ML20126A581
| ML20126A581 | |
| Person / Time | |
|---|---|
| Issue date: | 12/07/1992 |
| From: | Amato C, Costello F, Kirkwood A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20126A557 | List: |
| References | |
| REF-QA-99990001-921209 99990001-92-28, NUDOCS 9212210131 | |
| Download: ML20126A581 (6) | |
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U.S. NUCLEAR REGULATORY COMMISSION REGION I Report No.92-028 Docket No. 99990001 Licenso No. General License Priority N/A Category _,Ff2 Licensee: _lancElerjarea Sewer Authority 130 CentqrvJlle Road lancasten Pennsylvania 17603 Faci 1ity Hame: ,_Eup_GRRhanna Water Po11tLtigIL_Qpnttp1 p1 ant _
Inspection At: 1]60 Bljue Rock Roaj,. Washington Doro, Pennsylvania and NRC RI office, Kina of Prupph_Iteluigylvanin Inspection Conducted: l{ovember 4, 1992 an(1_Fovemller 16 thrSitqh 18, 1992 Inspectors: 1 wy - L tzt n - I.1 N l al date Anthony 1prkwood, IIcalth Physicist 1
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~ Charles Amat'o, IIcajth Physicist
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I Approved by: 4 IN Qf date
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Francis M. Costello, Chief
! Industrial Applications Section Ingpection Summaryl Special Innpoction conducted on Noverib er 4,_
add 16 throuah 18, 19_22_(JLeport No.
.2_9990001/92-0281, b_reas Inspected: Use and removal of a generally licensed, process line nuclear gauge.
Results: In the areas inspected, two apparent violations were identified: failure to assure testing at specified intervals (paragraph 6.0); and removal of the device by persons not specifically licensed to perform such activities (paragraph 5. 0) .
9212210131 921209 RE01 GA999 ELOLAN 99990001 PDR
I DETAILS 1.0 Persons Contacjigd Jerry liarris, !!cisay Mechanical, Ltd.
Andrew Iloisey, President, llelsey Mechanical, Ltd.
- A. Peterson, Radiation Safety Of ficer, Kay-Ray /Sensall, Inc.
John Snyder, Executivo Director, Lancaster Area Sewer Authority (LASA)
- Michael Williams, Plant Superintendent, LASA
- Attended the exit meeting on llovember 4, 1992.
- Interviewed by telephone.
2.0 packrtround On September 29, 1992, Lancastor Area Sewer Authority (LASA) contacted the Pennsylvania Bureau of Radiation Protection (BRP) and -asked, how could they dispose of a gauge. BRP notified the 11RC. Two BRP staff members went to the site the same day. The BRP personnel found the gauge source head in the Sludge Grinder Room dust plato f acing down with the lever in the measure position. They surveyed the source head and measured one rom por hour on contact with the dust cover and 150 millirem por hour at six inches from the dust cover. The DRP staffers directed that the lever be locked in the source storage position and the head moved to a secure location which turned out to be a locked room within the Oil Room.
3.0 Grg.ajli zati o_n The Lancaster Area Sower Authority operates the Susquehanna Water Pollution Control Plant (SNPCP). Staffed by 13 employees, the SWPCP operatos round-the-clock. A maximum of five employees are present on any one shift. John Snyder has been Executive Director sinco June 1983 and a LASA employee since December 1979. Michael Williams has been Plant Superintendent for 11 years and a LASA employee for 18 years.
The Superintendent stated that to the best of his knowledge the gauge was never used and they were unaware of the presence of a radioactive source until the gauge was moved.
4.0 facilities and Equinment The construction of the SWPCP began in 1972 and was completed in 1975. Garden Spot Electric, a SWPCP contractor, ordered the Kcy-Ray System 3500A Liquid Slurry Density Gauge consisting of a detector and source head model 7050, serial no. 1256, weighing approximately one hundred pounds. The Cesium-137 source is located within a 0.625 inch diameter 1 cad collimator within a dome which produces a 7 to 10 degree' divergent beam. The dome is fixed tc a base plate. A 0.03 inch thick aluminum dust plate is located within a recess
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I beneath the domo. The source activity was 250 millicuries in 1972 and was calculated by the NRC inspectors as 157 mci during October 1992. The gauge is fitted about a pipe by bolting the heads together at four locations. The result is a non-slip mounting. The heads may bo mounted vertically, horizontally or in an inclined position. Control is offected by a three position lover with indents to insure
" locking" in the desired position. In the store position a lead block is moved in front of the sourco. In the referenco position, one or moro lead collimators are placed in the beam.
While in the measure position, the beam is unattenuated. The gaugo is shipped with an instruction manual and a padlock with keys. The manual was received on August 20, 1975. The Liquid Slurry Density Gauge was mounted vertically on a pipe, downstream of the sludge grinders in the Sludge Pump Room (sludge is the solid sediment removed from settling tanks and is ground to prepare it for additional treatment). While mounted in the sludge grinding room, the dust plato faced a wall behind which was carth. An emergent beam would be directed toward an uninhabited area.
Kay-Ray did a post installation check (KR. No. 305). Survey results indicated the contact exposure rate was 7 mR/hr. The NRC inspectors observed an aged, dusty but legible warning label required by 10 CFR 31.5(c) affixed to the upper surface of the base plate beneath and to the left of the control lover. The label conformed to the requirements of 10 CFR 20.203 (a) (1) .
5.O fn y Lq o R e m o_yft1 LASA awarded a contract to !!aisoy Mechanical, Ltd., of Columbia, Pennsylvania, to upgrade the Sludge pump Room equipment and dispose of removed equipment and material.
Removal of the density gauge was added to the initial scope of the work by an addendum. The device was removed - by Heisey employees Jerry Harris and Jay Booth on the morning of September 11, 1992, during the first work hour and carried by the two men to a skid approximately ten foot away from the work area. The four bolts were cut. One-man held the source head in place while the other removed the detector head and placed it atop a nearby valve housing. Both men then moved the sourco head. For the remainder of the workday, seven hours, the men continued other tasks in the work area. Mr.
Ilarris could not remember what direction the device dome was facing when it was carried or when it was placed on the skid.-
The entire projoct was completed on September 18, 1992. The following week only Jay Dooth returned with Don Rambler. An y--. g --
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I electrician was also present, but assumed to be out of the exposure work area.
10 CFR 31 (c) (3 ) (11) requires that the testa required by paragraph (c) (2) and removal from the installation are performed by a person holding a specific licence pursuant to Parts 30 and 32 of the Chaptor or from an Agreement Stato.
The findings that the devico was removed and moved by pornonnel not holding a specific licenso represents an .
apparent violation of 10 CFR 31.5(c) (3) (11) .
6.0 pone PetimatioD Noither llolooy employee could recall the time it took to remove and move the gauge and its orientation while being moved. Dono estimaton are therefore baned on unknown valuon for time and orientation plus the exposure raten meneured by the 13RP staff members. Exposuro during removal in not considered significant if the lover woro in the measure position since the gamma ray beam would 'bo pointing toward the wall. Dono estimates are as follows.
Case I. Source head carried between the men with the dome facing up or down and the base plate parallel to the floor and the lover in the measure position.
The beam would pass betwoon the employeen and no done renulto.
Case II. Same as Case I, except that the nource la rotated 90 degreen and the beam in parallel to the floor, but not directed toward either man. No done would be delivered to either employee, Caco III. Game as Capo II but the employceo walk not nido by side as in the other throo cases but with the detector head between them and the dunt cover nix inches from a body ourface of one employco. If the transfer time were ton minuten, the done to a limited body area of one employee would be 22 mren This done is well below the whole body standard for occupational workers (5000 mrom/yr) and the general public (500 nrem/yr) .
Case IV. Source base plate dust cover pressed into outer garments of ono worker. Tho - done would be 148-mrom, F
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4 Either no dose was - received by the workero who moved the source or the maximum done would be 148 millirem to a small ?
portion of a worker's body.
The NRC inspectors surveyed the domo, base plato and dust 1 cover using an ion chamber and a Golger-MuUcr rato motor.
Some of these readings were taken af ter the dome had been i 4
tilted to f acilitato measuromonts along the dust plato. There was no statistically significant difference betwoon the rate I motor readings. But, maximum intensity was noted off of what should have boon the radiation beam conter lino. And, the IJRC readings were significantly below the values reported by the Pennsylvania BRP inspectors. The !!RC inspectors discussed this by phone with Kay-Ray's Radiation Safety Of ficer who opined that the function selector mechanirm might have malfunctioned. Such a malfunction could place the movablo lead collimators in the beam and readings woro made in the referenco position. Sinco source shield geometry information i was not available, permitting accurato calculation of exposure rato as a function of distance from the sourco, the NRC used the values reported by personnel of Pennsylvania's BRP to estimato doses. Those values are the high values and their use in estimating the dosos noted in Section 6 above resulto in conservative dose estimates.
The NRC inspectors wiped the dust plate, exterior of the dome, and areas where the gauge was mounted and to which it was removed. Field and NRC laboratory counting of the wipes indicated no leakage of radioactivo material. The licensee had not leak tested the device since August 20, 1975.
10 CFR 31. 5 (c) ( 2 ) requires pursuant to general license conditions that the device shall be leak tested for proper operation of the on-off mechanism and indication at-intervals not to exceed six months. The finding that these tests were not performed, represents an apparent violation of 10 CFR
- 31. 5 (c) (2) .
7.0 SpuredLpisposit ion The detector head was removed by licisey and transferred to the Kimbel Iron Works in Lancaster, Pennsylvania on an unknown date. A representative of Kay-Ray /Sensall packed and removed the source head on November 12, 1992. The head has been tranaferred to the firm's Illinois facility.
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e 8.0 Exit Meeting An exit mooting was hold with the Plant Superintendent in his office at the conclusion of the inspection. Mr. Williams was advised of tho interium inspection findings and violations.
Following completion of the inspection in Region I, Mr.
Williams was appraised of the inspection findings.
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