ML20196H709
| ML20196H709 | |
| Person / Time | |
|---|---|
| Issue date: | 06/28/1988 |
| From: | Mullauer J, Simmons T, Sreniawski D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20196H595 | List: |
| References | |
| REF-QA-99990003-880628 99990003-88-106, NUDOCS 8807060226 | |
| Download: ML20196H709 (18) | |
Text
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'U.S. NUCLEAR REGULATORY COMMISSION REGION III Report No. 999-90003/88106(DRSS)
Docket No.- 999-90003 General License No.10 CFR 31.5 Licensee: University of Wisconsin 361 Bascom Hall 500 Lincoln Drive Madison, WI 53706 Inspection At: University of Wisconsin Charter Street Heating Plant Madison, Wisconsin Inspection Dates: April 20 through June 8, 1988 Inspectors:d.[. x-v; W /h 46 /f68 T. L. Simmons Date Radiation Specialist O /5A,-
'J/ R. Mullaper, M.H.Si c/nle9 Datel I~
Radiation S ecialist Approved By: 28 D. reniawski, Chief Nu ea Materials Safety Datel [
Sec on 2 Inspection Summary Inspection on April 20 through May 31, 1988 (Report No. 999-90003/88106(DRSS))
Areas Inspected: This special inspection was conducted to review a complaint received from the International Brotherhood of Electrical Workers regarding
' generally licensed level gauges. This inspection included a review of records, interviews with personnel, independent measurements and a tour of the facility.
Results: One violation was identified: unauthorized installation of twelve level detector gauges, 10 CFR 31.5(C.3).
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DETAILS
- 1. Persons Contac.tj
- Kathleen Irwin - University of Wisconsin Legal Services C. Kent Lipsey - Building Construction Supervisor, Division of Facilities Management State of Wisconsin John Arnold - Mechanical Systems, Inc.
- Stan Novotny - Superintendent, Charter-Street Heating Plant
- P. -Michalski - Engineer, Charter Street Heating Plant Tim Morgan - Foreman, Staff Electric
- Abdul BenZikri - Health Physics, University of Wisconsin Bradley Hayden - Service Representative, Kay-Ray, Inc.
Don Freeman - Supervisor of Service Department, Kay-Ray, Inc.
Al Peterson - Radiation Safety Officer, Kay-Ray, Inc.
Eight Transco and Staff Electric employees
- Attended April 22, 1988 exit meeting.
- 2. Purpose of Inspection On April 15, 1988, NRC Region III Office received by telephone a complaint from the International Brotherhood of Electrical Workers (IBW) and the Occupational Safety and Health Administration (OSHA) regarding the installation of cesium-137 level measuring devices located in the University of Wisconsin Charter-Street Heating Plant.
Construction workers at the Heating Plant were concerned about the radiation hazards that.may exist around 20 cesium-137 level gauges.
3. Background
State of Wisconsin, Division of Facilities Management commissioned the ,
construction of a stack emission control system at University of Wisconsin Charter Street Heating Plant. A major portion of the project required the censtruction of twenty (20) fly ash hoppers. The project called for level measuring devices to be attached to each hopper.
Mechanical Systems, Inc., a contractor for the project, arranged the purchase of 20 generally licensed Kay-Ray level gauges to be delivered to the University of Wisconsin Charter Street Heating Plant. The gauges were received in June 1986. Under the direction of the Radiation Safety staff, the gauges were leak tested and secured until they were installed.
- 4. Specific Complaint and NRC Findings Employees of Staff Electric Company, Inc., and Transco Products, Inc.,
who worked at the Charter Street Heating Plant, at the University of Wisconsin were concerned about radiation hazards from 20 cesium-137 level measuring devices located on fly ash hoppers.
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Finding's fc From April 20 through June 8, '1988, the inspectors interviewed Heating Plant personnel, construction workers, Radiation-Safety Office staff-and Kay-Ray Inc, representative Officer.- The following information was obtained.
On. January 5, 1988, eight' 100 millicuries cesium-137 level detectors were installed on fly ash hoppers under the supervision of Mr. B. Hayden, a Kay-Ray: service engineer. Mr. BenZikri of:the University Radiation Safety Office and Mr. Arnold of Mechanical Systems, Inc. were present
'7 -during the installation. After the devices were mounted, Mr. Hayden removed the shutter locks, conducted operational checks, and performed leak tests and area radiation surveys. Mr. BenZikri independently performed area radiation surveys and leak tests. The results of these surveys are shown.in Attachments A and B.
On March 9, 1988, the remaining twelve gauges were installed (mounted on the hopper) by,Mr. Tim Morgan of Staff Electric Company. Mr.-Morgan stated that it took a total of three hours to mount the twelve gauges.
LWhile mounting these devices, Mr. Morgan wore a Dosimeter Corporation of
- - America (DCA) 0-200 millirem pocket dosimeter. Mr. Morgan continued to wear the dosimeter until April 13, 1988. During this period, Mr. Morgan accumulated a total dose of 40 millirem. The DCA pocket dosimeter worn by Mr. Morgan had been' calibrated on January 21, 1988, at two points as
'follows:
Expected Reading Actual Reading Variance :
50 45 -10%
150 143 -4.7%
Accordingly, Mr. Morgan received an exposure dose of 44 millirem for the period March 9 to April 13.
On April 11, 1988, Mr. Hayden returned to the Heating Plant and completed -
, the installation process. Additional radiation surveys were performed by Mr. Hayden and Mr. BenZikri (See Attachments C and D). In addition, Mr. BenZikri placed twelve film badges throughout the construction area to determine radiation exposure levels a person would receive if that .
person was continuously present.
On or about April 13, ~ Staff Electric Company and Transco workers became aware that the gauges emitted radiation. They expressed a concerns that they were being exposed while they worked around the hoppers. Mr. BenZikri returned to the plant to discuss the matter with the workers. He recommended that if the workers must work within four feet of the devices, a pocket dosimeter would be .
issued and if they work within six feet of the hoppers the adjacent shutters should be closed (see Attachment F, Paragraphs 2 through 6).
5 3
On' April 15,'1988, an individual from Staff Electric Company contacted IBW and OSHA for further resolution. On April 18, 1988, due to their continued dissatisfaction with the explanations received from the safety staff, the workers were supplied with Landauer whole body film badges.
NRC inspectors were onsite on April 20, 1988. Through independent measurements of the level gauges-and surrounding areas, the inspector's surveys were found to be in agreement with the Kay-Ray and University
~
resu!ts. The measurements obtained ware well below 10 CFR 20 limits for unrestricted areas with exception of the areas twelve inches or less from the source housing or detector (when shutter is open).
The inspectors held an information session with eight Staff Electric Company and Transco employees. The session included answering their questions concerning potential radiation hazards and demonstrating with a survey instrument principles of time, distance and shielding.
During the onsite inspection it was observed that each gauge was visibly labeled as containing radioactive material. The gauges are located approximately ten to twelve feet above the floor. Two of the hoppers are located near two stairways. Radiation levels at stair landings closest to the gauges ranged from 0.2 to 0.8 mr/hr. Although it takes only seconds to pass this area if going up or down the stairs, Mr. BenZikri recommended that a steel plate be installed on the railing of the stair landing. It was also learned that electricians must work at junction boxes attached to several of the hoppers. These boxes were located approximately five feet from the gauges. Radiation levels at the boxes ranged from 0.2 to 0.4 mr/hr.
As previously stated, Mr. Morgan installed (mounted) twelve gauges.
According to Kay-Ray representatives, mounting of devices is part of the installation process. 10 CFR 31.5 requires, any person who possesses byproduct material in a device pursuant to a general license to assure that. installation of such a device is to be performed by a person holding a specific license to perform such activities. Neither Staff Electric Company, Mechanical Systems, Inc. nor University of Wisconsin hold a specific 31 cense to install generally licensed devices. Installation of the twelve gauges by Mr. Morgan was in violation of 10 CFR 31.5.
One violation of NRC requirements was identified.
- 5. Conclusions University personnel have provided adequate radiation safety assistance since receiving the devices. Raciation levels in the unrestricted areas are well under Part 20 limits. On contact the devices measured up to 35 mr/hr, the radiation levels dropped to 2 mr/hr at 12 inches. The devices are labeled in accordance with 10 CFR 32.51. The University has provided film badges and dosimeters for those workers who wish to use them. While it might have been prudent to inform the workers that radioactive material would be present in the work area, general licensees 4
be present in the work area, general licensees are exempt from the requirements of 10 CFR 19.12. No further complaints or issues have been raised by the workers since the NRC inspectors met with them.
One violation was identified.
- 6. Exit Meeting An onsite exit meeting was held on April 22, 1988, with individuals identified in Section 1 of this report. During this meeting, the workers concerns and the apparent violation was discussed. The University was tsked to establish lock out procedures for the devices should work take place inside the hoppers. The attached licensee letter dated April 26, 1988, describes these procedures.
At the time of the onsite exit meeting, it was not clear as to which entity held the general license. After further interviews and record reviews, it was cetermined that the University of Wisconsin became the generai licensee upon receipt of the devices in 1986. This matter was discussed with Ms. Irwin on June 8,1988.
Attachments:
A. Kay-Ray Survey Results dtd 1/5/88 B. University Area Survey Results dtd 1/5/88 C. Kay-Ray Survey Results dtd 4/12/88 D. University Area Survey Results dtd 4/12/88 E. University Internal Memo dtd 4/17/88 License ltr dtd 4/26/88 - Lockout Procedures 5
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q Cs-137SS AT THE CHARTER STREET HEATING Pl. ANT a
Date: 1/5/1,988 ll-Indiv i dual s . : . John L . Arnol d, Mechan i cal Sys t ern t , Inc.
Linvolved contractor (608-249-6633).
Bradley C. Hyden, Kay-Ray Inc, field engineering service (312-520-1101).
Abdul Ben-Zikri, UW-Madison Safety Department, Health Physicist (608-262-8769)
Doug Kirkeeng, Electrician.
6 Sourcec i 20 SS Cs-137, 100 mci each on June 1986.
Location : UW-Madison Charter Street Heating Plant, third floor.
Procedures : The 20 sources were leak tested by the UW Safety Department, and by Kay-Ray. Eight of the sources were installed on' 1/5/1988. The rest of the sources .will be installed at a latter date. Surveys at the outer surfaces of the source housing and the detector were done by Kay Ray on 1/5/88. . Surveys at the adjacrnt areas to the sources were done by UW Safety Department on 1/5/88 and 1/7/88.
Leak Test : Results of the leak tests reve&Ied sources are not Results leaking.
UW Safety Department Survey Results :
Eberl.ine Model E-120 with probe HP-190 was used for this survey, the meter was cal ibrated on December, 1987. Each source was located about 8 feet off the l floor, and one source per hopper was in place. The results of the survey revealed the following:-
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Location Shutter-Status Exposure 5* off the floor, closed 0.20 mR/hr directly-under
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lj Location B (see closed 0.04 - 0.1 mR/hr fig. 1).
Location A (see closed 0.02 - .08 mR/hr
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Location C (see open3 0 . 30 - 0 . 6 m R/h r
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Location D (see open3 0.10 - 0.3 mR/hr I
fig 1)
At con tac t wi th closed 34 mR/hr33 source housing.
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9 Locations C and D are in line with the direction of the photon l' beam, about 8 feet off floor on a stair way, and only the shutter
{ of the adjacen t nour ce is.open.
99 This reading is the maximum exposure at contact with the source housing of one of the sources.
Note:- The exposure at these locations may increase when the other 12 sources are installed, or when t n'e shutters are opened.
NRC Requirements:
These sources need to be leak tested at the time l intervals specified in the license of these sources, l records must be kept.
The ON-OFF indicators and mechanisms must be tested at the time intervals specified in the license of these sources, records must be kept, t
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.RCSULTS .
i Location Shutter Status Exposure ,
\
5' off the floor, closed 0.20 mR/hr*
directly under the source.
Location 8 closed .04 - 0.1 mR/hr* f F
Location A closed .02 - .08 mR/hr* L Location C open3 .30 - 0.6 mR/hr* .
Location D opens .10 - 0.3 mR/hr*
At contact with closed 34 mR/hr33,* .
source housing.
Location E open 4 -
.5 mR/hr Location F open .04 -
.1 mR/hr Location G open .02 - .08 mR/hr NOTE: THE FOLLOWING ARE THE MAXIMUM REGULATORY EXPOSURE LIMITS .
FOR UNRESTRICTED AREAS- .
- 1. 2 mRems in any one hour,
- 2. 100 mRems per seven consecu t i ve days ( th i s comes to .6 ,
mrem /hr con t i nuousl y for a week), ,
- 3. 500 mRems per year. ,
Installing the remaining sources did not change the readings at ,
locations B,A,C, and D.
3 Locations C and D , E are in line with the direction of the radiation beam, about 8 feet of f fl oor on a stair way.
93 This reading is the maximum exposure at contact with the source housing of one of the sources. Note the sources are about 8 feet off the floor.
O Results from previous survey done on 1/15/89.
AttacwunrD
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. . April 17, 1988 TO: Sue Engelhardt, RSO 3 1 FROM: A. Ben 2ikri, HP ,
Re Meeting with Heating Plant Personnel on 4/15/198p First, the conclusions and the recommendations of the survey done at Charter street heating Plant were based on a zero occupancy factor at the sources and in the areas under the hoppers. This information was provided by the Kay Ray representative. However, at the present time the contractors' workers may have to work in the areas adjacent to the sources to finish their Jobs. Therefor, the conclusions and recommendations apply only for zero occupancy factor at the sources and in the areas under the hoppers, not to the curren t contrac tors.
Second, as for the meeting with the contractors' personnel,
, their concern was that they were not informed of the exposure levels from these sources, and that their understanding was these sources emit exposure l owe r than 30-35 mR/hr. Our records show that Kay Ray representative provided the information on the exposure levels to the contractors firm (see attached), but it seems the information was not forwarded to the people who are doing the work!.
I can understand the workers concern, and I agree that they shoul d have been informed of the exposure levels, but based on the pocket dosimeters readings that was provided to the workers, ( when I was informed that a worker was going to install the sources or install the shatter cables on the sources, I provided them with pocket dosimeters), I do not think that any of the workers received more than allowable limits. Th i s concl us i or, based on the f ol l owi n g :
Tim Morgan Installed 12 sources this requires handling the sources and being adjacen t to the sources during the installation. This work started on March 9, 1988. A pocket l dosimeter was provided to him before he started the work.
! Se had the dosimeter from March 9, 1988 to April 13, 1988; the dosimeter read 40 mrems. I believe Mr. Morgan is the one who spent the longest time hnd was the closest to the sources, and during that time he had the pocket dosimeter.
The fact that Tim Morgan i nstal l ed some of the sources, I was infermed by the contractor's rep. Mr. John Arnold that the individuals who will be installing the sources are authorized to do so. Mr. Arnold was present during all installation times.
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Finally, since some of the work that.needs to be done may '
require a worker being present in the area under the hoppers close to a debece, I recommend that workers who have to e
Sr closer than dosimeter; 4 feet Signs to the source be issued a cocket stating.this requirement must be-posted.
If a worker has to work 6 feet of the floor between hoppers the shutters of the two adjacent sources be closed.
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University of Wisconsin Madison 317 N. Randall Avenue MADISON, WISCONSIN 53715 SAFE 7 Y -lS OUA CONCERN. . .
608 262-8769 - 262-0667 Apri1 26, 1988 TO: Toye S i rrenon s U.S. NRC
- 79) Rooseve1t Rd Glin Filyn, 11 60137 FRCN: A. BenZikri Health Physicist Re: Lock-up Procedure for the Cs-137 ss at the UW-Madison Charter street Heating Plant station Enclosed is the lock-up procedure for the Cs-137 sealed sources for your information. These were posted by each remote shutter actuator.
If you have any questions regarding the Cs-137 sources at the heating plant station feel free to call.
l LETrn.R T AT ED 9/;u,lOB APR 2 81988 tecx.cor Psoc.acoRus
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. . LOCK-UP FROCEDllRFS
, FOR. THE Cs-137 SEALED. SOURCES 7
CAUTION
- USE ONLY THE REMOTE SHUTTER ACTUATOR TO OPEN OR CLOSE THE SOURCE.
DO'NOT ATTEMPT TO OPEN OR CLOSE THE SOURCE WITH THE HANDLES ON THE SOURCE HOUSING (AT THE SOURCE) AS THIS WILL RESULT IN DAMAGE i' TO'THE CABLE AND THE ACTUATOR MECHANISM.
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IF YOU DO NOT UNDERSTAND THE LOCK-UP PROCEDURES, ASK STAN NOVOTANY BEFORF YOU PROCEED.
- 1. Position the remote shutter actuator handle to the closed position. Observe the shutter handle at the source housino, this handle must change from the open to the close position.
The shutter noa is in closed position.
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- 2. Lock the shutter handle at the source, while the shutter in s -
the closed position, wi th a padl ock. ;
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- 3. Turn the interlock key and remove it from the interlock system at the remote shutter actuator panel. This key is removeable only when the locking bolt is extended.
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- 4. Use the interlock key to access the hopper.
- 5. After the problem in the hopper is rectified, lock the hopper with the interlock key, unlock the sn ;t ter handl e at the source and remove the padlock, retrac the l ocking bol t of the interlock system with the interl -k key. At this point you can open the shutter using the r. ote shutter actuator.
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