IR 05000312/1998001
| ML20202C498 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 02/05/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20202C467 | List: |
| References | |
| 50-312-98-01, 50-312-98-1, NUDOCS 9802120263 | |
| Download: ML20202C498 (22) | |
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ENCLOSURE 2 U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket No.: E4312 License No.: DPR 54 I
Report No.: 50 312/98 01
-- Licensee: Sacramento Municipal Utility District Facility: Rancho Seco Nuclear Generating Station Location: Rancho Seco Nuclear Generating Station 14440 Twin Cities Road Herald, Califomia Dates: January 5-8,1998 Inspector: J. Vincent Everett, Health Physicist Approved By: D. Blair Spitzberg, Ph. D., Chief Nuclear Materials inspection and Fuel Cycle / Decommissioning Attachment: SupplementalInformation i
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2-EXECUTIVE SUMMARY Rancho Seco Nuclear Generating Station NRC Inspection Report 50 312/96-01 Decommissioning was underway in the turbine building and the area outside the turbine building where the auxiliary boilers were located. A number of the systems being dismantled were fitted with insulation which contained asbestos and required removal by specially trained worker Contamination levels had been low with only three personnel contamination incidents in 199 Radiation levels in the work areas were very low, with typical readings between background and a few mR/hr. Work activities continued to be safely performed. Contamination encountered during the opening of systems had been effectively contained, and no significant radiological exposure problems had been encountere The dry cask storage program for the independent Spent Fuel Storage Installation (ISFSI) was on hold while the cask vendor, Transnuclear Corporation (formerly Vectra), responded to NRC quustions on the cask design and quality ascurance issues. All open issues were expected to be resolved by summer 1998 and loading of the Rancho Seco spent fuelinto the ISFSI could
, begin in late 1998 or early 199 Qtganization. Management. and Cost Controls
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The licensee was conducting limited decommissioning work consistent with activities described in the Post Shutdown Decommissioning Activities Report (PSDAR),
Compliance with technical specifications regarding the functions of the plant review committee and management safety review committee were confirmed (Section 1).
Commitment tracking for evaluating information issued by the NRC to licensees was reviewed and found acceptable, including the actions taken by the licensee related to the year 2000 computer issue (Section 1).
Maintenance and Surveillance
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Based on review of the computerized tracking system and observation of the morning meeting, there appeared to be an adequate process for prioritizing and processing work activities and tracking completion. No backlog of overdue work activities was identified for the spent fe.1 pool cooling system (Section 2).
Cold Weather Preoaration
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The freeze protection program for Rancho Seco was formalized in a freeze protection procedure which induded commitments made by the licensee in response to NRC Bulletin 94-01 concerning freeze protection for the spent fuel pool. The provisions for freeze protection for the spent fuel pool were found to be adequate (Section 3).
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Qtcommissionina Performanegyld Status Review
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The limited decommissioning and dismantlement work underway in the turbine building appeared to be conducted safely. Housekeeping and fire loading were found to be acceptable. Systems being dismantled were consistent with the activities described in the PSDAR (Section 4).
Health Physics
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Overall health physics activities during decommissioning work appeared adequate in the areas of personnel exposures, contarnination incidents, and control of sealed sources (Section 5).
- A violation was identified for failure to properly survey an auxiliary boiler prior to release for unrestricted use. The boiler was later found to have low but detectable levels of contamination by a scrap metal dealer, Failure to perform the survey was identified as a violation of Technical Specifications and 10 CFR 20.1501 (See:lon 5).
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4 Reort Details Summarv of Plant Staks The Rancho Seco nuclear facility was shutdown in 1989 and placed in a SAFSTOR conditio In February 1997, the licensee began limited decommissioning of the facility as a pilot project tu validate cost estimates for decommissioning work and gain experience in dismantling plant systems. The primary decommissioning work currently underway involved the turbine building and the area just outside the turbine building where the auxiliary boilers had been located. Plant staffing for the past year had remained at about 150 permanent and limited term employees and 20 30 contractors. Radiation levels and contamination levels in the areas undergoing dismantlement had been very low. No significant radiological problems had been experience The abatement project to remove asbestrss from several systems had progressed well with minimal problems. This effort involved bringing specialized personnel onsite to perform the work. Most of these workers had no previous work experience on systems that were contaminated. Radiation safety training and health physics oversight were provided by the license Organization, Management, and Cost Controls (36801) insoection Scope
The Post Shutdown Decommissioning Activities Report (PSDAR) was reviewed against current site activities to verify that the PSDAR accurately reflected work underwa Overall schedules and upcoming work activities were reviewed. Compliance with selected license technical specifications was verified. An evaluation of the licensee's program to integrate NRC issued information, such as generic letters and information notices, into licensee programs was reviewe .2 Observations and Findinos The Rancho Seco PSDAR, dated March 20,1997, provided an accurate description of the decommissioning status of the Rancho Seco facility. The PSDAR described the status of the Rancho Seco facility as Custodial SAFSTOR with limited dismantlement work underway. The reactor was completely defueled. The 493 spent fuel assemblies were stored in the spent fuel pool. Maintenance was being performed on systems and structures needed to support spent fuel poo' cooling, security, building services, environmental and radiological monitoring, and fire protection. Systems and equipment no longer needed were either shutdown and abandoned in place, or removed from the site as part of the asset recovery program and incremental decommissioning progra The PSDAR provided a schedule of activities for the Rancho Seco site which included continuation of the limited dismantlement activities and custodial SAFSTOR into 199 Sometime in 1999, the facility will be placed in hardened SAFSTOR until 2008 at which time decommissioning would be resumed License termination was planned for 201 .-. - - - . -- - .-. . _ _ - - -- - - . _ - .-- .-
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. The dismantlement work underway involved the removal, decontamination, and disposition of selected systems and components containing low levels of radioactive contamination. Material found to be below the radiological release limits was made available for asset recovery, including sale as scrap. Material found to be contaminated was stored for future shipment to Envirocare of Utah for burial under a recently signed
- contrac The activities of the plant review committee and the management safety review committee were reviewed and found to be consistent with the requirements in Technical Specification D6.5.1, * Plant Review Committee,' and D6.5.2, ' Management Safety Review Committee " Technical Specification D6.5.1 established the requirements for the plant review committee including the purpose of the committee, monthly meeting frequency, membership, and responsibilities. A review of meetings conducted in 1997 indicated that required monthly meetings were being held, the number of members required for a quorum was being met, and subject areas reviewed during the meetings were consistent with the responsibilities identified in Technical Specification D6.5. The meetings in June and July 1997 were reviewed in detail. The June meeting reviewed activities associated with plant modifications, asbestos abatement work, 10 CFR 50.59 reviews and approvals, cost accountability processes for decommissioning, and vendor qualification issues For July 1997, the Plant Review Committee reviewed the results of the fire protection audit, status of work on the component cooling water pump, defueled safety analysis report changes, and plant operations issues.
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Technical Specification D6.5.2 established the requirements for the management safety review committee including requirements for quarterly meetings, the number of members needed for a quorum, and responsibilities of the committee. For 1997, the requirements of the technical specifications had been met concerning required fo*ums and frequency of meetings. The December 4,1997, meeting was reviewed in detail. This meeting included discussions on plant status, decommissioning information exchange with Trojah, the status of the Vectra (now Transnuclear Corporation) contract for dry cask storage, technical specification reviews, audits conducted, and plant statu Various information notices and NRC bulletins are periodically distributed by the h RC to alllicensees. The Rancho Seco program for evaluating, processing, and assigni actions related to the information received from the NRC was reviewed and found to be
. acceptable. The licensee had established a site review group which included representatives from each of the key plant organizations. Procedure RSAP 0260,
' Commitment Management Review Group,' established the process for reviewing and processing information received that could affect site activities. This group typically met
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weekly. The licensee was on distribution for all NRC issued generic communication documents including those issued to operating plants. This included information notices, bulletins, and generic letters. The licensee had also niade arrangements with several other shutdown plants to share inspection reports. The review group evaluated the u
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. Information received and determined if the information was applicable to the Rancho Seco programs, if so, the review group assigned action item A computerized system, called the commitment tracking system (CTS), was used to track commitments including those made by the commitment management review grou As a test of the system, Information Notice 96 70, ' Year 2000 Effects on Computer System Software,' was searched. Responses were noted from all technical groups except one, which had not yet completed evaluation. Operations and security representatives determined that there was no effect on their systems. The radiation protection group evaluated the computers in use in their group including AST computers, Compaq, Hewlett Packard (HP), the Helgeson whole body counter, and Reply -
computers. Only the AST computer was able to handle a date greater than 1/1/200 The others would revert back to a date of 1/4/80 (DOS's birthday) when turned back o The Reply computer was used at the radiologically controlled area access control point for dosimetry tracking, Since this system used the clock on the AST computer, it was determined that the date problem would not effect operations. Preliminary evaluations concluded that the Prorad radiation protection data management system, which used IBM OS2 and DB2, would not have a problem. The radiation protection group was evaluating whether some of the older computers may need replacemen .3 Conclusion The licensee was conducting limited decommissioning work consistent with activities described in the PSDAR. Compliance with technical specifications regarding the function of the plant review committee and management safety review committee were confirme Commitment tracking for evaluating information issued by the NRC to licensees was reviewed and found acceptable, including the actions taken by the licensee related to the year 2000 computer issu Malntenance and Surveillance (62801)
2.1 Insoection Scooe The overall maintenance and surveillance program for the spent fuel pool was reviewed, including backlog work activities, prioritizing work, scheduling work, and maintenance related to the spent fuel pool cooling syste .2 Observations and Findings Maintenance activities at Rancho Seco were adequately controlled through a number of procedures and a computerized tracking system. Procedures reviewed included MAP-0009, " Preventive Maintenance Program," Revision 6; RSAP-0260, ' Commitment Tracking System,' Revision 6; and RSAP-0803, " Work Requests," Revision 1 _ , . - - .. _ _ __ - - - __ _
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Preventive maintenance, corrective maintenance, and surveillences were being performed for the spent fuel pool systems. The licensee maintained a computerized tracking system to monitor progress of maintenance activities. The computerized system allowed the user to determine which department currently had the maintenance request and wnether the work had been completed. Maintenance activities were prioritized based on several criteria defined in Procedure RSAP-0260, ' Commitment Tracking System.' Basically, issues related to safety and those related to compliance with regulations and technical specifications were given higher priorities. During the morning meetings, plant management reviewed activities and schedules for tasks underway. The operations manager listed key items on the operc is concern list of the daily work summary that were reviewed during the morning meetings. The daily work summary also provided a list of surveillences that come due. Through the morning meeting process, significant maintenance issues were monitored by management to ensure work completion on a timely basi Corrective maintenance work requests were generated anytime a problem was found with a system. The work requests were forwarded to operations and maintenance for action and were entered into the computerized tracking system. Surveillance activities were generated by surveillance procedures for various systems. A weekly list of surveillences was issued to each group supervisor. The overdue surveillences were listed in the daily work summary that was reviewed during the moming meetings. The daily work summary on January 5,1998, had seven overdue surveillences and two overdue routine tests. None of these activities were determined to be significant. Any surveillance that failed, and special surveillance results identified of interest, were forwarded to engineering for review. Failed surveillences resulted in a potential deviation from quality (PDQ) form being generated. The fire protection system required significant manpower to complete the scheduled surveillance The PDQ process included more findings than failed surveillances. Any concern or problem that needed management review and attention was entered into the PDQ process. This process was controlled by Procedure RSAP 1308, ' Potential Deviation from Quality." A review of the PDQ log indicated the following number of PDQs issued over the past several year YEAR PDQs tSSUED 1997 83 1996 95 1995 105 1994 104 1993 91
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B-Since site work activities had been relatively constant prior to 1997, the number of PDQs generated would be expected to be relatively cor.sistent from year to year. For 1997, the initiation of incremental decommissioning had net resulted in an increase in the number of failed surveillances or site problems, as reflected by the number of PDQs generate A review of the 1997 PDQ list did not identify any trends or recurring problems with specific systems. Problems included a variety of lasues such as smallleaks, high system voltage, problems with communication loops, failed surveillences, grounded cables, and damage to a fire water line. The radiation monitoring system had required a lot of attention. The spent fuel pool systems had few problem The computerized tracking system was reviewed during this inspection and was found to
, be an effective process for tracking work activities. The list of maintenance activities associated with the spent fuel pool included 530 maintenance activities dating back to 1987. Of these, all activities had oeen completed through July 1997. The activities still
! open were being reviewed and scheduled or had been assigned for work.
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During 1996 and 1997 the spent fuel pool coolir.g system had been shut down several times for maintenance. The shutdown periods extended up to two weeks. During these periods the spent fuel pool temperature increased. Attachment 2 to this report provides data for four periods in which the cooling system was turned off and the spent fuel pool l temperature was allowed to increase. An average 2'F/ day to 3'F/ day increase to the i
spent fuel pool temperature was observed. The highest pool temperature reached during the shutdown periods was 100'F which was well below the technical specification D3.2 limit of 140' Capclusion Based on review of the cornputerized tracking system and observation of the morning meeting, there appeared to be an adequate process for prioritizing and processing work activities and tracking completion. No backlog of overdue work activities was identified for the spent fuel pool cooling syste Cold Weather Preparations (71714) Insoection scoor Implementation of special actions for cold weather problems was reviewed, including verification that commitments made to the NRC by the licensee in response to NRC Bulletin 94-01 were still being implemente .2 Qbservations and Findinas Provisions for cold weather protection of the spent fuel pool systems were reviewed and found adequate. The cold weather program was described in Procedure OP-C.33,-
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' Freeze Protection," Revision 13. The program addressed freeze protection for the spent fuel pool cooling system, several storage tanks and systems, fire water systems, and several pumps. Actions included verifying that pumps were running, valves were properly positioned, certain systems were drained, and radiant heaters were tumed on in specific areas. Since the spent fuel pool cooling system is typically operated continuously, freezing of the system is extremely unlikely due to the heat created by the spent fue On May 12,1994, the licensee submitted a response to NRC Bulletin 94-01, ' Potential Fuel Pool r/raindown Caused by inadequate Maintenance Practices at Dresden 1,"
Bulletin rA-01 directed licensees to verify that potential freezing failures would not cause loss cf water to the spent fuel pool. The licensee's response evaluated the freezing proMem as applicable to the Rancho Seco facility and determined that even if the lowest piping penetration for the spent fuel pool were to freeze and break, the water level in the pool would still be above the spent fuel. The licensee committed to ensuring that the spent fuel pool cooling system and demineralizer sub system would be either running or isolated from the spent fuel pool any time ambient air temperature reached 25'F. The requirement to verify that these systems were running was in Procedure OP-C.3 .3 Conclusion The freeze protection program for Rancho Seco was formalized in a freeze protection procedure which included commitments made by the licensee in response to NRC Bulletin 94 01 concerning freeze protection for the spent fuel pool. The provisions for freeze protection for the spent fuel pool were found to be adequat Decommissioning Performance and Status Review (71801) Inspection Scope An evaluation of decommissioning activities underway was completed to verify that work being performed was consistent with license requirements. This includ9d a tour of the work areas to evaluate housekeeping, fire loading, structural aspe of the areas under dismantlement related to safety, and radiological postings, Observations and Findinas Decommissioning activities were being completed consistent with the descriptions in the PSDAR. Dismantlement work had been performed on the auxiliary boilers, bulk chemical storage tanks, moisture separator re-heaters, lube-oil system, and condensate systeni. The small and large auxiliary boilers had been removed. Preparations for work were underway for the electrical high pressure turbine, low pressure turbine, and spray ponds. Future work was scheduled for the main generator, condensate pit equipment, and condensers in the turbine building. Internal contamination was expected in the moisture separator reheate .- .
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10-The PSDAR submitted by the licensee to the NRC on March 20,1997, described the limited dismantlement work that would be performed. This included the dismantlement of portions of the plant with low levels of contamination including the auxiliary boiler, auxiliary steam system, high and low pressure turbines, and the disposal of the low level radioactive wast Tours were conducted of the turbine building, basement of the auxiliary building and the tank farm. This included the component cooling water system which provided cooling to the spent fuel pool. The system was operational with no indications of leaks or
- component problems noted during the tour. The system appeared in good conditio Tours of the turbine building found no unsafe work conditions. Fire loading was minimal and the areas were relatively clear of debris and loose material. Structural components in the turbine building appeared stable. Dismantlement work observed had not involved the removal of any components that appeared to be necessary to structurally support other components such that a danger to workers could occur. The materials collected and awaiting surveys were adequately stacked out of the way. Material that had been surveyed and found to be releasable, or contaminated, was sorted and placed in specific areas that were labeled with the status of the surveyed material. Material taken out of a radiologically controlled area had been surveyed prior to removal, then resurveyed at the free release point inside the turbine building.
I Conclusion The limited decommissioning and dismantinent work underway in the turbine building appeared to be conducted safely. Housekeeping and fire loading were found to be-acceptable. Systems being dismantled were consistent with the activities described in the PSDA Health Physics (83750,83726,83729)' Insoectiu Scooe The decommissioning work activities underway involved systems that were either clean or had only slight contamination and radiation levels. The overall effectiveness of the radiological controls were reviewed related to personnel exposures and contaminatio The recent incident involving the auxiliary boiler being returned by a local scrap yard due to potential contamination was evaluated. The licensee's program for maintaining inventory and control of radioactive sources was assesse .2 Qhservations and Findinos The licensee's program for maintaining an inventory of sealed sources and maintaining control of the sources was evaluated and found adequate. The Rancho Seco Defueled-Technical Specification D 6.10.1(i) required the licensee to maintain records of the
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11-annual physicalinventory of all sealed sources. Technical Specification D3/4.7 required scaled sources in excess of 100 microcuries of beta and/or gamma emitting material or 5 microcuries of alpha emi' ting material to be leak tested prior to use or transfer to another licensee and every 6 months if in use. Written procedures were implemented by the licensee to track sources used onsite and to ensure that required leak tests were conducted. These procedures included RP.305.11, * Radioactive Material (Source)
Handling,' Revision 4; SP.1102, " Annual Accountability and Inventory of Radioactive l Sources," Revision 2; and SP.1101, *Semlannual Radioactive Sealed Sources Leakage Testing," Revision 7. Procedure RP.305.11 established requirements for source receipt, storage, accountability and inventory. This procedure required new sources to be entered into the source control data base and a storage location assigned. Procedure SP.1102 was used to conduct the annual surveillance of sources. There were 210 sources listed as being onsite. The primary storage locations for the sources were the source locker, chemistry lab and the source room. From the list of sources, nine sources were randomly selected by the NRC inspector for verification. These sources included l most of the curie and millicurie activity level sources. All nine sources were found to be l at their assigned locations and were in locked rooms or locked cabinets, as required by 10 CFR 20.1801 and 10 CFR 20.180 I The source inventory list was reviewed to determine the number of sources which required leak testing. This was compared to the licensee's leak test list in Procedure SP.1101 and found to be consistent. Eighteen sources met the criteria for leak testin s The inspector verified that these sources had been leak tested within the past 6 months.
I Technical Specification D3.6 established a 10 curie limit for radioactive material, excluding tritium and trapped noble gases, for the following tanks: A and B regenerative hold up tanks, demineralized reactor coolant storage tank, miscellaneous water hold up tank, borated water storage tank, and outside temporary tanks. Weekly verification of compliance with this limit was a surveillance requirement. Rancho Seco Procedure SP.950, " Weekly Liquid Hold up Tank 10 Cl Limit Surveillance,' Revision 1, established the process for conducting and recording the weekly surveillences. All tanks listed in the technical specification were incorporated into the procedure for weekly surveillence Weekly surveillences for the period October 29,1997, through January 7,1998, were reviewed. During this period, only the regenerative hold up Tank B had contained wate Approximately 85,000 to 90,000 gallons were present with a total curie content of 4.18 x 105 Cl. Water had been stored in the tank during the time the component cooling water system outage was underway in November 199 The personnel dose estimates for 1997 and a summary of contamination incidents were reviewed. No significant individual exposures had occurred. Final values for site personnel doses will be available after the fourth quarter external dosimetry results are analyzed. The site dose goal for 1997 was originally 2.9 man-rem. The work on the upender pit was delayed and the site man-rem goal was reduced to 0.9 man-re Preliminary results indicated that the 1997 site dose will be well below this valu , .
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Three skin contamination incidents occurred in 1997. All three involved low levels of contamination that were easily removed. All three incidents involved work in the turbine >
building by contract worker A microRoentgen(uR) survey instrument was used to verify radiation levels and confirm .
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inat work areas were below posting limits for radiation areas as specified in 10 CFR 20.1902. Radiation areas required posting if an individual could receive a dose equivalent in excess of 5 millirem (mrom) in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 30 centimeters from the radiation source. Outside the reactor building, general background levels were typically around 0.01 mR/hr, except for the area near the wall of the tank farm, which read 0.11 mR/h This area was posted as a radiologically controlled area. Ten large transport containers stored near the cooling towers were surveyed. Several were loaded with scrap material that had been free released. All transport containers measured background levels of 0.01 mR/hr. The general area outside containment read 0.02 to 0.025 mR/hr The refractory material that was between the pipes on the auxiliary boiler read 0.0. ) mR/h On December 22,1997, a scrap metal shipment was made by the licensee to a local scrap dealer. This shipment consisted of portions of the diesel fuel fired auxiliary boiler that supplied steam when the reactor was not operating. The shipment consisted not only of the metal boiler and associated tubes, but also the concrete like refractory material which surrounded the boiler tubes. This material was used on the boiler tubes to help even out the heating of the boiler and to help hold the heat in the boile The local scrap yard screened all sNpments through a radiation truck monitoring system consisting of plastic scintillator detectors located on each side of the vehicle entrance to the scales near the front gate of the scrap yard. The truck monitoring system was set to alarm at slightly above the background count rate (4.5 sigma above background) which was as close to background as practical without causing numerous false alarms due to fluctuations from natural background radiation. The alarm set point was continually updated by the system based on background counts performed between counting the trucks. When a truck set off the monitor alarm, it was driven through a second and third time to confirm the alarm. Once confirmed, the shipment was rejected by the scrap yar When the boiler from the licensee arrived at the scrap yard, the truck monitor alarmed during entry. This alarm was confirmed with two additional passes through the truck monitor. The following table represents the data from the truck monitor syste Entry Background Alarm Point Scan Time - Reading (cps)* (cps)* (sec) (cps)*
1 908 999 8.25 1020 2 908 999 11.13 1033 3 846 933 11.94 1036
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The actual counts indicated a very low level source slightly above background. The truck was retumed to the Rancho Seco site and a full survey of the truck was conducted using hand-held detectors. The licensee re surveyed the refractory materia Background levels were 6 uR/hr. The highest reading of 17 R/hr was found on the refractory material on the bottom side. During this inspection, the NRC inspector performed a survey of the boiler and refractory material. Background levels were approximately 8 uR/hr. The refractory material was measured at 15 uR/hr. At i foot from the material, the readings were indistinguishable from background, it may have been possible that due to the large amount of refractory material on the shipment, the cumulative effect of the large volume of refractory material was sufficient to alarm the monitors. Gamma spectroscopy of the refractory material found naturally occurring isotopes of radium and actiniu During the re surveying of the boiler by the licensee, a contaminated spot of approximately 2 inches square was found on the metal end bell. The contamination was determined to be Cs-137 by the licensee using gamma spectroscopy. Using a i
microRoentgen survey instrument, the contaminated spot read 6 AR/hr above
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background. Barkround was 6 uR/hr. A direct frisk of the contaminated spot using a 20 cm' probe measuM 2,000 counts / minute at % inch. Background was 40 counts / minute.
I Technical Specification D6.11 required procedures for personnel radiation protection to be prepared consistent with the requirements of 10 CFR 19 and 10 CFR 20 and approved, maintained and adhered to for all operations involving personnel radiation exposure. Rancho Seco established limits for material being released from the site in Procedure RP 305.09A,' Removal of Tools and Equipment from Controlled Areas,"
Revision 7. Step 6.1 of Procedua RP MS.09A specified that tools and equipment were not releasable if contaminated with greawr than 100 corrected counts per minute beta / gamma fixed contamination using an RM 14 with an HP 260 (or equivalent) prob Corrected counts per minute were the actual reading minus background. This limit was consistent with NRC guidance provided in IE Circular 8107, ' Control of Radioactively Contaminated Material" dated May 14,1981 and IE Information Notice 85-92, ' Surveys of Wastes Before Disposal From Nuclear Reactor Facilities' dated December 2,198 Step 6.1 also specified that surveys were to be performed by a qualified radiation protection technician. In addition to Procedure RP 305.09A, these same release limits were specified in RP 305, " Radiation Protection Plan," Article 5 * Control of Radioactive Contamination'.
A search by the licensee for the radiological survey record of the end bell portion of the boiler revealed that a survey had not been completed. Surveying of material by a radiation protection technician prior to free release was required by Procedure RP 305.03A.10 CFR 20.1501(a) also requires surveys to be completed and states *Each licensee shall make or cause to be made, surveys that (1) may be necessary for the licensee to comply with the regulations in this part; and (2) are reasonable under the
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a 14-circumstances to evaluate (i) the extent of radiation levels; and (ii) concentrations or quantities of radioactive material; and (iii) the potential radiological hazards that could be present. Failure to perform the required survey was determined to be a violation of 10 CFR 20.1501 and Rancho Feco Technical Specification D6.11 (50-312/98001-02).
A meeting and tour was conducted at the scrap yard that had rejected the licensee's shipment of the auxiliary boiler. The scrap yard was located in Sacramento and was operated by Simsmetal America. The director of corporate services provided a very comprehensive summary of the truck monitoring system used at the scrap yard. The system utilized two plastic scintillators, one on each side of the roadway. The plastic scintillators were approximately 48 inches by 15 inches in size utilizing one photomultiplier tube each. The detector readings were displayed in the office building next to the scales and alarmed when radioactive material was detected. A 5 microcurie Cs-137 source was periodically hand carried through the detectors to verify operation of the system. Simsmetal America's experience with the truck monitoring system had been
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very positive. They estimated that of the approximately 240,000 loads / year of scrap metal they receive,18 to 20 were rejectable. When a problem was found, the scrap yard called the State of California radiological agency for assistance and had interfaced with them on several occasions. Hand-held radiation detectors were also maintained by the scrap yard. Annual training was prcWded tr' management on hazardous materials to include not only radioactive material but also chemicals. Individuals interviewed during l this visit Indicated that most scrap yards and steel mills had initiate d the use of truck i
monitors to protect themselves from receiving ra:iioactive material that would then be expensive to dispose of if they could not identify who had delivered the radioactive material to the yar .3 Conclusion Overall health physics activities during decommissioning work appeared adequate in the areas of personnel exposures, contamination incidents, and control of sealed source A violation was identified for failure to properly survey an auxiliary boiler prior to release for unrestricted use. The boiler was later found to have low but detectable levels of contamination by a scrap metal deater. Failure to perform the survey was identified as a violation of Technical Specifications and 10 CFR 20.150 Follow up of Open items (92701) (Closed) VIO 50-312/97004-01 Failure to Comolete Procedure Reauirements: Failure of the licensee to generate an out-of-tolerance report for the spent fuel pool thermocouple when it was found to be out-of tolerance during the annual calibration had been identified as a violation. The corrective actions taken by the licensee included a technical review of the condition, verification that technical specifications were not exceeded for spent fuel pool temperature since the tast calibration, and additional training for maintenance personnel. All actions had been completed. Training was completed November 6,199 I
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e 15-The corrective actions taken by the licensee were reviewed during this inspection and were determined to be adequate for the condition that existe .2 (Dhgussed) IFl 50-312/96001-01 Technical Soecification RevisioD: Technical Specification clarification conceming movement of loads over the spent fuel cask was still under development for submittal to the NRC. This issue remains ope .3 (DiscussedLifi 50 312/96003-01: Incorooration of the new 49 CFR reauirements into the radwaste shionina orocedures: A contract was signed with Envirocare for up to 10,000 cubic feet of low level radioactive waste. The licensee was revising it's radioactive waste shipping procedures to incorporate the provisions of the Envirocare contract and the requirements of 49 CFR. Shipments to Envirocare are tentatively planned for the 2nd quarter of 1998. This open item will remain open until the procedures are completed and reviewed during a futuro inspectio Exit Meeting l The inspector presented the inspection results to members of the licensee management at the exit meeting on January 8,1998. The licensee acknowledged the findings presented. The licensee did not identify as proprietary any information provided to, or reviewed by, the inspecto a
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o ATTACHMENT 1 PARTIAL LIST OF PERSONS CONTACTED Licensee D. Comstock, Shift Supervisor R. Crandal, Health Physics
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J. Delezenski, Nuclear Quality & Compliance Superintendent J. Field, Technical Services Guperintendent D. Gardner, incremental Decommissioning Project Leader R. Mannheimer, Licensing Engineer K. Miller, Project Manager S. Redeker, Plant Manager J. Roberts, Maintenance Superintencent '
T. Tucker, Operations Superintendent l. - W. Wilson, RP/ Chemistry Superintendent l N. Zimmerman, Records
- Simsmetal America D. Rogers, Plant Manager D. Haw, Director Corporate Services D. Larson, Trading Manager Valley Division Bicron R. Hanson, Technical Sales Representative
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INSPECTION PROCEDURES USED 36801 Organization, Ma' nagement, and Cost Controls 62801 Maintenance ard Surveillance 71714_ Cold Weathe. Preparations -
71801 Decommissioning Performance and Status Review 83726 Control of Radioactive Materials and Contamination, Surveys, and Monitoring 83729 Occupational Exposure During Extended Outages 83750 Occupational Radiation Expostre 92701 Followup on Open items
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ITEMS OPENED, CLOSED, AND DISCUSSED Opened 50-312/98001-01 VIO Failure to complete required radic si, c.>J survey Closed 50-312/97004-01 VIO Failure to complete procedure requirements Discussed 50-312/96001 01 IFl Technical specification revision 50-312/96003-01 IFl Incorporation of the new 49 CFR requirements into the radwaste E
shipping procedures
LIST OF ACRONYMS
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CFR Code of Federal Regulations l Cl Curie DSAR Defueled Safety Analysis Report IFl Inspection Follow-up Ifen ISFSI Independent Spent Fuel Storage installation
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mR milliroentgen mrem millirem NRC Nuclear Regulatory Commission PDQ Potential Deviation from Quality PG&E Pacific Gas & Electric PSDAR Post Shutdown Decommissioning Activities Report TLD thermoluminescent dosimeters uCi microcurie uR microRoentgen '
VIO Violation l
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ATTACHMENT 2
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SPENT FUEL POOL TEMPERATURE TRENDS
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EXHIBIT 16
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coNAM IHsPECTION '
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PERIODIC INSPECTION AND MAINTENANCE
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PROJECTOR. TYPE EXPOSURE DEVICES
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sufactursr_ b ;~ -J7"7 ^4' Model No MC Serial No NO7 A '
Curie Strength 38~
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INSPECTION AND CORRECTNF. ACTION TAKEN IS PERFORMED IN ACCORDANCE
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ACCEPTABf,E i n CORRECTIVE ACTION TAKEN TrEM
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Report of Interview with Stephen L. FAY On Thursday. Septembe'r 5,1996, at approximately 11:20 a.m., Ste hen L. FAY, Laboratory Manager. Conam Inspection. Inc., was interviewed by S cial Agent Richard Anderson. NRC:RIII Office of Investigations, anc' ThcGas oun Radiation Specialist. NRC:RIII Division of Nuclear Materisis and Safety, at Itasca. Illinoi FAY stated.that he began with Conam Inspection, Inc. (Conam), in October 1984 in Minnesota, as a technician. He said that he left Conam in 1986 but return in October 1990 as a utilities supervisor. In June 1993, he became the laboratory manager at the Itasca. Illinois offic FAY said that the Gary. Indiana office was opened in 1985 with William HIESTAND as the first manager. FAY said that Keith TUCKER became the Gary office Radiation Safety Supervisor in 199 In February 1996. HIESTAND was gp discharged by Conam's senior management, and TUCKER resigned in March 1996.
D FAY stated that for the last number of bths. Conam's management had been debating whether to close the Gary office and move everyone to Itasca or to close the Itasca office and leave the Gary office cpen. Pe said that this indecision led to an uneasy feeling among the employees. After TUCKER and HIESTAND were gone from the Gary office. FAY said that he was directed by management to report to Gary as a project manager. He said that shortly after arriving in Gary, he found the office fairly organized but noticed that some radiographic gauges and survey meters needed 90 day calibration FAY stated that there was some animosity against who was also directed to report to Gary from Itasca, and him ary personnel since many of the Gary personnel had been either relatives or close frien HIESTAN Partly because of this animosity. FAY said that he chose to assist him e calibration of the survey meters. FAY said tha d worked wit before and trusted him. FAY said that the ca on of survey meters was not that difficult to learn, and he knew that was a bright employee who learned very fas FAY also said that there was no one else in tie office when they started the calibration testin FAY said that he did not issue film badge before they started. He said that he did not remember sked him for a film badge or not. FAY stated th t was just an overs on his part that he did not obtain a film badge for FAY said that he set up the ionized then calibrated the first survey meter while explaining everything t He said that the first meter took about one hour to calibrate. FAY sa
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he actually calibrated th meter whiler% Assisted. FAY said that the third meter was done while he stooo by 'assisti and where needed. FAY said that th meters were calibrated b -
owever, he said that he was close b FAY said that on a coupl sions he left the room to answer a another part of the building but mainly was in the general area with EXHET / 7 CASEtc 3-96-014 ' NE /wd _
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FAY said that after finished each meter, he (FAY) reviewe wor He said that he had paper work (which included si r.alibration sheet) so t (new exactly where each copy went. FAY stated that he knew that eac er was properly c;.librated because he,
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personally, recalibrated each meter himsel FAY stated that 1 lat same day, radiog apher, approached l him and asked wh Pha si ed the calibrati sh the meters. FAY l said that he exp ;o that he (FAY) traine per '
r 4 e for calibrating survey meter said that he as if he a "- had a problem with that, and reportedly said t d no '
FAY stated that a short while later Randy SWEET, the Itasca General Manager, d him and said that a number of radiographers were compla1ning about ignature on the calibration sheets for the meters. FAY said that he exp aired exactly what he did to SWEET but SWEET directed him to recalibrate each meter and sign a new calibration sheet. FAY said that he did this on April 12. 1996 (Exhibit E. F. I, and K).
FAY, when asked why the " accept" box was not checked on the calibration sheets that he redid, stated that it was his oversight that h',e didn't check the box:
that he didn't know why he did not check each bo FAY stated that he called and directed him to do the 90 day calibration on the radiograph ated at the Uno-ven facility in Lemont. Illinoi FA a' called him and said that the camera was calibrated by hi rch 12. 1996. FAY said that with this information he then e rm for the camera calibration (Exhibit G) and signed " Performed by [ sic) @ Unoven [ sic) Refi ar " d put as the date of inspection "3-12 .
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FAY said that he expecte- to then fill out the paperwork when he came into the Gary office and sign i FAY said that he heard later that he allegedly lied about the date: that he had predated the form to March 12. 1996, when in fact. it was allegedly done a week later. FAY said that that information was totall false: that he had absolutely nr reason f ify that document: and t gned the document as being performed by knowing full a t was to replace that document with one e ed and dated by FAY stated that he
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learned later the v .eportedly never filled out a new form.
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FAY stated that Conam management finally decided " 'eep both offices open, and he was then transferred back to the Itasca of; ic This Report of Interview was prepared on Sept . r .
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- vj Tlichard Anderson NRC:RIII Special Agent Office of Investigations EXHET /7
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CERTIFIdATE OF CAIIBRATION
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X 10 80 MR ACCEPT X 100 100 MR ACCEPT
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THE ABOVE CALIBRATIONS WERE PERrORMED IN ACCORDANCE WITH CONAM'S RSAM, PART 8, USING A G/N IC-51 CAL 1BRATION DEVIC .
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' THE ABOVE CALIBRATIONS FERE PERFORMED IN ACCORDANCE WITH CONAM'S RSAM, PART 8, USING A G/N 3C-51 CALIBRATION DEVIC t
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Report of Interview
On Thursday, September 5Inc., Inspector,ConamInspectIon,96,atapproximately10:45 was interviewed by Specia ent Richard l
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Anderson,NRC:RI!!OfficeofInvestipations,andThomasYoung, adiation Specialist, NRC:RI!! Division of Muc ear Mr.terials and Safety, at Itasca,
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Illinoi ,y stated the he be an with Conam Inspection. Inc. (Conam) on He said that he transferred to the Gary, In ana o"fi in August , . He said that he was trained as a liquid penetrant technician and was also qualified in computer and drafting design ( ). He said that he ret.eived no radiation safety training while at Con a safety orientation on the proper use of survey meters. However did state that in 1994 in received 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of radiation safety trai ng w 11e employed with Petroleum Industries, Texas, 1996, he was in the Gary office when ep enstated that on Thursday, FAY, Laboratory Manag Marchte 14,d him to assist FAY in the calibration of a number of survey meter aid that he was i.et a radiation worker;
- that he had occasionally serve helper who manned the s r outside a roped off area where radiography was taking place, ated that he inquired of FAY why FAY wanted him to assist to FAY that this would be a training session. FAY allegedly told hat he (FAY)
someone in the Gary effice whom he could trust the job righ said that he had no idea who did the calibration of the meters before that at .
tated that he did not read a procedural manual or any other training ument regarding calibration of survey meters prior to assistirg FAY. He said that the training was basically on the job training. He did remember asking FAY about the need for a film badge, but he did not remember if FAY acknowledged the need for one. However, he said that he was not given a film badge, a stated that FAY showed him how to remove the meter casing and adjust the ca ibration screws. FAY also showed him how to use the gradient markings ed on the floor) from the ionized source to assist with t bratio stated that at no time did he handle the ionized sourc said even if he were to conduct a calibration that day (August 19 ),he would have a supervisor obtain the sourc & , tated that the calibration of each survey meter took approximately 20 To 30 minutes. He said that FAY actually calibrated the first meter while explaining the procedure to him, d that with the second meter, he and FAY did the calibration togethe said that with the remaining two or three meters, he did the calibration himself; however, he said that FAY was in the same room with him at all time Macknowledged that the signature on Exhibits A, B, C, D, and J (dated March 14,1996) were his signature. He said that he felt that signing the
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certifica libration for each of the meters was part of the job training, said that he was told that a calibration was good for 90 days. He at ed ed that certificates of calibration for most of the same meters (Exhi its E. F. K, and I) were signed by FAY on April 12, 1996, said that he did not know why FAY racertified the same meter that there was no one else around when he was being trained by FA stated that shortly after that date, he was assigned to " ultra sound" tank inspections. He said that cinc.e that time, he had not calibrated any other survey meter This Report of Interview was prepared e 199 '
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Report of Interview with Randy SWEET
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On Thursday, September 5,1996, at approximately 12:40 p.m. Randy SWEET, General Manager, Conam Inspection, Inc., was interviewed by Special Agent Richard Anderson NRC:RI!! Office of Investigations, and Thomas Young, RadiationSpecialist,NRC:RI!!DivisionofNuclearMaterialsandSafeguards, at Itasca. Illinoi SWEET stated that he had been the General Manager for Conan Inspection, In (Conam), since April 1996. Prior to that he had been with Conam in Tennesse However, he said that for a couple of months prior to April 1996, he worked between Tennessee and Illinoi WrrT said that_the general manager before him did not do anything about
-^v ^]regarding the over exposure incident on February 27, 199 'He stated that We reviewed the documen red regarding the incident (Exhibit L) and perso 1 ,rviewed on March 20, 1996, SWEET said that he remnn u on car cation untti January 1, 1997,
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-n e gave him directett him to be retrained in E radiatio safety, an rected h learned training session to the compan a radiation safety lessons SWEET stated that he also disciplined a radiographer's ista t, a t me time for not we ing a a adge. He said that both
' and era reportedly upset, because the two individuals felt that the incidents happened in ths pas SWEET stated that he was contacted by a couple of radiographers from the Gary who stated that they would not use sont survey meters, becauseS
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an inspector, had signed the calibration forms as having calibrated the meters. SWEET stated that he talked to both Stephen FAY, the saboratory
. (temporarily assigned from Itasca, Illinois, to the Gary offi egarding the calibration. He at after hearing FAY's and exp anation regarding the training of to calibrate the meters, h (SWEET) did not feel that any policy h en violated. However, since the radiographers reportedly said that they would not use the meters, SWEET directed FAY to recalibrate all the meters in question and fill out new calibration sheets. He said that FAY did this on April 12, 199 SWEET said that he did not feel, after investigating the facts, that the calibration issue was a safety issue. He said that he felt that the proble; identified by the Gary radiographers was really the result of personality clashes. SWEET said that the radiographers in Gary were not happy with the
.distni s s of the erevious manager, were not happy with the discipline of q; 9b dF"%d and that they (the radiographers) did not want personnel Yordis- ITasca to run their operation. SWEET also said that since he hiredJEGM*l'lh, and the Gary radiographers knew that, the perception was that K4w., SWEET's personal fr WEET said even though he did hire G e had no real contact with ince hiring hi EXHlBIT_ JI tute 3-96-014 pg,s 1 op 4 eme<st _ - -
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Report of Interview with Robert J. SLACK On Thursday, September 5,1996, at approximately 1:30 p.m., Robert J. SLACK, Quality Assurance Director and Radiation Safety Officer Conam Inspection, Inc., was interviewed by Special Agent Richard Anderson, NRC:RIII Office of ,
Investigations, and Thomas Young, Radiation Specialist, NRC:RIII Division of Nuclear Materials and Safety, at Itasca, Illinoi SLACK stated that he had been with Conam Ins >ection, Inc. (Conam), as the Radiation Safety Officer (R50) since 1989. :4e said that he had been the Assistant R50 at Conas since 1978. He said that at each of Conam's locations, there was an individual who was designated the radiation safety superviso SLACK said that on February 27, 1996, Keith TUCKER, the Gary, Indiana office Radiation Safety Supervisor, ca pAtasca officeadiographe regarding an overex>osure incident involving SLACK said tiat he advised TUCKER to y remo from the work site and arrange for his film ba processed i diately. SLACK stated that he did not remember calling -
tas41 SLACK said that on February 28
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met; TUCKER and at the Gary offic re-enact the ont re inct ont for them, hich h HesaiothattheyhadM(camera id without any props r ladder). An incident report and tatement was taken at that '
bit L, pp. 1-5). SLACK said tha C _ reported to had the dosimetry in a fanny
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pack next to his stcmac that he surveyed the camera
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using a 360' motion. SLACK stated as very emphatic that he did not climb very high on the ladder conta ng t e camera, and that he was involved in very little twisting motion. Therefore, the impression that
@ left with SLACK was that the dosimetry was in direct line with the source, and that the dosimetry reading would be nearly t SLACK said that he didn't even consider a leg exposure based upon statemen SLACK stated that he and TUCKLR made calculations based upon statement and estimated the whole body exposurs to be between n (E However, the processed dosimetry reading was 4.6 REM. Because l emphasized that the dosimetry was next to the source (waist high), and 3 hat he did not climb higher on the ladder, SLACK said that he accepted the 4.6 REM reading. SLACK stated that he did not contact the NRC, because the reading had to be above 5 REM to be reportabl SLACK said that he reviewed the incident with Randy SWEET, the newly appointed general manager, and they issued, on February 29, 1996, a memorandum (Exhibit M) to all radiographers re-emphasizing the proper procedure when using exposure device SLACK stated that on Thur.sday. April !!, 1996, they met with NRC:RI!!
~ e-enacted for all of them t i
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technical personnel, and t using a ladder and a camer LA K said he was surprised when reported that he climbed up to the next-to-the-top step of the lad camera being on the top step of the ladder). SLACK also said that gg C.'-0(."01hi EXHlBIT M s
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indicated that the he turned away from the source little) for a period of time while he placed the f(41m, thereby exposing hismorethanjusttwistin upper left lan directly to the camera. SLACK said that the new information present b h Mo the P.RC certainly changed the amount of a receivec to his legs. SLACK said that in~ defense of he
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was probably very nervous the first time he recreated t dont and van to minimize his carelessnes SLACK stated that after a complete review, s removed 11 graphic activity until January 1, 199 he was to be retrained in radiation safe y; an a was to pres sons learned training session to the compan Regarding the incident involving '
Stephen FAY, and the survey meter calibrations, SLACK stated that he was na aware by FAY that some survey mete ed calibrating. He said that FAY later advised him that he (FAY)
used to assist in the calib ons as part of a training session with ALLE . CK stated that he knew to be a and intelligent individual and had no problem with rainin SLACK said that other than that, he was not aware of any probl e radiographers in the Gary office had with the calibrations or wit, SLACK stated that all radiographers and assistants are issued dosimetry film badges, but a survey metfr calibration source was not a radiographic devic SLACK stated that if - e ontinue to calibrate meters on his own, then he expected FAY o s ue dosimetry . SLACK said that it was probably an oversight on FAY's part at to give simeter in the first place, but he (SLACK) felt that the issue regard not having a dosimeter for the training session was a gray are felt that section j'
5.1.1. of Conam's procedures: " Personnel Monitoring Requirements" (Exhibit N),
applied to radiographic equipment. SLACK pointed out that the manufacturer's calibration manual for the IC-51 survey meter calibration source did not even address the dosimetry issu Mis Report of Interview was prepared r er
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site manager. One copy shall be re'.alned at the >b site and two copies forwarded to the regional office vnekl .0 PERSONNEL MONITORING REQUIREMENTS Personnel Monitorino Eautoment O. 5.1.4 Radiographers and adographers' assistants / trainees (l'RCR) shal
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with ionizing radiation or transporting by product materials. The pocket dosimeter must be capable of measuring doses from zero to
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, at least 200 milliroentgens. Additionally, en alarm rate meter sher also be wom when regulations requir ,
5.1.2 A film badge shall be assigned to, and wom by, ontv one oermon. as it is the legal media for making the determination of an over exposure. Used film badges must be retumed to the regional office immediately upon receipt of a re, placement badge for the next badge perio '
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5.1.3 Badges not being wom shall be stored in a radiation free are .
5.1.4 Pocket dosimeters shall be recharged at the boolnnino of each work shift and periodic readings taken throughout the work shifL Such
/ checking will give immediate indication of radiation exposure and work procedures shall be corrected if excessi"e exposure is note At the end of each work shift final readings win be taken and recorde .1.5 Any individual whose pocket dosimeter goes off scale (Over 200 mr),
while using a source of radiation,1.hall immediately stoo oroductive work. recharoe his dosimeter. and make a comolete radiation survev of the area, making certain that no additional radiation exposure is receive (a), if the source of radiation is in the shielded position, immediately notify the Radiation Safety Officer, Assistant Officer, Manager, or an Assistant Manager, about the condition of the dosimete (b) If the source is in the exposed position, make certain the area is restricted and access is controlled to preve. t a radia6cn hazard, and notify the regional office bout the condition of the source and your dosimeter. The individual's film badge shall be processed immediately. He shall not work in areas where he can receive additional exposure until the results reported -
show that his total exposure is not in excess of allowable limit EXHlBU M MM
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o EXHIBIT 24
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CASEHO. 3-96~b14 EXHIBIT 24
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, Report of Interview
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September 5, Igg 6, at approximately g:55 a.m.. M bchnician,ConamInspection,Inc. vss interviewed by Special Agent i nderson NRC RI!! Office of Investig,ations and Thomas Young,
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j l Radiation specialist, NRC RI!! Division of Nuclear Materik1s snd safeguatvis, l st Itasca. Illinois.
! "*#w#'tatedthathehadstartedwithConwaIr,sper. tion,Inc.(Conan),in
- as an assistant radiographer, but had qualified to become a pser. He said that between September 'c'id and May 1993, he worked
! with Indiana Where he attended courses to become a radionr phy. He also obtained, hat time frame the 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />
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IndustryServices(5GS),during(lleyConunityd11egein y scfety course from Moraine Va n o .
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aid that after he started with Coram, Keith TUCKER, the former Conas ra on safety supervisor for the Gary thdiana field office, conducted s trainingforhimintheConam's'0operatIngandEmergencyproceduresMahdal'
! for the various cameras and an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> r6diation safety review, which included i a written tes *
stated that he was familiar with the operating s,nd emerpency ce ures for the Amersham Model 6608 exposure device since he sad used the
- imera at both !G5 and Conas.
I T said that during the latter part of February 1936, he was working for
- nn at a 13te in Indianapolis, Indiana. He said that another radiographer, 1 -- 2 was wo ith him. He said on February 27, they were working j n e night shiot, and was in the dark room developing fil He stated i that he was alone and was 5 ooting t' butt welds with the Amersham exposure device. He said that he had already comp 16ted between 12 and 15 shots. He i
believed that he had followed all the procedures up to that time but admitted
- that he might have, on occasion, become lax in assuring that the ring selector was turned to the locked position and that the pleger was depressed.
l stated that the comp ny where they were workin was not happy with
! The radiography production and was stressing that they fConam radio lraphers)
! needed to increase the number of welds that wert, shot each sh m was i
! directed to increase the sinft hours from eight to 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> stated
! that even with the longer hours it was still difficult to get the t to I welds per shift. He said that the area he was shooting was very congested, with each shot taking approximately 10 minutes. He sa'd that on the average, each weld recuired approximately three shots, so he was still pressured to
! increaseproductio o tated that at approximatet;/ 4:30 p.m., en the 27th of February,
! 99 , e performed a shot with the camera located at the top of a six foot
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ladder. He stated that his dosimetry was located in c fanny pack next to his stomach. He said that after he cranked the sou.ce back, he neglected to turn the selector ring and depress the plunger. He did state that lie thought he heard the slide bar kick ever but could have been mistaken since it was a high
. noise area. He said that he surveyed the camera, but only on the sides. He
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EXHIBIT U
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said because of the camera posittore, he did not' survey the front part. He said that he stood on the ladder war the top rung, with his leg closest to the c,amera, and changed the film. He said tist he then reactied over to unlock Wie bar but realised that the slide bar was not totally engage @ tated that he immediately move $ the slide bar to the unlock position an tsen exited the area. He said that when he checked his desiastry, it was off scal
said that he then fully retracted the source entti he heard a clic e said he checked the alarming rate meter and it was okay. At this point, he surveyed the cawra totally, pulled the t ra, and went to the trailer to explained the inuJent t tated hen telephoned TUCKER, who told him to wait r a re n p one call.'
stated that he thought Robert SLACK, Conan's Radiation Safety Off ce (R50 called his back and directed him to return to the Gary office the next day),.
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tated that on February 28 1996, he met both TUCKER and SLACK at the ary c SLACK his dosleetry and thou explained to them what happened, afd that he told SLACK and TDCKER that during the incident, he was nly f6cing the camera while surveying the camera and i
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changing the film. He said tist he stood on the second rung from the top, next to the camera. He 1 that the only time he turned from the camera was to change the film, said that he was told that his dosimetry reflected 4.6 Rems. He said that he thought that r was a true representative of the radiation that he received, id state that his leg was actually closer to the camera than the badge was attached retar his wais % stated that radiography activity unti 199 . e sat a he was removed from e a so received retraining on the proper operation and safety procedures regarding the camera "~
stated that he did not follow the procedures for the camera, but he
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d nc o it deliberately. He said that he was under pressure to increase the number of shots, and that was the reason for his c4relessnes This Report of Interview was prepared on %c; 9, q
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NRC:Rll! Special Agent Office of Investigations EXHlBITJL PAGE(S)
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l EXHIBIT 25 cAstND. S-0G-014 EXHIBIT 25
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i Control Cable: 25 ft. Lmg
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i (c) TE0HNICAL OPERATlQNS MODEL 532,660, CAPACITY 100 CURIE IRIDIUM 122 All exposure devlees must be inspected at the beginning of each day that It is used. The radiographer making the inspection will sign the radiation l
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report in the space provided, certifying the inspection was performe INSPECTION PROCEDURES ARE FOUND IN SECTION 1 QPERATION: BURVEY CAMERA
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. Unlock with the key and tum the selector ring from LOCK to CONNECT. The storage cover will disonage from the projecto . Slide the control cable collar back and open the jaws to expose the male portion of the swivel coupling (i.e., the ball-entt on the drive cable). J Press back the spring loaded locking pin with a thumb nail and engage the male and female portions of the swivel couplin .
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' Release the locking pin and check that the connection is s3our Close the jaws of the control cable connector over the swivel couplin . Slide the control collar over the connector jaws. ' .
NOTE: The drive cable connector, when property installed with the selector ring in the CONNECT position, displaces anti rotation lugs which allows the selector ring to be rotated to the LOCK position and when required through ;o the OPERATE poshio . Push and hold the control cable collst flush against the projector ,
connector andictate the selector ring from CONNECT to LOC Do not rotate past LOC The drive cable connector is now locked into the projecto . Keep the projector in the LOCK position until ready to* start the -
exposur . Remove safety plug from the 'out' connection of the exposure device and connect the guide tube MBIT 28
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, . Extend guide tube and control cables in as near a straight une as ;
- possible and place free guide tube at the exposure position.
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1 Unlock the 533 model exposure devlos. The 533 model is ready to operat Unlock the 860 exposure devlo Use the key to unlock the ;
projector look and rotate the selector ring to the OPERATE positio Ensure there is no tension xrce In either direction on the drfve cabl l Push the slide bar (green meikliig) isterally from left to right (as seen behind the projector) until the slide bar (red marking) fully appears
- on the right side of the selector ring and you feel or hear the sleeve j snap into slide. When the green marking is visible the source
, assembly is locked into the safe' 'ored position within the projector; when the red marking is visibe the source assembly is free
, to be projected from/to the projector. The source is now free to j mov :
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1 Survev to determine that radiation levels do not exceed 2mr/hr at the boundaries or perimeter of the radiographic are . At end of exposure, retract source into unit.
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1 Survev camera and guide tube carefully to be sure that source has
- returned to safe positio ;
. On Model 660 the automatic locking mechanism will engage and the
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, green dot will be exposed on the slide bar.
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(WARNING-EXPOSURE DEVICES CAN BE LOCKED IN AN UNSAFE POSTION.)
j 1 On Models 660 and Models 533 tum selector ring from operate to lock and secure with the projector loc i
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The location of the source (storage safe, guide tube or exposure position)
must always be determined by using a survey meter before, during and after each exposure. .
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(dNbCHNICAL OPERATIONS MODE ACITY . 200 CURIE IRi31DM,192
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This un}t is a light weight, i (200 curies Iridium 'iB2), vacuum
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operated, remotely controlled system .
anually/ mechanically established vacuum with an on.cff/ exposed stored so o .
I EXHIBri .25
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as CONAM o&s N/30/W
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,e i The procedures specified in Paragraph 9.1, shall be followed when
, exchanging sealed sources between a radiography exposure devlos and source change .4 if any unauthortred person enters the radiation area the source wt be retracted and no exposures made unts the area is cleared.
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10,0 PROCEDURES FOR HANDLING AND USE OF LICENSED SEALED SOURCES
, AND RADIOGRAPHIC EXPOSURE DEVICES
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1 General All sealed sources used for Industrial r.if.cgi.FJiy by CONAM
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INSPECTION INC, are housed in remote operated, shielded camera type .
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, devices. The handling of byproduct materials using 'open air" or "Ilsh pole *
j techniques is prohlbhed. Any evallable shielding and/or a collimator shal
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be used when practicable.
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' 1 When performing radiography, the radiographer or assistant radiographer /tralneo (TRCR),- under direct supervision of the
., radiographer / trainer, shall conduct a physical radiation EDSX on the rear, i sides, top and front (360') of exposure device as follows:
- (a) After each radiographic exposure to determine that the sealed source has been returned to its shielded position, in addition to the
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above 360' survey, ,t a guide tube must be surveyed after each t
exposure, t i
j (b) Prior to storing the radiographic exposure device, to determine that
! - the sealed source is in its shielded poth!cr TT,& highest reading of .
I this survey must be recoidea on the radiation report (See Appendix A).
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(c) in order to use up stock of radiation reports, the word ' securing'
shall be marked out and the words, ' storage of" written in, also indicate 360' as per Appendix .2.1 in no case should the levels of radiation for the above surveys
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exceed the following limits:
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(a) Radiographic exposure devices measuring less than four (4)
inches from the sealed source storage position to any exterior ,
surface of the device shall have no radiation level in excess of
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, 50 milliroentgens per hour at six (6) inches from any exterior surface of the devic I ta coNW o & E 0$/3B/53 ExHeit .25 -
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m.e*-4AM2,w u _ A s m a Awou.23hd h a - ar,ha-- ---m -4 . mm-=%.am_.._.au.m,,4%e w w,p-m maa.a m.w-,u a w a m m m.a-mav-- - -- . - - - - - - - -
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EXHIBIT 26
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l EXHIBIT 26
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CHECKLIST FOtt INCIDENT REPORT Name ofIndMdual Making Reprt: KEITH TUCKER -
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Date ofReport: 2/27/96 Date ofincident: 2/27/96
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Time ofineldent: 5:3$ Source:IR 192 S/N A't462 CO 60/S/N N/i
. Desimeter 61020 2 .
Due: Kate Meter: 13102 Due:12/16/97
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.. Curies: '94 f*~ Camera Model # '660 Shlal #: B2179*, '
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,, . , , , Survey Meter Model #, GS 2006 * Serial #: 1032 Vold Date: 3/5/96 :<,' ,
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Was Survey Meter'Wpking Conectly? lYES
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' Rate Meter? YESi'. 7. '.-
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fI . How Was the So6rce Retum'ed to the Safe Position? NORMAL CRANKINIL
,. Who Retamed the Sodree to'the Safe Position? , :.; . ,,
j,* By Wse Authority Yas th' e Source' Returned?' NOT REQUIRED
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Was any ,lndividual's bosimeter Discharged? 'If' Yes: -
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Was Individual removed frotn any seerties where they. coup receive an .
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additionalexposure? YES -
Was film bad 6p' [cked up.for immediate processing? YES ,,
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W.as ' dosimeter recharged? YEs! NO DRIFT FOR 16 HOURS -
. Cajeulate Exposures:(Show Calculations): N : s.s + 554,600mr/i ni - 554R/hr 3.0667 - x.97R :
$$4.400'h2 * 138mr .0667 = t.24R et .! .
. Whole Body 91o.36 REM Actual Whole Body 4,6 REM ,
Was Individual Retumed to Duty (RT)? NOT UNTIL F/B IS PROCESSED
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,.. Job Location: ELI LILLY / INDIANAPOLIS,IN 1317/227 9729 x 389B .
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tonective Steps Taken'1R'esuits Achieved (Ust additional sheets as necessary)
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Conective Steps Which Will Be Taken To Avoid Future incidents:
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Date When Full Compliance iVill Be Achieved: CURRENT ~
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Transmittal Date: 2/28/96 RSO office Received Date: 2/2A/96 REPLY WITH TEN (10) DAYS OF TRANSMITTAL DATE!
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CC: Boyd Creech Responsible Manager: '
RJSjjh:96 045 EXHIBILM m ' '
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EXHIBIT 27
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DATE: FEBRUARY 29,1996 3
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To: * DISTRIBUTION
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. FROM: ,
R. J. SLACK h - +
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.REF: RADIATION INCIDENT ,
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On Febrdary 27,1996, the attached incident occurred in Indianapolis, I ,
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After reviewing the written description of the lacidg}t and observin'gia,*inock-up" reenat:tment of the occurrence, I have determined the followin ..
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s s The survey to assure the source was in the secured position was performi>d but not with
., full attention given to tty reading coming from the exit port bf the camera /.
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Additiorialty, as the entrance door was closed, the radiographer could noin$arsie slide -
7 bar mechanism * click * Into the safety stored position (green dot exposen. Aifailed to assure that the slide bar was completely in the safety stored position. Theyl was not yotated from the " operate * to * lock" pos} tion nor was the keyliock plunger mechanism depresse .g ,. 4 L
This incidert .:'sutted 'in a whole body exposure to.the radiographer of 4.6 REM. With a January dose of 0.150 REM already recorded, the decision has been raade to remove the ..
radiographer from ALL future radiographic operations for the duration of the 1996 calendar yea In order to avoid futureincidents of this nature,it is determined that ALL exposure devices wiil be operated in the following manner:
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DISTRIBUTION . .
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March 1,1996 -
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Prior $ to the initial exposure,'ALL radiographers must assure that the source is ;
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connected property to the drive cable; the drtvo cable housing is property. connected .
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to the camera; the otrnera is set into the 'oporete* position, and, efter exiting the
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.n After,co'mpleting' EACH exposure, a full and accurate survey of the collimator, gdide ,,
' *. . tube., camera exit port and complete perimeter of the camera will be performed, the camera position' selector mechanism will be rotated (rnanipulated) to the LOCKED
. position and the key lock plunge: WILL BE DEPRESSE ** g
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Any deviation of these instructions will be grounds for digelplinary action lip"to and
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Please apjrise ALErediographic personnel of these instructions as they will bW held
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accountab e for compliance, ..
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DISTRIBUTION: ./ .?
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M. Creech ( J. BrueggeW . 5.Creech/ '
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NW. Hutand J. Burke v P.Za 9ala '
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D, Bertollottj J. Ward / b.Tormiensee .
K. Tucker / / R. Wlison *' '.} /
A. Bogarry# .
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N. Difondo / R. Catarett R. Turco
D. Totman V C. Norcutt 7 J.Fhng .; -
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S.Shennan/ Unoven Site Re/ L Gallowey ~
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B. Kremlun
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EXHIBIT 28
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s,0 MRSONNEL TRAIN lNQ AND QUALIFICATION REQUIREldENIR Administratka Personnd-As administroth personnel named on Appendix A, (other than electronic repair), that meet either (a) or (b) plus (c) belo (a) Three years practical experience in psitorming or cArecting the performance of industrial radiographic operation or
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(b) Successful completion or en approved formal course of instruction in radiation health physius (i.e. training school courses of general l Industry neceptance, quellred loonsee's training program or
, equivalent programs).
M o (c) Successful completion of a one hundred twenty fivs (125) questions radiation safety tes Additionally, all administrative personnel must be qualmed radiographers prior to performing radicy.9,y and, to perform source recovertes, they must be qualified radiographers plus shall have rooolved instructions in source recovery or have equivalent experience, in no event shall any administrative personnel perform functions in excess of their experience and instruction . The experience and training record of each man named shall
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be documented and maintained on file by the Radiation Safety Offce .2
.Radiograohars . To quellfy as a radiographer with CONAM inspedm, Inc.,
, each techniolan who has not worked as a radiographer for another toones must meet the following requirements:
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-'~~,,.i 1 Recehe a minimum of thres mcWJ,5 on-thejob training
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performing industrial radiography under the supervision of a quellfed radiographer and have assigned to him a copy of CONAM's ' Operating and Emergency Procedures Manual.' ,
5. Receive or have received a minimum of fortyJotal hours-formal instructions covering the following points: *
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4 CONAM RSAM 03-26-93
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L FUNDAMENTALS OF RADLATION SAFETY
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l characteristks of gamma radiatio Units of radiation dose (mroms) quantity of radioactMty (curie).
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' Hazards of exposure to radiatio Levels of radiat'on from Boonsed motorial.
, Methods of controlling radiation dose- . Working Time Working Distances Shlolding I RADIATION DETECTION INSTRUMENTATION TO BE USED I Use of radiation survey instrumerfts- ' Operation Calibration
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$. Survey Techniques -
s ... . Use of personnel monhoring equipment- Film badges and thermoluminescent dosimeters (TLD's) Pocket dosimeters Alarming rate meters Il RADIOGRAPHIC EQUIPMENT TO BE USED Remote handling equipment
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b.' Radiographic exposure devices Storage containers I INSPECTION AND MAINTENANCE PERFORMED BY.TNE RADIOGRAPHERS
. CASE HISTORIES OF RADIOGRAPHY ACCIDENTS -
E041BITM PAos A oFJ PAGES 5 CONAM RSAM 03-26-93
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5. The sony hour total required to quesy as a radiographw may consist of the abaeon hours formal to quemy as an assistart radiographer, plus twentriour to quaNy as
. radiographer, or may consist of a forty hour course given by
'..outside aponey, =g-;=cJ by the Redistion Safety Omoo . Demonstrate his abluty to property uttte radiation survey instruments, personnet monitoring equipment and evidence a thorough understanding of sunoy techniques involved. Must
, be aware of the correct operation of such instruments, the calibration requirements and the Imitations of the instruments
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used. Must also have a worldng knowledge of the primary mathematics involved in basic radiation anta'd=*w . Demonstrate thorough famRarity with the radiographic exposure equipment used, daily inspections and maintenance requiremt,nts, and with instructions for safe application of the
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units involved. Thl,s will be documented using the Sold i examination form (Radiographer).
5. Pass a written examination designed to test his knowledge and understanding of the points covered in the training and instructions he has reoolved. The examination wil consist of
- fty or more questions selected from a Est of 125 possible questions and a grade of 75% or better is required to pas Each question that is answered incorrectly will be discussed and reviewed with the studen . Technicians who have previously wotNod as radiographers for -
another licensee may be quellfed for CONAM 11- It can be verifed that the technician has worked as a fully quellfied radiographer for another licensee, and ; Receives instructions in CONAM's O&E Manual,'
including equipment operation, and the NRC Uoense (State License where appreable).
- Satisfes the requirements of 5.2.4 and 5.2.5 by'
practical demonstration, and Is tested as required in paragraph 5. . Students not passing the initial examinations shall not be
_ qualified as radiographers until additional instruction and rs -
examination (using dttforent questions) quellfes the CONAM FDMIBip3M3
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EXHIBIT 29
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Report of Interview
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On Thursday, August 29 1996 adiogra her Level II, Conan i
Inspection,wasintervIewed tal/genkRichardAndersonatthe !
Uni-ven Refinery, Lemont, Illinoi j e tated that he started with Conan Inspection i He said ;
.a as already a trained radiographer in May 1993, ill
- Conam Ins 1 HIESTAND, Gary manual. He said that he work Office Manager $d out of t$ection, e Sary trained office and wouldhis go on to aConan's new policy
job location each day. He said that each day he would take a different !
radiographic gauge. He said that the tauge would then be returned to the office each night.
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i W n Ftated that in February 1995, he was assigned permanently to the Uni-1ery,Lemont, Illinois. He said that before he started there, Keith TUCKER, Conam Supervisor, instructed him on how to do a 90 day inspection on
. gauges. He said that there were two gewes assigned to the Lemont sit : Dur' ng 1995, he said that he did at less". three inspections of the gauges, which included signing the paper work. However, he said that on some
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occasion., the gauges were returned to the Gary office, and new gauges were ,
brought back to Lemon aO aid that around February 1996, there was a major turnover of I at the Gary office. He said that HIESTAND and TUCKER resigned, and that Steve FAY, who had ng out of the Itasca Illinois office, became the new manager, aid that he was aware that during this time -
period, there was some e cause of the abrupt change in personne n e said that he rememb the March 18,1996 FAY called him and t the enues that he ad was just past due fer the 90 day inspection. m m M said t instructed to do the in,tpection stely. ano snat FAY would handle the paper work back at the Gary offic G Tsaid that he did the full inspection of the gauge immediately, m stated that the next day, March 19,1996, he was in the Gary office a ed at the paper work (Exhib he gauge. He said that he observed that FAY had noted that he had done the inspection (which he said was correct), but that the paper wor the inspection was reported as being done ta March 12, 199 aid that he did not think anything of it, because he knew that FAY was o get all the paper work, which was just left in disarray by TUCKER, in or e d
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stated that he did not feel that FAY was trying to deceive the NRC-a was doing his best to reorgant ceandthatthatparticular
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90 day inspection was just over looke aid that he was aware that since that time, all gaeges were inspec on .
T ~ aid that he was aware of the rumor regardin
erforming an n dt n of some survey meters, but he had no first an now dge of the inciden EXHIBIT N
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aid that he was aware of th ncident in February 1996 in w1 e radiographer failed to s nger lock on the camera after a shot and had over exposed himsel d that it was true that before the incident, he and others were 1 king the plunger; however after that inctoent, the ssuedadirectiveorderingeveryonetofollowthe written procedur aid that since then he had been diligent in following all proce Conan Inspectio This Report of Interview was prepared on Friday. A"~?:t 'a 199 n1C at An J
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Special Agent, RI!!
Office of Investigations l
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