dary. According to the lead radiographer, this was the approximate location of the HRA' barrier on May 2 Another rope, designating the restricted (radiation) area boundary,
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was located at the 803' level, the area from which the craft workers were allowed to descend to the 778' leve Each of the craft workers were asked to individually descend from
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the restricted area boundary to the 778' level to indicate their location before they were told to leave the area by a UST represent-ative who was instructed to maintain surveillance over the HRA boundary (this representative was unavailable since he is now working for another company in Texas).
During the reenactment, Individuals A & B indicated they were at locations inside the posted HRA rope barrier. However, both workers stated that the area was not roped off or posted during the actual shot on May 29. Both workers also indicated they were inside the posted HRA about one minut ,
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Individual C followed a path that was outside of, but approximately parallel to the HRA boundary. He could not recall if a rope barrier was up, but did not think there was on Individual C stated that he was in the area 2-3 minutes and Individual D was walking right behind hi Polaroid pictures were taken of the pipe that was radiographed which show the positioning of the radiographic equipment and the locaticns designated by the craft worker After the craft workers left the area, the inspectors performed radiation measurements * on the 778' level while the radiographer operated the radiographic equipment, which involved the use of a 43 curie iriduim-192 source. The source crank-out/ crank-in time was determined using a stopwatch; for this part of the reenactment, one inspector was in radio communication with the radiographe Radiation measurements were made as the source was cranked-out and back into the radiographic exposure device (camera) through the guide tube and into the collimato With the source in the collimator, radiation measurements were obtained on the 778' level above the collimator and in each of the locations designated by the craft workers. Because of metal structural material in the area (which was essentially the same on May 29), a range of readings was obtained in relevant locations. The recorded reading was the highest obtained in these locations. A radiation measurement was also obtained on the first landing above the 778' leve Distance measurements were made from the collimator vertically up to the 778' level and then, from this vertical, horizontally along the 778' level to the Individual A, B, and C location Perso~nnel Interviews After the reenactment, the three craft workers were individually interviewed by the inspectors; other interviews were held with IP personne Since the craft workers expressed concern over the dose they may have received, the inspectors attempted to place into perspective their estimated radiation exposure of less then 2 mrem to personal exposures authorized by NRC regulations; they indicated satisfaction with these discussion The following information was provided by the interviewed workers:
(1) They stated that Mr. Hillyer announced at a meeting held immediately after the incident that they would receive a report concerning the incident; they had an opportunity to ask questions and participated in the discussions at that meetin * Instrumentation used during the reenactment is identified in the Attachment to this repor _
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(2) They mentioned the meeting with Mr. Grimm during which they were asked to read and sign a one page letter dated June 14, 1985 (Subject: Assigned Radiation Dose) which referred to the May 29 incident and indicated their total exposure to radiation was less than one mrem. Mr. Grimm told them that this was all they were entitled to and all they would get. They said there were errors in the letter and all refused to sig (3) Individual C stated his lawyer represents all four craft worker Individuals A and B denied this; they said they have no lawyer regarding this matte (4) In a June 25 meeting with IP personnel, the craft workers said they were told, once again, they would get a full report con-cerning the May 29 inciden As a result of discussions with IP personnel,.it was the inspectors'
understanding that the promised written detailed information the craft workers expected from IP was not furnished because of the time required to prepare, review, and approve the report and, IP's subsequent decision to place the matter of issuing the report in the hands of their attorney In discussions with UST personnel, it was the inspectors' understanding that, to the best of UST's recollection, the conditions during the reenactment were the same as that which existed on May 2 In a meeting with IP personnel during the afternoon of September 27, the inspectors briefly discussed their findings concerning the May 29 incident and stated that our report will most likely be forwarded to the NRC Region I office who, in turn, would handle any followup action, including an exit meeting with UST managemen . Followup Reenactment A subsequent reenactment with the collimator/ source located in a different position on the pipe was done on October 2 by UST/IP personnel
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and was observed by an NRC inspector. Measurements were made in the same locations as on September 26. This followup reenactment was conducted after the licensee expressed uncertainty as to whether the collimator/
source were in the correct position for the September 26 reenactmen Therefore, this reenactment was conducted with the collimator/ source in the most likely position at the time of the May 29 inciden . Dose Assessment Based on the radiation, time, and distance measurements obtained during these two reenactments, and considering the maximum time the workers said they spent in the area, calculations were made to estimate the radiation dose received by the craft workers. These calculations were adjusted to reflect use of a 63-curie iridium-192 source on May 29. The calculations showed that all individuals had received less than 2 mrem each. Speci-fically, the September 26 reenactment showed Individual A received 1.80
. mrem, Individual B 0.60 mrem, Individuals C and D 0.69 mrem eac i
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l Considering the October 2 reenactment, Individual A would have received 0.75 mrem, Individual B 0.80 mrem, and Individuals C and D 1.00 mrem each, r Conclusions-The June 14, 1985 letter from UST to the craft workers involved in the May 29 incident states, "At no time were you permitted to enter the area
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in which radiography was being performed, which was barricaded, surveilled and posted with High Radiation Area signs at the 781' elevation at the l stairs." The workers disagreed with this statement and said they entered
! the area which UST states was posted as a HRA. The workers maintain that l this area was not posted as a HRA on May 29. Because the exact circumstances
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of May 29 could not be confirmed, this allegation could not be substantiated l nor could it be refute Conservative estimates concerning the radiation dose received by the craft workers ranged from 0.6 mrem to 1.8 mrem, which does not exceed regulatory limits for individuals in restricted or unrestricted areas.
, The fact that a licensee representative removed the rope on the 803' level
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radiographic operation) and allowed the craft workers to enter the restricted area is a violation of License Condition No. 17. Condition
! No. 17 requires the licensee to possess and use licensed material in accordance with statements, representations, and procedures contained in letter dated December 1,1983 with attachments, plus other document The licensee's Radiation Safety Program (RSP) was submitted with the December 1, 1983 letter. In Attachment C of their Operating Procedures, as shown in the RSP, it states under 1.B., " Personnel who have no need to enter a restricted area or who are not adequately monitored and aware of the radiation field must not be allowed to enter a restricted are If unauthorized personnel cannot be prevented from entering the area, the source must be immediately returned to its shielded position."
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Instrumantation Used for the September 26, 1985 Reenactment Eberline, Model E-530, survey meter (NRC No. 000716), calibrated September 5, 198 . Gamma Industries, Model 2528, SMAC survey meter (NRC No. 013117),
calibrated September 12, 1985.
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