Information Notice No. 85-43: Radiography Events at Power Reactors

                                                          SSINS No.:  6835 
                                                           IN 85-43        

                               UNITED STATES 
                       NUCLEAR REGULATORY COMMISSION 
                    OFFICE OF INSPECTION AND ENFORCEMENT 
                           WASHINGTON, D.C. 20555 

                                May 30, 1985 

Information Notice No. 85-43:   RADIOGRAPHY EVENTS AT POWER REACTORS 

Addressees: 

All nuclear power reactor facilities holding an operating license (OL) or a 
construction permit (CP). 

Purpose: 

This information notice is provided to alert licensees to three events that 
occurred at nuclear power plants in the preoperational phase. No significant
personnel exposures resulted from these events; however, such events 
indicate a potential for significant exposures. Licensee corrective actions 
and lessons learned from the events are discussed. 

It is expected that recipients will review this information for 
applicability to their facilities and consider actions, if appropriate, to 
preclude similar problems at their facilities. However, suggestions 
contained in this notice do not constitute NRC requirements; therefore, no 
specific action or written response is required. 

Description of Circumstances: 

A brief description of each of the three events is provided in Attachment 1.
In each event, the responsible radiographers failed to maintain a high 
radiation area (created by radiographing) clear of unauthorized personnel. 
In each case, the radiographer did not use all reasonable means to ensure 
the affected "shot" area was evacuated. In two of the events, bullhorns 
(voice amplifiers) were either unavailable, in disrepair, or simply not 
effectively used, even though required by local procedures. In highly 
congested areas, such as BWR drywells, visual-only searches for 
clearing/warning personnel simply are not effective. In one case, the 
radiographer left his watch area during the exposure. In all the events, the 
radiographers promptly retrieved and stored the sources when they discovered 
unauthorized personnel in the affected area. 

Discussion: 

10 CFR 34 establishes licensing and radiation safety requirements for 
radiographers. Part 34 specifically requires certain precautionary 
procedures, making the radiographer responsible for ensuring worker safety 
by maintaining proper access controls for areas affected by radiographic 
operations. However, each power plant licensee can help increase worker 
awareness of radiography operations. Power plant licensees can help increase
overall worker safety by cooperating with and augmenting the radiographer's 
control actions, where appropriate. 


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                                                             IN 85-43      
                                                             May 30, 1985  
                                                             Page 2 of 2   

Appropriate enforcement actions against the radiographers as a result of the
events either have been taken or are under consideration. 

In an effort to improve control and increase their oversight during 
radiographing, power plant licensees have taken the following corrective 
actions as a result of their review and lessons learned from the three 
events. 

1.   Plant control procedures for radiographing have been strengthened by 
     clearly defining specific plant actions to provide additional oversight
     measures to augment the radiographers control efforts. 

2.   Plant worker awareness of on-going radiography was increased by 
     training opportunities offered by routine plant safety meetings. The 
     importance of remaining vigilant and obeying all radiological warning 
     postings was reemphasized. 

3.   Appropriate plant health physics coverage is provided for radiographic 
     operations. 

No specific action or written response is required by this information 
notice. If you have any questions about this matter, please contact the 
Regional Administrator of the appropriate regional office or this office. 


                                   Edward L. Jordan, Director 
                                   Division of Emergency Preparedness 
                                     and Engineering Response 
                                   Office of Inspection and Enforcement 

Technical Contacts: J. E. Wigginton, IE 
                    (301) 492-4697 

                    R. L. Pedersen, IE 
                    (301) 492-9425 

Attachments: 
1.   Event Summaries 
2.   List of Recently Issued IE Information Notices  
.

                                                             Attachment 1  
                                                             IN 85-43      
                                                             May 30, 1985  

                             Event Summaries 

Perry Nuclear Power Plant, Unit 1                 Event Date: 6/16/84 

While radiographing in the drywell using a 200 curie Ir-192 source, 
radiographers noticed two workers leaving the controlled shot high radiation
area. These workers had been working near the reactor vessel, about 15 feet 
from the source (on a lower elevation) while a full radiographic exposure 
(13 min.) and an abbreviated (2 min.) exposure had occurred. According to 
the radiographers, a visual search was made, radiation warning signs and 
barriers erected, but no bullhorn was used to warn personnel. The bullhorn 
normally used had been inoperable for several weeks. The NRC inspector noted 
that the workers' location was shielded from view in most directions by 
piping, components, and scaffolding. Based on a reenactment of the incident 
(exposing dosimeters in the location that had been occupied by the workers), 
a maximum dose reading of 15 mrem was observed. 

Clinton Power Station, Unit 1                     Event Date: 1/5/85 

While radiographing the biological shield on the 737-foot elevation in the 
drywell, a radiographer noticed two workers descending a ladder 
approximately 20 feet from the exposed 76-curie Ir-192 sealed source. 
Although bullhorn and public address system warnings were given (but none on 
the elevation where the workers had been located), workers on the 755-foot 
elevation reportedly could not hear warnings. Based on a reenactment of the 
incident, workers were each assigned 20 mrem from their stay in the high 
radiation area (maximum exposure rate of 6OOmR/hr). 

Hope Creek Nuclear Generating Station, Unit 1     Event Date: 3/21/85 

While radiographing a piping weld inside the control building, a 
radiographer noticed a worker inside the no-access area. Contrary to the 
surveillance requirements for a high radiation area, the radiographer had 
left his watch area when the 53 curie Ir-192 source was exposed; upon 
returning, he noticed the apparent inadvertent entry. Further search found a 
second worker in the affected area. Based on the licensee's worst-case 
evaluation, it is unlikely that any worker received a dose greater than 12 
mrem.