ML20236C828
| ML20236C828 | |
| Person / Time | |
|---|---|
| Issue date: | 03/15/1989 |
| From: | Mallett B, Slawinski W, Wiedeman D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20236C823 | List: |
| References | |
| REF-QA-99990003-890316 99990003-89-01, 99990003-89-1, NUDOCS 8903220334 | |
| Download: ML20236C828 (9) | |
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S. NUCLEAR REGULATORY COMMISSION I
l REGION III i
Report No. 99990003/89001(ORSS)
Docket No.'99990003 General-Lictase (10 CFR 31.5) 1 Licensee:
Grand Haven Board of Light and Power 1700 Eaton Drive Grand Haven, MI 49417 I
I Inspection At:
J. B. Sims Generating Station i
North Third Street l
Grand Haven, MI 49417 Inspection Conducted:
February 22, 1989 (iJ fp.M ~ >
Inspector:
Wayn
- .U5 winskV 3 -t r-69 l
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Date h,.
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Reviewed By:
D. G. Wiedeman, Chief 3-/F#f Nuclear teri is Sa efy~
Date Sect' n/ 1 iw Approved By:
Bruce S. Mallett, Ph.D., C f
I"MIf Nuclear Materials Safety Branch Date e
Inspection Summary Iupection on February 22, 1989 (Report No. 99990003/89001(DRSS))
raas Inspected:
Special safety inspection to review worker concerns Fegarding removal, security, and radiological hazards associated with nuclear gauging devices used at the S'ms Station.-
Results:
An apparent breakdown in the licensee's control of gauging devices containir.g byproduct material was noted.
Six apparent violations of NRC l
requirements.(10 CFR 31.5 and 30.51) were identified:
(1) gauges containing byproduct material were removed from installation by unauthorized and unqualified persons; (2) failure to perform source leak and device on-off mechanism tests at the required intervalt; (3) failure to maintain gauge 1abeling legible; (4) failure to maintain records of byproduct material L
receipt and (5) records of device removals and (6) failure to furnish a l'
transfer report to the Commission.
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8903220334 890316 REG 3 QA999 ESGMI i
99990003 PDC
DETAILS 1.
Persons Contacted J. Chandler, Instrument Department Supervisor R. DuPuis, Senior Instrument Technician
- G. Groenevelt, Production Superintendent
- E. Hughes, General Manager M. 01ger, Scrubber Operator
+C. Stevens, Maintenance Staff
+J. Tobey, Maintenance Staff M. Welling, Instrument Technician
+A. Peterson, Radiation Safety Officer, Kay-Ray, Inc.
+P. Sieck, Vice President, Manufacturing / Radiation Safety Officer, Ohmart Corporation
- Denotes those preseat at the site exit interview on Fetiruary 22, 1989 and at the enforcement conference on March 14, 1989.
+ Denotes telecon contacts (or.ly) between February 21 and March 3, 1989.
2.
Purpose of Inspection This special inspection was prompted by worker concerns associated with nuclear gauging devices at the J. B. Sims Generating Station, initially directed to the Michigan Department of Public Health and subsequently relayed to NRC Region III.
On December 9, 1988, the Michigan Department of Public Health (MDPH) was contacted by a Sims Station worker concerned with the physical condition, removal, security and radiological hazards associated with several nuclear gauging devices at the facility.
The MDPH informed NRC Region III that same day and the licentee was contaL+ed by the NRC later that day and requested to secure those gauges that had allegedly been removed from installation and were not secure.
A MDPH site visit to the Sims Station on December 12, 1988 confirrned that the devices removed from installation were properly secured from unauthorized removal and that others mounted in the plant posed no significant radiological hazard.
The NRC inspection conducted at the licensee's Sims Generating Station in Grand Haven, Michigan consisted of a review of the overall licensed program involving byproduct material gauging devices and included a review of the worker (s) specific concerns (AMS No. RIII-88-A-0173 (Closed)).
The allegation findirigs are summarized in Section 5.
3.
Licensed Program The licensee possesses and usos density / thickness gauges containing byproduct material (cesium-137 sealed sources) pursuant to the general license provisions of 10 CFR 31.5.
General licenses are issued to transfer, receive, acquire, possess and use byproduct material 2
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incorporated in devices or equipment which nave been manufactured, tasted and labeled by the manufacturer in accordance with the specifications contained in a specific license issued by the Commission.
Licensees that possess material pursuant to the general license provisions of 10 CFR 31.5 are exempt from 10 CFR 19, 20, and 21 requirements other i
than 10 CFR 20.402 and 20.403 for reporting radiation incidents, theft or loss of licensed material.
No previous inspection has been performed of the NRC licensed activities at the Sims Station.
4.
Inspection Details
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I a.
Gauge Possession, Use and Testing
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l The licensee possessed six byproduct material gauging devices under the general license provisions of 10 CFR 31.5, distributed to the l
licensee by the respective device manufacturer in late 1981.
The devices were placed in operation at the Sims Generating Station in early to mid-1983, shortly before the station commenced commercial operation.
Five Ohmart Corporation (DensArt 3460) devices containing nominal 50-150 millicuries of cesium-137 (sealed sources) 1 were shipped to the facility in November 1981 and mounted in place at the station (presumably) by the facility design and construction contractor during site construction between that time and early 1983.
The Ohmart devices were subsequently placed in operation, tested and surveyed by the manufacturer on March 16, 1983.
Although any person is authorized to initially mount the Ohmart device, provided the shutter remains locked in the off position, only Ohmart personnel have the shutter lock combination and are authorized (along with others specifically licensed) to place the device in initial operation.
Additionally, one Kay-Ray, Inc., device (Model 7062) containing a nominal 100 millicuries of cesium-137 (sealed source) was shipped to the facility in November 1981 and mounted, placed in operation, tested and surveyed by the manufacturer on May 18, 1983.
Unlike the Ohmart devices, the Kay-Ray device is authorized to be mounted only by those specifically licensed.
All six devices wece mounted on various process lines and used by the licensee for thickness and density measurements from 1983 through mid to late 1987, until three of the devices were removed from installation (see Section 4(b)).
As of the date of this inspection, the licensee maintains possession of all five Ohmart devices, three mounted on process lines and two in storage.
The Kay-Ray device was removed and transferred to an authorized disposal company in June 1988.
According to the licensee, receipt and possession of these six devices were initially assumed by the Sims Station design and construction contractor (Babcock and Wilcox) and transferred to the licensee in mid-1983 when the facility began commercial (turnkey) 3
operation.
No records oD device receipt, installation, or initial testing were maintained by the licensee or could be obtained through Babcock and Wilcox.
Failure to maintain receipt' records for the byproduct material contained-in six gauging devices appears contrary to 10 CFR 30.51, which requires such records.to be maintained as long as the licensae retains possession of the byproduct material and for two years'following transfer or disposal of the material.
According to device manufacturer field records, the gauges were tested for leakage of radioactive material and proper operation of the on-off mechanism by the manufacturer when they were placed in initial operation in 1983.- Specifically, the five Ohmart devices -
were leak and on-off mechanism tested on March 16, 1983 and the i
one Kay-Ray device tested on May 18, 1983.- The licensee performed I
a source leak test on-three (currently mounted) Ohmart devices in early February 1989 and on the two stored Ohmart devices on February 22, 1989, the latter at the NRC inspector's request; no leakage was detected.
No other leak or on-off mechanism tests i
were performed on the Ohmart devices.
The Kay-Ray device was not leak or on-off mechanism tested.. subsequent to the manufacturers l.
test on May 18, 1983; the device was transferred to a disposal-company in June 1938.
Approximately six years elapsed between leak tests on the Ohmart devices and over five years on the Kay-Ray device.
Additionally, no on-off mechanism tests were performed on any of the' devices subsequent to those conducted by the manufacturers in 1983.
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labels affixed to the devices allow extended -(three year) leak and on-off mechanism test intervals.
Failure to leak test the sealed sources and test the device on-off mechanisms for proper operation-I on at least the three year interval specified on the device ~1abel l
appears contrary to 10 CFR 31.5(c)(2), which requires such tests at no l
longer than six month intervals or at other intervals specified in the label affixed to the device.
Although shutter mechanism tests have not been performed since 1983, the licensee plans to contact-Ohmart Corporation in the near future and arrange for removal of the three installed devices and the transfer of all remaining devices.
According to the device manufacturer, shutter mechanism closure is verified and source leak tests are performed whenever l
they remove or accept device transfer, b.
Gauge Removals Two 150 millicurie Ohmart devices (mounted on. scrubber models "A" and "B") and the 100 millicurie Kay-Ray device (mounted adjacent to a sludge detection conveyor assembly) were physically removed from
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their mounted locations by the licensee on separate occasions in mid to late 1987.
Two of the devices were removed by members of the Sims Station maintenance staff and the third by'a station senior instrument technician.
None of those involved in the device removals were authorized by a specific license or technically 4
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-i qualified to perform this activity.
The maintenance people involved had no previous experience handling nuclear gauging devices of any type.: Although the instrument technician appears.to possess a general knowledge of gauge operation ~and routinely performed device detector (electronic) calibrations in accordance with the manufacturers instruction manual, the' individual was not trained in-device removal methods or: procedures and had never previously.
removed a gauging device. According to the device manufacturers' literature, their instruction manuals do'not-support device removal by untrained persons. Removal of these devices by untrained individuals may have led to the failure to properly close or: secure the shutters of two devices (see Section 4(c)). The devices were-removed because the licensee was not satisfied with their operation l~
and planned to replace them'with~another manufacturers device.
10 CFR 31.5(c)(1) require persons that receive possess, use,-or transfer byproduct material in measuring or gauging devices pursuant to a general license to comply with all instructions,and' l
precautions provided by the labels affixed _to the device.
10 CFR 31.5(c)(3) requires licensees to assure _that. device testing.
and removal from installation are performed in.accordance with the-instructions provided by the labels or by a. person holding e specific license pursuant to Parts 30 and 32 of this chapter or from an Agreement State. The labels affixed to the Ohmart and Kay-Ray gauges require that device relocation be performed by persons specifically licensed by the NRC or'an Agreement State.
1 Contrary to these requirements, on three separate occasions'in.1987, Sims Station workers neither specifically licensed by the.NRC or an Agreelnent State, nor technically qualified, removed gauging devices
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containing byproduct material from their mounted locations.
1 Additionally, records of device removals, required pursuant'to j
10 CFR 31.5(c)(4), were not maintained for the two Ohmart devices that were removed from installation in mid to~ late 1987.
After removal, the two Ohmart devices were placed on the respective-scrubber module inlet duct (essentially the scrubber floor or l
platform) beneath their mounted locations and remained unsecured from removal in those locations for about 12-16 months until moved to the instrument shop (a locked area) in December 1988 at NRC (telecon) request. Although the scrubber inlet ducts are unrestricted areas, are readily accessible to plant workers,-and the gauges could be easily observed from a walkway adjacent to the area, the specific location where the removed devices were placed was not routinely occupied by plant workers. During this 12-16 month period, the shutter mechanisms on one of the two devices remained open while the shutter on the other was closed but unlocked (see Section 4(c)).
The 100 millicurie Kay-Ray device was removed from installation by a maintenance worker and soon after placed in_ storage in the instrument shop where it remained until transferred to an authorized.
disposal company in June 1988. The licensee failed to furnish a written report of this transfer to the Commission as required l
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0 by 10 CFR 31.5(c)(8).
According to the licensee, operation of the Kay-Ray device was discontinued long before its removal, the device shutter was closed and lockei because of its nonuse and remained in this (beam shielded) configuration'during the removal and disposal evolutions.
c.
Radiological Significance Associated With Device Removals It does not appear that significant radiation exposures were
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incurred during the device removals or ensuing events.
The shutter i
mechanisms on two of the three devices were apparently closed prior to the removal process; however, only one.of the two shutters
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was closed intentionally for the removal.
The instrument technician that removed one of the Ohmart devices was aware of device on-off mechanism operation and physically verified shutter closure prior to removing the device.
However, civil defense survey meters maintained by the instrument technicians for the community
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civil defensa program were not used to verify radiological conditions j
subsequent to shutter closure.
(The effectiveness of;the shutter in shielding the radiation beam was verified by the inspector during the inspection (see Section 4(d)).
The shutter on the Kay-Ray device had reportedly been closed and locked long before the device removal but was not verified as part of the removal process.
An open shutter mechanism on one of the Ohmart devices does not appear to have exposed workers to the unshielded radiation beam because the method used to remove the device unintentionally. shielded the beam.
Specifically, maintenance workers removed a section of the process piping which the device (composed of separate detector and source housing pieces) wts mounted onto while the gauge itself remained-intact and both its pieces attached to the piping.
This was done to facilitate device removal and not intentionally for radiological reasons.
As previously discussed, the maintenance workers had no previous nuclear gauging device experience and were unaware of the shutter mechanism and its operation.
Although the shutter nechanism was open during device removal and remained open for up to 16 months while the device remained on the inlet duc.t, the process piping and gauge detector shielded and intercepted the radiation be.;m.
The maximum radiation levels these maintenance workers may ha<e been exposed to appears to be minimal and similar to those measured by the NRC inspector on the Ohmart devices currently in use (i.e., less than 2 mR/hr; see Section 4(d)).
There is no indication that the removed devices were improperly handled or tampered with while they remained dismounted, including the two that were unsecured on the inlet duct for up to 16 months d.
Independent Inspection Effort During this inspection the inspector toured those plant areas where three Ohmart gauging devices remained mounted, the scrubber module where two device = had been removed from installation and stored on inlet ducts, and the instrument shop where these two devices are currently stored.
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m The NRC inspector made radiation measurements on the mounted devices (shutters open) which revealed maximum contact radiation levels of 1.5 mR/hr; levels were !ess than 1.0 mR/hr with the shutters closed.
The source beams from the mounted devices were not' i
accessible to extremities (hands / arms) because of shield material and device mount configurations.
Inspector surveys performed on the two 150 millicurie Ohmart devices stored in the instrument shop showed similar (closed shutter) contact radiation levels.
No external radiation problems were noted with the. mounted or stored devices.
Source leak tests were performed on the two stored devices at the inspector's request and sent for analysis the next day; no leakage was detected.
All Ohmart devices appeared to be properly labeled in accordance with regulatory requirements (10 CFR 31 and 32); however, the labeling was either partially or completely obscured by~ dirt,1%e, or other deposits.
The gauge mounted on the lime feed line ent in-use during the inspection was painted over, obliterating the device label.
In addition, the shutter lever locking nasp on the rievice mounted on the "A" thickener underflow pump had apparently broken off and the shutter could not be locked in the closed position.
Failure to maintain device labeling legible appears contrary to 10 CFR 31.5(c)(1) which require persons that receive, possess, use, or transfer byproduct material in measuring or gauging devices pursuant to a general license to comply with all instructions cad precautions provided by the labels affixed to the device.
The labels affixed to all five Ohmart devices state they are to be j
maintained on the device in a legible condition.
Similar information is included in the device manufacturer's instruction i
manual along with a copy of the label.
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Root Cause and Licensee Corrective Actions The problems described above appear to be caused by the licensee's general unawareness of the regulatory requirements applicable to their licensed activities.
However, the labeling affixed to the devices and information contained in the device manufacturer's instruction manual essentially reiterate the j
regulatory (10 CFR 31) requirements.
A copy of the Ohmart instruction manual and 10 CFR 31 is maintained by the licensee.
As previously described, the two Ohmart gauges removed from l
installation in 1987 were relocated to a secure storage area at NRC (telecon) request in December 1988.
The three currently mounted gauges were leak tested by the licensee about two weeks prior to this inspection and the two stored in the instrument shop were leak j
tested on the day of tho site inspection at the inspector's request.
I According to the licensee, leak tests were performed on the gauges currently in use when they realized that these requirements may have j
been violated.
The licensee stated they were not fully cognizant of all applicable regulatory requirements until informed during this
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inspection.
The licensee committed to inaugurate a gauging device 1
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instruction /information program for.all plant workers and a surveillance program to assure legibility and integrity of device i
labeling. The licensee plans to contact Ohmart Corporation for removal of the three mounted devices and make arrangements for-transfer of all five devices back to the manufacturer.
1 5.
Allegation Findings and Conclusion The allegation as described in Section 2 was substantiated in that gauging devices used at the Sims Station were removed from installation by l
untrained station employees, stored in unsecured lacations, shutters on certain removed devices were open, and labels. affixed to several devices l
were not legible. As a result, apparent violations were identified for unauthorized removal of gauging devices and for failure to maintain device labeling legible. - Although two of the removed devices were' stored in an unrestricted area and may not have been secured from unauthorized removal, no regulatory requirements were violated because the licensee is exempt from unrestricted area storage and security requirements of 10 CFPs 20.207. However, the devices were not removed from their storage location by unauthorized personnel and the likelihood of removal was limited because the devices weigh about-130 lbs each. The inspection disclosed that the shutter mechanism on one of the devices was open while it was removed from installation and remained open for up to 16 months during its storage; however, it does not appear that significant radiological exposures were received as a result of the device removals or ensuing events.
1 In addition to the two apparent violations noted above, four other apparent violations of regulatory requirements were identified and-include failure to perform leak and on-off mechanism tests at the required intervals, failure to maintain records of byproduct material i
receipt, failure to maintain records of device removal, and failure to send a transfer report to the Commission.
6.
Exit Interview The inspector met with licensee representatives (denoted in Section 1) at the conclusion of the site inspection on February 22, 1989 and summarized the scope and findings of the inspection. The inspector indicated that the problems identified during the inspection appeared to represent a breakdown in control over their licensed activities and that a potential l
for escalated enforcement exists. The inspector summarized the 10 CFR 31.5 requirements and the NRC enforcement policy.
7.
Enforcement Conference An enforcement conference was held at the NRC Region III office in Glen Ellyn, Illinois on March 14, 1989. The meeting was held between Mr. C. E. Norelies and other members of the Region III staff and those licensee representatives denoted in Section 1.
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The NRC staff summarized the inspection findings, the apparent i
violations, root cause(s) and the NRC enforcement policy.
The licensee did not disagree with the inspection findings and described the A
corrective actions taken and planned.
Corrective actions taken by the-
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~ licensee are described in other sections of this report; additional i
licensee actions taken subsequent to the inspection include the following:
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Designated a (primary) responsible individual for all nuclear l
gauging devices.
i Convened a safety committee meeting on February 23, 1989 to discuss the NRC inspection findings and the corrective actions planned.
l Developed a preventative maintenance program to assure that device testing requirements are met.
Instituted daily (visual) device inspections to assure device and label integrity.
The three mounted Ohmart devices were removed by the device i
manufacturer and all five remaining devices were transferred to l
Ohmart Corporation.
1 The NRC acknowledged the licensee's presentation and stated the corrective actions described during the meeting appeared adequate to address the apparent violations; however, the licensee was informed that a program for assuring continued long term compliance is necessary.
The senior NRC representative stated that Region III recommendations concerning enforcement action would be forwarded to the NRC Office of Enforcement h
for review.
The licensee will be notified in writing of the NRC's proposed enforcement actions.
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