IR 015000038/1998001: Difference between revisions

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{{Adams
{{Adams
| number = ML20247D979
| number = ML20249A088
| issue date = 03/30/1998
| issue date = 06/04/1998
| title = Insp Rept 15000038/98-01 on 980309.Apparent Violations Being Considered for Escalated Enforcement Action.Major Areas Inspected:Radiation Safety Activities
| title = Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 15000038/98-01. Corrective Actions Will Be Examined During Future Insp
| author name = Costello F, Reber E
| author name = Blough A
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
| addressee name =  
| addressee name = Thielsch H
| addressee affiliation =  
| addressee affiliation = THIELSCH ENGINEERING ASSOCIATES, INC.
| docket =  
| docket =  
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = 15000038-98-01, 15000038-98-1, NUDOCS 9805180166
| document report number = 15000038-98-01, 15000038-98-1, NUDOCS 9806160042
| package number = ML20247D966
| title reference date = 05-08-1998
| document type = INSPECTION REPORT, NRC-GENERATED, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| document type = CORRESPONDENCE-LETTERS, OUTGOING CORRESPONDENCE
| page count = 7
| page count = 2
}}
}}


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INSPECTION NO. 150-00038/98-001 i
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i U.S. NUCLEAR REGULATORY COMMISSION REGION I  '
Docket No.: 150-00038   '


RI License No.: 3D-065-01    )
==Dear Mr. Thielsch:==
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Report No.: 98-001 l
This letter refers to your May 8,1998 correspondence, in response to our April 23,1998 letter.
Licensee: Thielsch Engineering, In '
Facility: Bridgeport Resco Location: Bridgeport, Connecticut Date:  March 9,1998 Inspector Eric H. Reber
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          [ I Health Physicist l
Approved by:  fa A F ncis M. Costello, Chief b 3d /#9
        [/ date clear Material; Safety Branch 3 l
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REG 10ill 9805180166 980403 PDR  STPRQ ESQRI PDR
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Thank you for informing us of the corrective and preventive actions documented in your letter.
e EXECUTIVE SUMMARY Thielsch Engineering, In NRC Inspection Report 150-00038/98-001 An announced inspection, limited to a review of radiographic operations performed by Thielsch Engineering, Inc. on February 27,1998 at Bridgeport Resco was conducted on March 9,1998. Two apparent violations for 1.) failure to keep unauthorized individuals out of the restricsed area; and 2.) failure to file NRC Form-241, " Report of Proposed Activities in Non-Agreement States," prior to engaging in activities in a Non-Agreement State were identifie /98-001
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l These actions will be examined during a future inspection of your licensed program.
REPORT DETAILS 1. Background RI License No. 3D-065-01 authorizes Thielsch Engineering, Inc. (licensee), in part, to perform radiography at temporary jobsites in the State of Rhode Island. On February 27,1998, the licensee used an Amersham Model 660B radiography camera (S/N B2301)  l with a 27.6 Ciiridium-192 source to perform radiography at Bridgeport Resco, a co-generation facility, in Bridgeport, Connecticut.' The licensee's radiographer and engineering assistant were at the site performing radiography. During a three minute ;
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exposure, an unauthorized Resco employee was inside the restricted are On February 28,1998, the Connecticut Department of Environmental Protection (CTDEP) was conducting an inspection regarding an unrelated matter at Bridgeport Resco when they were informed of the incident. On March 2,1998, the CTDEP informed NRC Region I that the licensee had performed radiography at Bridgeport Resco, and that an unauthorized individual was inside the restricted area when the radiography source was exposed. On March 9,1998, two Region I inspectors reviewed the inciden II. Control of Restricted Area Inspection Scope The inspectors reviewed the licensee's control of the restricted area established ren February 27,1998 at Bridgeport Resco for compliance with NRC requirement Obsen/ations and Findinas On February 27,1998, Thielsch performed radiography on the attemperator above the superheater penthouse on the 9* level of Boiler #3 at Bridgeport Resco. The 9" level is the uppermost level of the facility. Thielsch planned to establish a restricted area on the 7",8* and 9" levels of the facility. Two stairways lead to the 9* level. The radiographer, engineering assistant, and a Resco employee cleared the 9* level, including the superheater pmthouse, of personnel. The Resco employee and the  ;
licensee's engineering assistant then cleared the 8* level, and then the 7*. As they
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proceeded, they placed yellow and magenta ropes and restricted area caution signs at elevator openings on the 9*,8*, and 7* levels. Ropes and signs were also placed across the stairways at the 6* level. Approximately 45 minutes passed after the restricted area was established. Prior to exposing the 27.E Ci iridium-192 source, an announcement that radiography was to be performed was made over the facility's public address system. After the restricted area was established, a Bridgeport Resco
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employee, without the knowledge of the Thielsch radiographer, entered the superheater penthouse on the 9" level, an area below where the source would be exposed. While the source was expose 1, the Bridgeport Resco employee exited the superheater penthouse through the access hatch and was seen by the radiographe The source was retracted immediatel /98-001


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Your cooperation with us is appreciated.
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. Conclusions Thielsch is required by their license to " Confirm that no unauthorized personnel are within boundaries of restricted area" during and after radiographic exposures and this did not happen. The licensee's procedures also require that "No unauthorized personnel shall be allowed within the restricted area."


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Condition 19 of RI License No. 3D-065-01 requires that licensed material be possessed and used in accordance with statements, representations and procedures contained in Radiation Safety Manual NDT-41, Revision 1 !
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Item 7.2 of this manual requires that "No unauthorized personnel shall be allowed  ,
I within the restricted area." ltem 7.5 of this manual requires that licensee personnel will i confirm that no unauthorized personnel are within the boundaries of the restricted area during and after radiographic exposures.


l The finding that, on February 27,1998, unauthorized personnel were allowed within
Sincerely,
! the restricted area and licensee personnel did not confirm that no unauthorized I personnel were within the boundaries of the restricted area during and after radiographic exposures is an apparent violation of Condition 19 of RI License N D-065-0 Ill. Dose Estimate 1 Inspection Scooe The inspectors reviewed the dose estimate performed by the licensee for the Resco employee that was present in the restricted area when the radiography source was expose , Observations and Findinas Later in the day on February 27,1998, the radiographer arranged the 27.6 Cl  l Iridium-192 source as it had been when the Resco_ employee was exposed and  i measured dose rates where the employee had been during the exposure. The
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' measured dose rates were as follows:
Original signed by A. Randolph Blough
Access Hatch  <2 mR/hr l Resco Employee work area <0.5 mR/hr l
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A. Randolph Blough, Director Division of Nuclear Materials Safety I
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Employee's path of travel from work area to Access Hatch 1 mR/hr Exposure directly under source 4 mR/hr All dose rates appear reasonable considering source strength, distance and the fact that a 8.3 hajivalue layer collimator was used with the beam pointed away from-4-  150-00038/98-001
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State of Rhode Island
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State of Connecticut
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where the Resco employee was working. These measurements could not be repeated during the inspection because the boiler was in operatio The source had been exposed for 2.5 minutes when the Resco employee was discovered. The Resco employee spent approximate!y 1 minute at the work area and 1.5 minutes traveling from his work area to the access hatch. The licensee estimated a total dose of 0.005 millirem for the Resco employee. This estimate
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appears to be conservative, and, at the very least, the dose estimate would not approach the dose limit for members of the public (100 mR/yr). Conclusions The licensee's dose estimate is conservative. Dose limits for individual members of the public were not exceede IV. Training Inspection Scope The inspectors reviewed the training of the radiographer for compliance with NRC requirements.


! Observations and Findies The radiographer involved received 40 hours of radiation safety training and 80 hours of radiography training when working for a previous employer. He had 120 hours of classroom radiography training with another previous employer. The radiographer also received training regarding equipment and procedures specific to the licensee. He was tested by the licensee and received a composite score of 92.55%. The written portion of the exam included general radiation safety questions as well as questions specific to radiography. The radiographer was also required to demonstrate the proper use of radiography equipment. He received annual retraining on January 2,1998 and passed an examination with a score of 96%.
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The radiographer stated that he has always been instructed to keep people out of the restricted are c,  Conclusions The radiographer involved in this incident was trained in accordance with NRC requirement IV. Reciprocity Inspection Scooe l-5- 150-00038/98-001 ,
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9806160042 980604 PDR STPRO ESGRI PDR l
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The inspectors reviewed the licensee's authorization to perform radiography on February 27,1998 at Bridgeport Resco in Bridgeport, Connecticu Observations and Findinas l
On February 27,1998, Thielsch performed radiography at Bridgeport Resco with a 27.6 curie iridium-192 source, but did not file an NRC Form-241, " Report of Proposed Activities in Non-Agreement States," prior to commencing work. The Thielsch employee responsible for filing such forms stated that he believed Connecticut was an agreement state and therefore, did not require a Form-241 to be filed. The licensee  I, filed an NRC Form-241 on March 4,1998 after being informed that the form was recuire Conclusions 10 CFR 30.3 requires in relevant part, that no person shall possess or use byproduct material except as authorized by a specific or general license issued by the NR CFR 150.20(a) provides, in part, that any person who holds a specific license frem an Agreement State is granted an NRC general license to conduct the same activity in non-Agreement States subject to the provisions of 10 CFR 150.20(b).
 
10 CFR 150.20(b)(1) requires, in part, that any person engaging in activities in non-Agreement States shall, at least 3 days before engaging in each such activity, file 4  ;
copies of NRC Form-241," Report of Proposed Activities in Non-Agreement States",  1 with the Regional Administrator of the appropriate NRC regional offic The finding that, on February 27,1998, Thielsch Engineering, Inc., a licensee of Rhode Island, used 27.6 Ci of iridium-192 in Bridgeport, Connecticut, a non-Agreement State, without a specific license issued by the NRC and without filing Form-241 with the NRC is an apparent violatio VI. Management Meetings Preliminary results of the surveys were discussed with Bruce MacLure, the licensee's Laboratory Supervisor at the conclusion of the inspection.
 
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Oi I Thielsch Engineering, Inc.
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l PARTIAL LIST OF PERSONS CONTACTED Licensee Bruce MacLure, Laboratory Services Supervisor, Thielsch
Distribution:
!  Stephan Goodyear, Radiographer, Thielsch Bob Duhamer, Radiographer, Thielsch l
PUBLIC Nuclear Safety information Center (NSIC)
Bridaeport Resco Tom Maillet, Operations Manager, Resco Robert Cushing, Control Room Operator, Resco State of Connecticut Department of Environmental Protection Mike Firsick, Radiation Control Physicist l
Region i Docket Room CBuracker, RI i
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- DOCUMENT NAME: G:ONMSDOCWORK\\lNSPLTR\\LRl3D065.01A 16320088
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To receive e copy of this document, inecote in the bos: "C" = Copy w/o attach /enct
*E" = Copy w/ sttach/enci
*N* = No copy OFFICE DNMS/RI lN DNMS/RI lN DNMS/Rh l N l
NAME EM FMCostell#M ARBlough T.


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DATE 06T04/98 064/98' M 06/JT98 06/ 198 OFFICIAL RECORD COPY l
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Latest revision as of 12:45, 16 March 2025

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 15000038/98-01. Corrective Actions Will Be Examined During Future Insp
ML20249A088
Person / Time
Site: 015000038
Issue date: 06/04/1998
From: Blough A
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To: Thielsch H
THIELSCH ENGINEERING ASSOCIATES, INC.
References
15000038-98-01, 15000038-98-1, NUDOCS 9806160042
Download: ML20249A088 (2)
v • d • e


Text

SUBJECT:

INSPECTION NO. 150-00038/98-001 i

Dear Mr. Thielsch:

!

This letter refers to your May 8,1998 correspondence, in response to our April 23,1998 letter.

Thank you for informing us of the corrective and preventive actions documented in your letter.

l These actions will be examined during a future inspection of your licensed program.

Your cooperation with us is appreciated.

l

Sincerely,

.

Original signed by A. Randolph Blough

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A. Randolph Blough, Director Division of Nuclear Materials Safety I

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State of Rhode Island

State of Connecticut

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9806160042 980604 PDR STPRO ESGRI PDR l

IE07

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Oi I Thielsch Engineering, Inc.

Distribution:

PUBLIC Nuclear Safety information Center (NSIC)

Region i Docket Room CBuracker, RI i

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l l

!

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- DOCUMENT NAME: G:ONMSDOCWORK\\lNSPLTR\\LRl3D065.01A 16320088

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To receive e copy of this document, inecote in the bos: "C" = Copy w/o attach /enct

  • E" = Copy w/ sttach/enci
  • N* = No copy OFFICE DNMS/RI lN DNMS/RI lN DNMS/Rh l N l

NAME EM FMCostell#M ARBlough T.

DATE 06T04/98 064/98' M 06/JT98 06/ 198 OFFICIAL RECORD COPY l

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