ML20248K237
| ML20248K237 | |
| Person / Time | |
|---|---|
| Issue date: | 04/04/1989 |
| From: | Lasuk S, Mallett B, Sreniawski D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20248K216 | List: |
| References | |
| REF-QA-99990003-890404 99990003-89-02, 99990003-89-2, NUDOCS 8904170261 | |
| Download: ML20248K237 (6) | |
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.c TV.S.' NUCLEAR REG"LATORY. COMMISSION' m,
1 REGION III
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d Report'No. 99990003/89002(DRSS) f J
Occket No.199990003-
' General L+ cense. (10.CFR 31.'5) i 4
' Licensee:. Niegara of Wisconsin. Paper Corporation 1101 Mill Street Li Niagara,.WI 54151-d
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Inspection Conducted: March 13, 1989 "i
Inspection-Conducted At: -1101 Mill' Street, Niagara, Wisconsin SW b
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Inspector:
S. R.:Lasuk 3/JI/87 Sr. Radiation Specialist Date l
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' Reviewed By:
D. J.. Sreniawski, Chief. :
hf Nuclear Materials Safety Date Section 2 l
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Approved By:
B. S. Mallett, Ph.D.,-Chief IfM[
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Nuclear Materials Safety Date Branch jl i
Inspection Summary i
Inspection on March 13, 1989 (Report No. 99990003/89002(DRSS))
'W Areas Inspected:.Special safety inspection to determine the circumstances surrounding the reported loss'of a device containing licensed material that was removed from service in Octcber 1988..The inspection included a review of the device removal operation, device disposition, and recovery efforts.
Results: An apparent breakdown in the licensee's control of a gauging device i
containing byproduct material was noted.
Two apparent violations were identified:
(1) a device containing licensed material was removed from its installed location by an unauthorized person (10 CFR 31.5(c)(3)),
Section 4.b ; and (2) licensed material was transferred to an unauthorized recipient (10 CFR 31.5(c)(8)), Section 4.c.
8904170261 890404 4 REQ 3 GA999 ENV*****
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DETAILS 1
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Persons Contacted L. Michaud, Electrical Engineer / Maintenance Department R. Tercha, Engineering Manager
.T. Murphy, Vice President, Finance f'
T. Bowman, Onsite Representative for Measurex. Corporation D. Carpenter, Foreman, C. R. Meyer & Sons, Co. (General Contractor)
D. Schneider, Co-owner, Schneider's Iron and Metal,(via telephone on'3/23/89) 2.
Purpose of Inspection This special inspection was prompted by the licensee's report that as "C" shaped device (beta gauge) containing a krypton-85 source was Tost sometime af ter it was removed from service in October 1988. The licensee notified the NRC'by telephone on January 18, 1989, and in a wrftten report dated February 10, 1989 (Attachment A).
3.
Licensed Program The licensee possesses and uses devices containing byproduct material (krypton-85 sealed sources) pursuant to the general license provisions of 10 CFR 31.5.
General licenses are issued to acquire, receive, possess, use or transfer byproduct material incorporated in devices which have been manufactured, tested and labeled by the manufacturer in accordance with the specifications contained in a specific license issued by the NRC or an Agreement State.
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 except for the-provisions of 10 CFR 20.402 and 20.403 i
for reporting radiation incidents, theft or loss of licensed material.
4.
Inspection Findings a.
Device Possession and Use 1
The licensee had two generally licensed LFE corporation devices f
containing krypton (Kr)-85 sources, one of which contained the l
lost source (activity was approximately 340 millicuries in i
October 1988).
The source from the other device was removed'by J
l an LFE representative and shipped back to the manufacturer on
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January 27, 1989.
These devices were usea to measure the weight j
per unit area of paper during the paper manufacturing process, j
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The licensee currently possesses and uses eight Kr-85 sources t
l (nominal activity is one curie per source) in Measurex Corporation j
scanners, which perform a similar function as the LFE devices.
l They also have a Foxboro gauge with a 20 millicurie Kr-85 source l
for checking test samples of paper.
These are all generally I
licensed devices.
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The function =of'the' devices' radiation warning. lights, shutter' mecha'nism,land< radiation, safety < interlocks are testedosemiannually by manufacturer's representatives. ' The shutter and indicator '
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-lights on the LFE device, contain'ing the missing source, were, j
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operating properly when tested on August 13, 1988.
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Device Removal-d The 5-foot'long device, which contained the lost source, had i
been installed at the North Mill Off-Machine Coater.
The monel fe s
encapsulated Kr-85 source (LFE Corporation, Model S70A, Serial
',1 No. 8196) was in a. steel ' housing assembly with a fail-safe shutter f) which closed when the power to the device failed, or was shut off.
The device was scheduled for removal in order tocinstall-a Measurex.
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i On October 25, 1988, personnel from C.
R.' Meyer & Sons, a general. #
contractor, removed the device from its installed position and transferred it to another location within the plant'..The licensee i
i believes the device was subsequently moved to the licensee's scrap metal collection point-outside the butiding, but within_their fenced-in property.
Mr. Robert Tercha, the licensee's Engineering Manager, authorized the removal operation.
Removal of the-device from its-
' installed location is an apparent violation' of 10 CFR 31.5(c)(3) since.neither the licensee,nor C. R. Meyer & Sons have a license.
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1 a to perform such-activities and instructions on the label did rott indicate that-a general licensee could do the removal, according t
to the manufacturer.
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Device / Source Disposition s.
The licensee believes the device, containing the intact Kr-85 source, was transported to:Schneider's Iron & Metal salvage yard in Aurora, Wisconsin on about October 27, 1988.
Schneider's uses their own truck to pick up metal from..the licensee's scrap pile and transfer"it to the Aurora site.> This transfer is an apparent violation of 10 CFR'31.5(c)(8) since Schneider's ' Iron & Metal does '
i not have a. license authorizing them to receive the, licensed material.,
t At the salvage yard, the scrap metal'is compacted hydraulical y and then sheared into lengths of approximately 115 feet. These operations take place outdoors. Once this is done, the sheared metal could l
leave the salvage yard within a few days via transport to the i
Brillion Iron Works in Brillion, Wisconsin.
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At the Brillion site, metal is melted in a furnace which reaches a temperature of 2,800 F.
No shredding, shearing, or compacting.is done at this site.
The licensee believes the device or its. parts may have ultimately been transferred to the Brillion Iron Works.
d.
Licensee Becomes Aware of the Missing Source i
The licensee did not realize thsy were missing a radioactive source until December' 5,1988, which was just prior to the removal of another LFE Corporation device from another machine.
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' Ari LFE representative removed the ' source from the device,
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'b packaged,it, made necessary radiation surveys, and prepared the e
v.C shipping ' papers in 'accordance with authorization-'under Part 31.
The manufacturer. acknowledged receipt 'of this.500 millicurie i
Kr-85 source (Serial No '8298) in a letter d,ated february 20,1989.'
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Upon learning that a radioactive source 4as in the' device that was s
removed in October 1988, Mr. Tercha coritacted Mr. Lee Michaud, i
Electrical, Engineer'in.the licensee's Maintenance Department, who in-May.1988 as:sumed responsibility: for re'gulatory matters pertainin'g to the generally licensed devices. Attempts'to find the source were initiated as of December 5,1988.
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Recovery Efforts c'
Since no~ operations were conducted on the removed device, other..
then placing it in the scrap area, there was no reason to believe
-the source was separated from.the device while.on'the licensee's'
's premises. However, a visual search of the plant'and scrap area l
was conducted on December 6, 1988, and' subsequent dates, but.
failed'to locate'the. device.
Mr. Michaud subsequently consulted with (1) plant' worke'rs who move scrap to determine 'if' the device,
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was placed in;the scrap pile or moved elsewhere on their premises; (2) production area-personnel to ' find.out if-they could' recall when
<thedevicewas.last-seeninlthatarea;J3)the'generalcontractor.
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' personnel to see if anyone remembered moving theLdevice, and when it was moved.
The licensee concluded shipment' of the device asiscrap
.to"Schneider's salvage. yard was the most' probable' disposition.
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Mr. Micha~ud checked with 'his Purchasing Department 'regarding dates j
.when scrap was. hauled away.
He contacted Schneider's Iron & Metal L
who ' indicated scrap metal from the licensee's plant was processed
'immediately after receipt.
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.In mid-January 1989, Mr. Michaud visited Schneider's salvage yard
,9 with a picture of.a device sin,ilar to the one which contained 42 the missing' source, and a' survey. meter.
Two people thought,they saw the device,Eone of.them.was the shear operator, who has a view of s'I the shear hopper into which scrap metal is first loaded. With a Victoreen meter (Model.470A, calibrated 8/22/88) set on the 0-3 mR/hr' range, Mr. Michaud conducted a radiation survey'under I
the shear and'in other areas of the yard; no' radiation above background was detected.
A notice was placed in the licensee's daily newsletter dated January 19, 1989 (Attachment B), regarding the missing source.
'Anyone knowing tha location of the device or having any information j
that may. aid in determining its disposition was asked to contact i
Mr.. Michaud, who notified NRC-Region III of the lost source the previous day.
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'Mr.-Carpenter,thegeneralcontractor'sLforeman',saidtheradiation-
- hazard symbol was on the device but he could not recall any legible
. message on the unit. Mr. Tercha added that, with time, such equipment gets' dirty'and label information cannot be seen.
f.
Followup Action-
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In an attempt to preclude'a similar incident,.a memo to all management personnel from Mr. Michaud was issued on March'1, 1989 (Attachment C).
The memo listed current equipment in the plant containing a radioactive source, a brief summary of regulatory :
-l requirements pertaining to these items, plus who to contact regarding problems, service or other information.
On that same.
i day, similar information was provided in the daily newsletter ;
(Attachment D)'for'all other plant personnel.
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Radiation Exposure Consideration It does not' appear that'significant radiation exposures were-
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incurred during the device removal and probable disposition, based.
-l on the following consideration.
Exposure to the.Kr-85,'a beta gamma l
emitter, would not be ' expected except in the beam and,. if the source was breached, the. gaseous krypton would have been ~ released and dissipated.
The source housing was des'gned so that the shutter..
i would close whenlpower to the device was shut off.
Boltsiholding
-i the dev,w in its installed position'were removed and a hoist was l
used to lift it onto.a cart which was~ then used to transport the device to the scrap ~ metal collection area.
It seems'unlikely-that anyone'would have'their hand.in the limited space between the source housing ~and detector head. for any significant time while on-the licensee's property.
Since'no apparent destructive operations wer'e performed on the device while at the paper plant, no one should have j
been exposed to the direct radiation' beam.
i At Schneider's salvage yard, scrap metal is loaded into the shear hopper with.a. lifting magnet.
The hopper contents,are compacted and then sheared into smaller pieces.
The source could have been ruptured or sheared and the gaseous Kr-85 released during these
' outdoor operations. No one would be close to the source during i
such a release.
I At the Brillion site, the metal is loaded into a hopper from which it proceeds to a preheater and then to the furnace. A buildup of
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pressure in the capsule while in the preheater (1,200 F) could have ruptured the capsule window releasing the Kr-85; if not, the final furnace temperature (2,800 F) would have melted the capsule.
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Exit Interview The inspector met with Messrs. T. Murphy, R. Tercha, and L. Michaud
.during the af ternoon of March 13, 1989, to review the findings of this inspection.
The two apparent' violations were discussed.
The inspector added that if additional violations are identified af ter further review 5
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ofi.information providediduring this' visit, the' licensee would be-so'.
o notified by; telephone. The licensee was also informed that the findings thus 'far _ indicate a potential for escalated enforcement an'd a' portion of I
NRC's enforcement policy was summarized.
6.
Enforcement Conference Atelephoneenforcementco'nferencewasheldon; March 30, 1989, with Messrs. Elmer Beale, President; Robert Tercha, Engineering Manager; and-Lee Michaud, Electrical Engineer for -the licensee and Messrs. J. Hickey, f
B. Stapleton, D. Sreniawski, and S. Lasuk of the Region III staff.
The meeting opened with a discussion on the purpose of an enforcement conference and NRC's enforcement policy. This was followed by a review of the lost source incident, the licensee's efforts to find the source, and the apparent-violations identified during'the inspection. The NRC-also. expressed concern over the apparen_t late notification of this incident but the licensee. clarified their position on the matter and no violation of the reporting requirement was indicated.
4 The licensee. agreed with the two violations concerning unauthorized removal and transfer, and, summarized actions they have taken and plan to'take as a result' of this incident (see Attachment E).
~The NRC indicated the corrective actions appeared adequate to address.
4 the-apparent violations. The licensee was informed that Region III D
recommendations concerning enforcement action would be forwarded to the-
'NRC Office of Enforcement for review; and, they would subsequently be notified in writing of NRC's proposed enforcement action.
Attachments:
'A.
Licensee's Incident Report, dated 2/10/89 B.
_ Licensee's Newsletter dated 1/19/89 C.
Licensee's Internal Memo to Management Personnel dated 3/1/89 D.
Licensee's Newsletter dated 3/1/89 E.
Licensee's Letter, dated 3/28/89,
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E. C. Beale to NRC-RIII
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