ML20247D979
| ML20247D979 | |
| Person / Time | |
|---|---|
| Issue date: | 03/30/1998 |
| From: | Costello F, Reber E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20247D966 | List: |
| References | |
| 15000038-98-01, 15000038-98-1, NUDOCS 9805180166 | |
| Download: ML20247D979 (7) | |
See also: IR 015000038/1998001
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I '
Docket No.: 150-00038 '
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RI License No.: 3D-065-01 )
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Report No.: 98-001
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Licensee: Thielsch Engineering, Inc.
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Facility: Bridgeport Resco
Location: Bridgeport, Connecticut
Date: March 9,1998
Inspector
Eric H. Reber
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Health Physicist
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Approved by: fa A
F ncis M. Costello, Chief
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EXECUTIVE SUMMARY
Thielsch Engineering, Inc.
NRC Inspection Report 150-00038/98-001
An announced inspection, limited to a review of radiographic operations performed by
Thielsch Engineering, Inc. on February 27,1998 at Bridgeport Resco was conducted on
March 9,1998. Two apparent violations for 1.) failure to keep unauthorized individuals
out of the restricsed area; and 2.) failure to file NRC Form-241, " Report of Proposed
Activities in Non-Agreement States," prior to engaging in activities in a Non-Agreement
State were identified.
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REPORT DETAILS
1. Background
RI License No. 3D-065-01 authorizes Thielsch Engineering, Inc. (licensee), in part, to
perform radiography at temporary jobsites in the State of Rhode Island. On February
27,1998, the licensee used an Amersham Model 660B radiography camera (S/N B2301) l
with a 27.6 Ciiridium-192 source to perform radiography at Bridgeport Resco, a co-
generation facility, in Bridgeport, Connecticut.' The licensee's radiographer and
engineering assistant were at the site performing radiography. During a three minute ;
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exposure, an unauthorized Resco employee was inside the restricted area.
On February 28,1998, the Connecticut Department of Environmental Protection
(CTDEP) was conducting an inspection regarding an unrelated matter at Bridgeport
Resco when they were informed of the incident. On March 2,1998, the CTDEP
informed NRC Region I that the licensee had performed radiography at Bridgeport
Resco, and that an unauthorized individual was inside the restricted area when the
radiography source was exposed. On March 9,1998, two Region I inspectors reviewed
the incident.
II. Control of Restricted Area
a. Inspection Scope
The inspectors reviewed the licensee's control of the restricted area established ren
February 27,1998 at Bridgeport Resco for compliance with NRC requirements.
b. Obsen/ations and Findinas
On February 27,1998, Thielsch performed radiography on the attemperator above the
superheater penthouse on the 9* level of Boiler #3 at Bridgeport Resco. The 9" level
is the uppermost level of the facility. Thielsch planned to establish a restricted area on
the 7",8* and 9" levels of the facility. Two stairways lead to the 9* level. The
radiographer, engineering assistant, and a Resco employee cleared the 9* level,
including the superheater pmthouse, of personnel. The Resco employee and the ;
licensee's engineering assistant then cleared the 8* level, and then the 7*. As they
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proceeded, they placed yellow and magenta ropes and restricted area caution signs at
elevator openings on the 9*,8*, and 7* levels. Ropes and signs were also placed
across the stairways at the 6* level. Approximately 45 minutes passed after the
restricted area was established. Prior to exposing the 27.E Ci iridium-192 source, an
announcement that radiography was to be performed was made over the facility's
public address system. After the restricted area was established, a Bridgeport Resco
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employee, without the knowledge of the Thielsch radiographer, entered the
superheater penthouse on the 9" level, an area below where the source would be
exposed. While the source was expose 1, the Bridgeport Resco employee exited the
superheater penthouse through the access hatch and was seen by the radiographer.
The source was retracted immediately.
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c. Conclusions
Thielsch is required by their license to " Confirm that no unauthorized personnel are
within boundaries of restricted area" during and after radiographic exposures and this
did not happen. The licensee's procedures also require that "No unauthorized
personnel shall be allowed within the restricted area."
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Condition 19 of RI License No. 3D-065-01 requires that licensed material be
possessed and used in accordance with statements, representations and procedures
contained in Radiation Safety Manual NDT-41, Revision 15. !
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Item 7.2 of this manual requires that "No unauthorized personnel shall be allowed ,
I within the restricted area." ltem 7.5 of this manual requires that licensee personnel will i
confirm that no unauthorized personnel are within the boundaries of the restricted area
during and after radiographic exposures.
l The finding that, on February 27,1998, unauthorized personnel were allowed within
! the restricted area and licensee personnel did not confirm that no unauthorized
I personnel were within the boundaries of the restricted area during and after
radiographic exposures is an apparent violation of Condition 19 of RI License No.
Ill. Dose Estimate
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a. Inspection Scooe
The inspectors reviewed the dose estimate performed by the licensee for the Resco
employee that was present in the restricted area when the radiography source was
exposed. ,
b. Observations and Findinas
Later in the day on February 27,1998, the radiographer arranged the 27.6 Cl l
Iridium-192 source as it had been when the Resco_ employee was exposed and i
measured dose rates where the employee had been during the exposure. The
' measured dose rates were as follows:
Access Hatch <2 mR/hr
l Resco Employee work area <0.5 mR/hr
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Employee's path of travel
from work area to Access Hatch 1 mR/hr
Exposure directly under source 4 mR/hr
All dose rates appear reasonable considering source strength, distance and the fact
that a 8.3 hajivalue layer collimator was used with the beam pointed away from
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where the Resco employee was working. These measurements could not be
repeated during the inspection because the boiler was in operation.
The source had been exposed for 2.5 minutes when the Resco employee was
discovered. The Resco employee spent approximate!y 1 minute at the work area
and 1.5 minutes traveling from his work area to the access hatch. The licensee
estimated a total dose of 0.005 millirem for the Resco employee. This estimate
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appears to be conservative, and, at the very least, the dose estimate would not
approach the dose limit for members of the public (100 mR/yr).
c. Conclusions
The licensee's dose estimate is conservative. Dose limits for individual members of
the public were not exceeded.
IV. Training
a. Inspection Scope
The inspectors reviewed the training of the radiographer for compliance with NRC
requirements.
! b. Observations and Findies
The radiographer involved received 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of radiation safety training and 80
hours of radiography training when working for a previous employer. He had 120
hours of classroom radiography training with another previous employer. The
radiographer also received training regarding equipment and procedures specific to
the licensee. He was tested by the licensee and received a composite score of
92.55%. The written portion of the exam included general radiation safety questions
as well as questions specific to radiography. The radiographer was also required to
demonstrate the proper use of radiography equipment. He received annual
retraining on January 2,1998 and passed an examination with a score of 96%.
The radiographer stated that he has always been instructed to keep people out of
the restricted area.
c, Conclusions
The radiographer involved in this incident was trained in accordance with NRC
requirements.
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IV. Reciprocity
a. Inspection Scooe
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The inspectors reviewed the licensee's authorization to perform radiography on
February 27,1998 at Bridgeport Resco in Bridgeport, Connecticut.
b. Observations and Findinas
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On February 27,1998, Thielsch performed radiography at Bridgeport Resco with a
27.6 curie iridium-192 source, but did not file an NRC Form-241, " Report of Proposed
Activities in Non-Agreement States," prior to commencing work. The Thielsch
employee responsible for filing such forms stated that he believed Connecticut was an
agreement state and therefore, did not require a Form-241 to be filed. The licensee I,
filed an NRC Form-241 on March 4,1998 after being informed that the form was
recuired.
c. Conclusions
10 CFR 30.3 requires in relevant part, that no person shall possess or use byproduct
material except as authorized by a specific or general license issued by the NRC.
10 CFR 150.20(a) provides, in part, that any person who holds a specific license frem
an Agreement State is granted an NRC general license to conduct the same activity in
non-Agreement States subject to the provisions of 10 CFR 150.20(b).
10 CFR 150.20(b)(1) requires, in part, that any person engaging in activities in non-
Agreement States shall, at least 3 days before engaging in each such activity, file 4 ;
copies of NRC Form-241," Report of Proposed Activities in Non-Agreement States", 1
with the Regional Administrator of the appropriate NRC regional office.
The finding that, on February 27,1998, Thielsch Engineering, Inc., a licensee of
Rhode Island, used 27.6 Ci of iridium-192 in Bridgeport, Connecticut, a non-Agreement
State, without a specific license issued by the NRC and without filing Form-241 with
the NRC is an apparent violation.
VI. Management Meetings
Preliminary results of the surveys were discussed with Bruce MacLure, the licensee's
Laboratory Supervisor at the conclusion of the inspection.
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PARTIAL LIST OF PERSONS CONTACTED
Licensee
Bruce MacLure, Laboratory Services Supervisor, Thielsch
! Stephan Goodyear, Radiographer, Thielsch
Bob Duhamer, Radiographer, Thielsch
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Bridaeport Resco
Tom Maillet, Operations Manager, Resco
Robert Cushing, Control Room Operator, Resco
State of Connecticut Department of Environmental Protection
Mike Firsick, Radiation Control Physicist
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