ML20058P354
| ML20058P354 | |
| Person / Time | |
|---|---|
| Issue date: | 07/25/1990 |
| From: | Kirkwood A, Jason White NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20058P353 | List: |
| References | |
| REF-QA-99990001-900806 99990001-90-01, 99990001-90-1, NUDOCS 9008160222 | |
| Download: ML20058P354 (4) | |
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U. S. NUCLEAR REGULATORY COMMISSION REGION I i
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. Report No. 99990001/90-001 j
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Doc'ket No. 99990001 t
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~ General Liceh.,
iLicenseet USX - United States Steel Corporation 1
Fairless Works i
Fairless Hills, Pennsylvania 19030 t
-Facility Name:t USX - United States Steel Corporation, Fairless Works
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Inspection At:
Fairless Hills, Pennsylvania
'i inspection Conducted:. May 9, 10 and 17, 1990-t i
- Inspector
- M ove d "P. 6, 19 9' O AnthonyK{fkwood,Healt, Physicist.
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Approved by:-
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') Nuclear Materials Safety -Section C 6hn R. White, Chief
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. Inspection Summary:
Special, Announced Safety Inspection conducted on May.9, 6
-10,.and17,1990(SpecialInspectionNo. 9999001/90-001)..
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Areas Inspectu:
Review of the circumstances leading.to-the minor. exposure of:
- personnel by a Generally Licensed nuclear density; fixed gauge.
The areas 4
inspected included licensee operations and organization, background inspector observations of.the gauge, training, radiation safety, and NRC measurements.
t Results:' Two apparent violations were observed:
unauthorized removal of the i
gauge (Section 3); and failure to maintain records of installation and removal of.the. gauge (Section 6).
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L DETAILS 1.
Persons Contacted
' Donald Rizer, Jr., Acting Manager Employee Relations James Jones, Department Manager - Safety, Security, Environmental Health and Industrial Hygiene (R$0)
- Margaret Phillips, Staff Supervisor - Industrial Hygiene Joseph DeMilio, Area Manager, Process Control - System Repair John Krut Team Leader - Systems Repair 2.
Licensee Operations and Organization USX - United States Steel Corporation, Fairless Works, uses both specifically and generally licensed nuclear gauges on its process control lines. The inspection was limited to the causes leading to personnel exposure by a generally licensed Gamma Industries Model GR-100, thickness gauge, containing 1000 mil 11 curies of americium-241.
This gauge is located in the Sheet and Tin Division, on the 80" pickling line and used to measure the thickness of long rolls of sheet steel.
Radiation Safety is administered by the Radiation Safety Officer who is also the Department Manager for Safety, security, Environmental Health and Industrial Hygiene. The RSO reports administratively to the Division Manager - Employee Relations, and on radiation safety matters to the Chairman of the Corporate Radiation Committee in Pittsburgh.
The RSO has been extensively assisted, for this incident, by the Staff Supervisor of Industrial Hygiene who reports directly to him.
Fairless Works has a plant General Manager who reports to a Vice President in the Pittsburgh corporate office.
No violations were identified.
===3.
Background===
On May 3, 1990, the Region I office received a call from the Radiation Safety Officer of USX, Fairless Works, Pennsylvania, reporting a shutter failure on a fixed gauge. The failure was discovered on April 17, 1990, when three employees were assigned to clean and calibrate the g3uge.
Up-until the time these employees removed the source head, they were performing routine duties. They removed the source head, containing the americium-241, to determine if an electrical fault was preventing the indicator lights from functioning. After an electrical fault was ruled out, a survey meter was used to determine whether the shutter was open and the source unshielded. The shutter was determined to be open. The source port was then shielded manually, and the source head brought back to a storage area outside the electronics shop.
It was later determined by a contractor that the shutter mounting posts had sheared off, voiding shielding and electrical indication of shutter position.
This resulted in minor, but unplanned radiation exposure to the workers involved in the cleaning and calibration of the gauge.
Relative to the three emplyees involved, the highest total estimate for whole body exposure was 22 millirems; and the highest estimate for extremity exposure was 19 millirems.
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A breakdown in licensee procedures occurred when the Team Leader failed to respond to a no light indication as being a shutter open condition. At that time the RSO should have been notified and work suspended.
Of the three workers interviewed, none indicated that they had removed a source in the past. They did feel under pressure to complete the job owing to layoffs of personnel at USX, They did not contact the RSO prior to removing the source head for an electrical check nor did they consider the shutter open when neither on or off indicator lights were working.
A combination of eagerness to perform their jobs and lack of appropriate instruction contributed to their unnecessary exposure.
10 CFR 31.5(c)(3) requires that a general licensee shall assure that removal from installation of a device containing radioactive materials be performed by a person holding a specific license to perform such activities.
None of the employees of USX, at this location, are authorized to perform this function.
This is an apparent violation of 10 CFR 31.5(c)(3).
4.
Inspector Observations of the Gauge The inspector observed the following relative to the gauge design:
a) The shutter mounting post failed, allowing a shutter open condition to exist without a red light indication, b) A shutter open indication does not occur until the shutter is nearly in the open position, allowing a partially open shutter to indicate green or closed.
These items will be followed up with the equipment manufacturer.
5.
Training All the employees had attended at least one formal training session given by contractors, and the team leader gave several reviews of safe job procedures (SJP) involving gauge work.
However, no record of course content was available for review.
The SJP's review mentioned the need for de-energizing power to the gauge prior to work, or checking with a foreman on unusual conditions.
It also mentioned to check the gauge with a survey meter.
All the employees interviewed stated they were unaware on April 17, 1990, of the USX requirements to treat a no light condition as a shutter open condition, or to contact the RSO in this event.
No violations were identified.
6.
_ Radiation Safety The Gamma Instruments, Model GR-100 on the 80" pickling line was damaged in an accident which occurred around November-December 1988.
The C-frame had to be replaced, although the source head was not damaged. On March 3, 1989, the entire assembly returned to the factory.
The replacement parts and source were received on August 1989 and were installed sometime after March 1, 1990.
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For the period from November 1988 to April 17, 1990 no records were maintained showing the dates. and names of persons performing installation and removal of the gauge. This is an apparent violation i
7.
NRC Measurements The inspector took measurements around the C-Frame with source head installed and with the shutter closed and open and obtained similar measurements to a dose profile done by the gauge manufacturer. The beam is well collimated. With open shutter, doses drop off rapidly out of the direct beam center from 50 mR/hr at 18" from source port, in beam center, to 0.8 mR/hr at 6" from beam center on the perimeter of the C-Frame. The inspector used a E-120 with open side window, S/N 924, for all measurements.
8.
Exit Interview The findings of this inspection were discussed with the individuals listed in paragraph 1 on May 17, 1990.
The scope of the inspection was summarized, and two apparent violations were identifiad. A summary of possible enforcement options was discussed.
It was also mentioned that a follow-up with the manufacturer would be done.
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