ML20210T508

Insp Rept 99990002/97-07 on 970814.Apparent Violations Being Considered for Escalated Ea.Major Areas Inspected:Facts & Circumstances Surrounding Unauthorized Removal of Generally Licensed Fixed Gauging Device

ML20210T508
Person / Time
Issue date:	09/04/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20210T505	List: ML20210T501 ML20210T508
References
REF-QA-99990002-970904 99990002-97-07, 99990002-97-7, NUDOCS 9709150164
Download: ML20210T508 (7)

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' U. S. . NUCLEAR REGULATORY COMMISSION REGION 11:

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, Docket No.: 999 90002 i 1 1 License No.: General License (10 CFR 31.5)  :

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- Report No.

999-90002/97-07 i.

Licensee

Virginia Power Company.  ;

j' Location: Chesterfield Power Station

• 500 Coverdale Road

. Chester, Virginia  :

} Dates: August 14,1997-

! Inspector: John M. Pelchat, Health Physicist t-

Approved by

Thomas R. Decker, Acting Chief >

i Materials Licensing / inspection Branch 1 Division of Nuclear Materials safety  :

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- 9709150164 970904 REG 2 GA999 EUTVEPC

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L l EXECUTIVE

SUMMARY

Virginia Power Company NRC Inspection Report fJo. 999-90002/97-07 s

This Tpecial, anrcunced inspection was conducted to determine the facts and circumstances surrounding the unauthorized removal of a generally licensed fixed gaugirig davice at the licensee's Chesterfield Power Station facility in Chester, Virginia.

l TM 'nautherized removal of the fixed gauge was identified through a routine licensee N,v illance of erarally G licensed devices installed at the facility . The licensee's investigation into the removal determined that the device was removed from a fly ash hopper by a contrador  ;

employee during maintenance activities in June 1997. After removing the gauge from the fly

, ash hopper, the contract emp oyee set the device aside on an adjacent cable tray. The shutter of the gauge was open at the time of its remova; and may have remained in that condition for approximately two months. The removal of the gauge by a person not specifically licensed to do so was identified as an apparent violation, in addition, other gauges were observed to have labels, containing information required by NRC regulations, obscured by fly ash and dust and

! therefore were not legible. This also was identified as an apparent violation i- Upon discovery of the gauge's condition in August 1997, the licensee took prompt action to close and lock the gauge shutter and to place the device in safe and secured storage. The licensee also prompt!y made arrangements to have an authorized individual examine and leak test the device. The authorized individual confirmed that the sealed source and its containment were not damaged The inspector examined the fixed gauge and confinned that the device was in good condition and 'liat it was in safe and secure storage.

Two apparent violations of regulatory requirements were identified during the inspection.

4 Attachments:

List of Persons Contacted inspection Procedures Used 4

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REPORT DETAILS 01, INSPECTION OF UNAUTHORIZED REMOVAL OF FIXED GAUGE (87103)

a. Scope The inspector reviewed licensee incident reports, direct rad'ation and radioactive contamination survey results, and maintenance procedures; and , interviewed licensee and contractor employees to determine the adequacy of the licensee's actions regarding the unauthorized removal of a generally licensed fixed gauge.

The inspector also walked down areas of the plant in which p~ rally licensed fixed gauges were installed.

b. Observations and Findinas The inspector reviewed licensee records and interviewed the licensee's plant Radiation Safety Officer (RSO), the plant Production Leader, other licensee and contractor employees, and the individual who removed the fixed gauge. Based on these reviews, and interviews, the inspector determined the following.

The Chesterfield coal fired power plant was operated by Virginia Power Company.

The plant operated 130 generally licensed fixed gauging devices to measure levels of various materials throughout the facility.

On June 17,1997, contractor personnel from insulation Specialists Inc. (ISI) were removing insulation from the exterior of the Unit 6 AC3 fly ash hopper so the hopper skin could be inspected and repaired. A contractor employee encountered a generally licensed fixed gauge containing about 72 millicuries (mCl) of cesium 137 (Cs 137) during this activity. The device was a Kay-Ray /Sensall, Inc.

Model 7062 BP source holder. Without prior consultation with other contractor or licensee personnel, the contractor employee removed the gauge with the device sht.tter open. The contractor employee then placed the device on a cable tray that ran adjacent to the fly ash hopper. The device was placed in such a manner that the source shutter was pointed downward and the device was irradiating an area on a catwalk below the cable tray.

The device's removal was discovered on August 12,1997, by the plant RSO during a routine physicalinventory of fixed gauges installed at the facility. As he approached the Unit 6 - AC3 fly ash hopper, the RSO noted that the fixed gauge was not in place. The RSO found the gauge by following the cable that ran from a remotely located operating handle mounted on the fly ash hopper to the gauge's shutter actuation mechanism. The RSO immediately obtained a padlock, moved the gauge shutter mechanism to the fully closed position and locked the device.

The RSO notified local and corporate levellicensee management of the unauthorized remcyal of the fixed gauge. A licensee representative notified the NRC of the event on August 12,1997.

The RSO notified the device manufacturer, Kay-Ray /Sensall, Inc. In accordance with the information provided by the device manufacturer, the RSO roped off the area, and posted the cordoned off area with " Radioactive Material- Keep Out"

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signs. The RSO performed radiation surveys of the device and measured 8 - 35 millirem per hour (mR hr ") on contact with the gauge and 1.8 2.5 mR hr 4 at 30 centimeters (1 foot) from the gauge.

On August 13,1997, health physics staff from the licensee's Surry nuclear power plant performed more extensive radiation surveys of the removed fixed gauge.

4 Licensee surveys measured 38 millirem per hour (mR hr ) on contact with the side of the gauge housing and 3 mR hr at 30 centimeters from the gauge.

0.08 mR hr " was measured at the boundary of the cordoned on area.

Radioactive contamination surveys were performed in accordance with the Surry Power Station Health Physics Technical Procedure for sealed source leak testing.

These surveys measured less than 1000 disintegrations per 100 square centimeters (dpm 100 cm4) on the exterior of the gauge housing.

The licensee had a contract for fixed gauge service and support with TN Technologies. This firm was the parent company of Kay-Ray /Sensall, Inc. the firm that originally manufactured the removed fixed gauge. The RSO contacted TN Technologies and requested that a authorized individual be dispatched to the Chesterfield plant to inspect and leak test the device and assist the licensee in moving the device into more secure storage.

On August 14,1997, the representative from TN Technologies moved the gauge into a locked equipment cage located within a warehouse at the licensee's facility.

The TN Technologies representative inspected the device and discovered no i apparent damage. The TN Technologies representative also leak tested the device's sealed source and found no removable contamination.

At the time of the inspection, the inspector found that the gauge was located in the locked equipment cage and that the RSO had the only key to the padlock on the enclosure door. The inspector's examination of the device confirmed that the device had not suffered any evident damage.

Based on information provided by licensee staff and observation of the area in which the gauge was placed after removal, the inspector estimated the exposure rate in the vicinity. The inspector's calculations indicated that the exposure rate -

one meter below the device was about 24 millirem per hour. This estimate was conservative because it did not take into account the shielding that would have been provided by the structure of the cable tray or by the cables in the tray. It is also likely that personnel working in the vicinity of the gauge were more than one meter away from the device and that they were not always standing directly in line with the source housing shutter. The inspector's calculations also assumed that the source housing shutter was fully open. However, the RSO stated that it was his recollection that less than a complete lever arm movement was required to close the device's shutter. Partial closure of the source shutter may have resulted in lower actual radiation levels. As of the date of the inspection, plant personnel were not certain what inspection or repair activities had taken place near the device and how long such activities would have lasted. The production coordinator stated that it might be possible for the licensee to estimate the duration of maintenance activities in the vicinity of the removed gauge by reviewing plant maintenance records.

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Upon discovery of the fixed gauge's removal, the licensee contacted the insulation contractor and determined the identity of the individual who removed the fixed gauge from the Unit 6 - AC3 fly ash hopper. The licensee confirmed that the contractor employee hat - amoved the device while removing insulation from the  ;

fly ash hopper. During the inspection, the inspector interviewed the individual and l her foreman and determined that the individual had not received any radiation  !

safety training; was not familiar with the radiation warning label or: the device or the radiation caution symbol; and, that contractor employees removing insulation from the fly ash hopper had not been informed of the presence of the fixed gauges nor had they been informed that any handling of the devices was prohibited.10 CFR 31.5(c)(3) requires that any person who acquires, receives, possesses, uses, or transfers byproduct materialin a device pursuant to a general license shall assure that tests for leakage of radioactive material and proper operation of the on-off mechanism and indicator, if any, and other testing, installation, servicing, and removal from installation involving the radioactive material, its shielding or containment, are performed: (1)in accordance with the '

instructions provided by the labels; or (2) by a person holding a specific license pursuant to 10 CFR Parts 30 and 32 or from an Agreement State to perform such activities. Removal of the fixed gauge by a person not specifically licensed by the NRC or an Agreement State to perform such activity was identified as an apparent violation of 10 CFR 31.5(c)(3) (eel 999-90002/97-07-01).

Through interviews of licensee personnel engaged in plant maintenance activities, the inspector determined that the licensee had developed procedures entitled " Environmental Guidelines for Station Employees," that specifically prohibited the removal of fixed gauges from any fly ash hopper. These procedures also required that any dislocated fixed gauge be reported immediately to the plant production leader, who in tum would direct any required actions.

However, licensee personnel stated that contractor personnel were not informed of these procedures prior to beginning the removal of insulation off the Unit 6 -

AC3 fly ash hopper.

The inspector walkea down the installation of other generally licensed fixed gauges installed in the vicinity of the Unit 6 - AC3 fly ash hopper. Examination of other fixed gauges found that the radiation warning labels affixed to the gauge housings were obscured with a layer of fly ash, dust, or other materials and that the labels were not legible.10 CFR 31.5(c)(1) requires that any person who acquires, receives, possesses, uses or transfers byproduct material in a device pursuant to a generallicense shall assure that alllabels affixed to the device at the time of receipt and bearing a statement that removal of the label is prohibited are maintained thereon and shall comply with all instructions and precautions provided by such labels. The failure to maintain labels affixed to these gauges in a legible condition was identified as an apparent violation of 10 CFR 31.5(c)(1)

(eel 999-90002/97-07-02).

c. Conclusions The inspector concluded that the generally licensed fixed gauge was removed from its installation during a maintenance activity on the Unit 6 - AC3 fly ash hopper. The individual who removed the gauge was neither technically qualified

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4 nor were they specifically licensed by the NRC or an Agreement State to remove the device. The licensee discovered the removed fixed gauge during a routine physical inventory to account for licensed materials possessed and used at the facility. - Upon discovery of the removed gauge, the licensee took prompt action to secure the gauge, and to contact qualified personnel to determine the device's condition.

Despite the licensee's development of procedures to preclude the removal of fixed gauging devices, the licensee failed to train contractor personnel on these procedures or to notify contractnr personnel of the presence of generally licensed devices on the Unit 6 - AC3 fly ash hopper. The licensee also failed to ensure that radiation warning labels on fixed gauges were maintained in a legible j condition. While the statements of the contractor employee suggest that a legible label would not have prevented the removal of the fixed gauge from the hopper in this particular instance; under most circumstances, a legible label may have prevented the unauthorized removal by serving to alert personnel of the presen:e l of radioactive materials and to seek out guidance before handling or removing the device. Two violations of NRC regulatory requirements w% identified.

EXIT MEETING

SUMMARY

T An exit meeting was held with the licensee representatives indicated in Attachment 1. The licensee was advised that two violations of regulatory requirements had been identified during the inspection. These were: (1) removal of a generally licensed fixed gauge by a person not specifically licensed to perform such activity; and, (2) failure to maintain radiation labels affixed to gauging devices in a legible condition. The licensee was advised that Region 11 management was preparing a confirmatory action letter formalizing certain licensee commitments regarding the evaluation of the radiological consequences of this event and to ensure that licensee and contractor personnel were trained conceming the proper handling of fixed gauges at the plant, 1 No dissenting comments were received from the licensee.

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5 ATTACHMENT LIST OF PERSONS CONTACTED -

Licensee D. Holley, Plant Manager

• B. Tomlinson, Environmental Compliance Coordinator and RSO P. Parker, Production Coordinator R. Ames, Production Leader

• Attended July 30,1997 exit meeting.

Other-

• N. Norton, Field Service Representative, TN Technologies P. McCay, insulation Specialists Inc.

D. Slagle, Foreman, insulation Specialists Inc.

t INSPECTION PROCEDURES USED IP 87100 Licensed Material Program IF87103 Inspection of Incidents at Nuclear Materials Facilities LIST OF OPEN ITEMS ltem No. Status item Tvoe Description

. 99-90002/97-07-01 Open eel Unauthorized removal of generally licensed fixed gauge.

90002/97-07-02 Open- eel Failure to maintain required radiation . l warning label in legible condition.-

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