IR 015000038/1998001

Insp Rept 15000038/98-01 on 980309.Apparent Violations Being Considered for Escalated Enforcement Action.Major Areas Inspected:Radiation Safety Activities

ML20247D979
Person / Time
Site:	015000038
Issue date:	03/30/1998
From:	Costello F, Reber E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20247D966	List: ML20247D961 ML20247D979
References
15000038-98-01, 15000038-98-1, NUDOCS 9805180166
Download: ML20247D979 (7)

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i U.S. NUCLEAR REGULATORY COMMISSION REGION I '

Docket No.: 150-00038 '

RI License No.: 3D-065-01 )

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Report No.: 98-001 l

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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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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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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. 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

! 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

' measured dose rates were as follows:

Access Hatch <2 mR/hr l Resco Employee work area <0.5 mR/hr l

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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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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 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of radiation safety training and 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> of radiography training when working for a previous employer. He had 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> of classroom radiography training with another previous employer. The radiographer also received training regarding equipment and procedures specific to the licensee. He was tested by the licensee and received a composite score of 92.55%. The written portion of the exam included general radiation safety questions as well as questions specific to radiography. The radiographer was also required to demonstrate the proper use of radiography equipment. He received annual retraining on January 2,1998 and passed an examination with a score of 96%.

The radiographer stated that he has always been instructed to keep people out of the restricted 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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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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l PARTIAL LIST OF PERSONS CONTACTED Licensee Bruce MacLure, Laboratory Services Supervisor, Thielsch

! Stephan Goodyear, Radiographer, Thielsch Bob Duhamer, Radiographer, Thielsch l

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

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