ML19249B729
| ML19249B729 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 08/30/1979 |
| From: | Felton J NRC OFFICE OF ADMINISTRATION (ADM) |
| To: | Fox E HARRIS, BEACH, WILCOX, RUBIN & LEVY |
| References | |
| FOIA-79-307 NUDOCS 7909040714 | |
| Download: ML19249B729 (2) | |
See also: IR 05000244/1974001
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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AUG 3 c 979
DOCKET f40. 50-244
Edward H. Fox, Esquire
Harris, Beach, Wilcox, Rubin & Levey
Attorneys At Law
Two State Street
Ifi RESPONSE REFER
Rochester, NY 14614
TO FOIA-79-307
Dear fir. Fox:
This is in response to your letter dated August 3,1979 in which you
requested, pursuant to the Freedom of Information Act, copies of all
documents relating to investigation report No. 50-244/74-01.
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Documents 1 through 5 of Appendix A are enclosed.
Documents 6 through 9 of Appendix A have already been made publicly
available at the NRC Public Document Room (POR), 1717 H Street, N.W.,
Washington, DC and at the Local Public Document Room (lPDR) located at
the Rochester Public Library, Business and Social Science Division,115
South Avenue, Rochester, NY.
Copies of documents 1 through 5 will also
be placed in the PDR and LPDR.
The purpose of the LPDR is to provide a local source of access to publicly
available records relating to the R. E. Ginna facility.
The documents
subject to your request should be located in the " Inspection" and " Correspondence"
files at the LPDR. All records in the LPDR are available for public
inspection and copying.
Sincerely,
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Division of Rules and Records
Office of Administration
Enclosures: As stated
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APPENDIX A
1.
7/27/74
Letter, R. Nader to Chairman Ray
2.
8/7/74
Memo, C. Kuhlman to J. Davis re Excessive Exposures
3.
11/12/74
Letter, D. Knuth to R. Nader
4.
Undated
Letter, R. Nader to K. Knuth
5.
5/19/75
Letter, D. Knuth to R. Nader
SA. 3/25/74
Letter, S. Green to D. Knuth
6.
IE Investigation Report 50-244/74-01
7.
6/7/74
Letter, J. P. O'Reilly to Rochester Gas & Electric
8.
7/3/74
Letter, K. Amish to J. P. O'Reilly
9.
7/18/74
Letter, J. P. O'Reilly to Rochester Gas & Electric
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UNil ED STATES
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NUCLEAR REGULATORY COMMISSION
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AUG 3 c 979
DOCKET NO. 50-244
Edward H. Fox, Esquire
Harris, Beach, Wilcox, Rubin & Levey
Attorneys At Law
Two State Street
IN RESPONSE REFER
Rochester, NY 14614
TO FOIA-79-307
Dear lir. Fox:
This is in response to your letter dated August 3,1979 in which you
requested, pursuant to the Freedom of Information Act, copies of all
documents relating to investigation report No. 50-244/74-01.
Documents 1 through 5 of Appendix A are enclosed.
Documents 6 through 9 of Appendix A have already been made publicly
available at the NRC Public Document Room (PDR), 1717 H Street, N.W.,
Washington, DC and at the Local Public Document Room (LPDR) located at
the Rochester Public Library, Business and Social Science Division,115
South Avenue, Rochester, NY.
Copies of documents 1 through 5 will also
be placed in the PDR and LPDR.
The purpose of the LPDR is to provide a local source of access to publicly
available records relating to the R. E. Ginna facility.
The documents
subject to your request should be located in the " Inspection" and " Correspondence"
files at the LPDR. All records in the LPDR are available for public
inspection and copying.
Sincerely,
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J. M. helton, Director
Division of Rules and Records
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Office of Administration
Enclosures:
As stated
SOM.!CO
APPENDIX A
1.
7/27/74
Letter, R. Nader to Chairman Ray
2.
8/7/74
Memo, C. Kuhlman to J. Davis re Excessive Exposures
3.
11/12/74
Letter, D. Knuth to R. Nader
4.
Undated
Letter, R. Nader to K. Knuth
5.
5/19/75
Letter, D. Knuth to R. Mader
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5A. 3/25/74
Letter, S. Green to D. Knuth
6.
IE Investigation Report 50-244/74-01
7.
6/7/74
Letter, J. P. O'Reilly to Rochester Gas & Electric
8.
7/3/74
Letter, K. Amish to J. P. O'Reilly
9.
7/18/74
Letter, J. P. O'Reilly to Rochester Gas & Electric
SC/12CU
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July 27, 1974
The Honorable Dixy Lee Ray
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Chaircan
The Atomic Energy Connission
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b'a s h i n g t o n ,
D.C.
20545
Dear Chairnan Ray:
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Your attention is called to matters relating to overex-
posures suffered by workers at the Indian Point I and Ginna
plants.
In the Indian Point case, the corrective action pro-
posed by Consolidated Edison and accepted by the AEC is clearly
inadequate in preventing future overexposures.
In both cases,
the AEC's lack of guidance in establishing worker control
standards is at least partly responsibic for the overexposures.
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Indian Point overexposures:
The Indian Point cases involve eight' individuals who were
clicwed to cxcccd their cuartcriv . ose ; i ..i t s .
c. e r the 7+ r i n d
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Novenber 1972 to December 1973.
Two cases involved 18 year
olds who were overexposed before their ages were discovered.
Uncertainty pervades the remaining overexposures.
In each of
the six cases, dose by film badge was greater than 3 ren, but
dose by dosineter was less than 3 ren.
In the worst case, the film badge dose was nearly four
times that of the corresponding dosineter value (2290 nren vs.
575 nren, during September 1973; reported by letter from Con
Edison to Directorate of Regulatory Operations (DRO) on November
23, 1973).
'The only nention Con Edison nakes of any efforts
to resolve the film-dosineter dis crepancy appears in the Noven-
ber 23 letter.
The company assures DRO that Con Edison is
" accelerating our investigation" of the discrepancy.
Apparently
the acceleration has not been rapid enough to provide answers
at this time.
The company's proposed corrective action for the dis-
crepancies is to require workers to wear thermoluminescent
dosineters (TLD's) as a measuring device.
But the conpany has
not determined the causes of the film-dosincter differences.
Nor has it evaluated relative accuracies of the two nethods
when a difference occurs.
The company in fact has provided no
public evidence that it is investigating either probica.
To
use the TLD's without answers to these problems is merely to
add a third potential discrepancy.
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Chairman Ray
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Page Tuo
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Question (1) :
Con Edison's public files are silent on
its efforts to resolve the film-dosineter discrepancies.
!!as
the conpany kept the AEC inforned of its efforts to solve
these problens?
!!as the AEC required the company'to adequately
inform the AEC of the company's efforts?
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Ginna overexposures:
Additional problems have occurred at the
R.E.
Ginna plant.
In a letter to DRO dated March 25, 1974, Rochester Gas and
Electric (RGE) reported that 40 ten had received filt badge
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doses of 3 rem or greater in a quarter, while the dosineter
doses for the same nen were all less than 2500 nren.
In four
cases, the dose by film badge was greater than 5 ren.
RGE felt that the discrepancies were due to improper
supervision of workers - all 40 nen were caployed by an outside
contractor for maintenance on the spent fuel pit.
As corrective
action, Ginna now requires that any contractor personnel be
closely supervised by RGE personnel.
RGE was apparently unaware
of the Indian Point problens, and believed.that yorker control
would clininate the Ginna problec.
In light of similar occur-
ences at two plants, however, the possibility of a generic
'.iscrepun.f.- c nnnr he di misned.
Question (2):
Are the Indian Point and Ginna cases iso-
lated incidents, or does a g e n e ri c film-dosineter discrepancy
exist?
If a generic proble
does exist, what. action has the
AEC initiate'd to solve it?
Inadequacy of Con Edison c: rective action:
As further corrective
ction for its overexposures, Con
Edison has established a 3i-it of 2 ren, after which a worker
is excluded from radiatior. .:rk for the remainder of the quar-
ter.
This limit is suppose
to prevent the worker from
receiving a dose by film b; ;e whi~ch might be greater than
3 ren per quarter.
However, in four out of the six cases involving greater than
3 rem exposure, this limit would not have prevented the exces -
sive doses.
Consider the folloeing cases:
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1.
An overdose during April 1973 was reported by a Con
Edison letter to DRO on June 18, 1973.
The individual received
1980 trea by dosimeter during. April 5 and 11.
h' hen his film
badges for those days were developed several days later, they
gave an exposure of 3080 tren.
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An overdose 'during August 19732*Yo
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Teported by a Con
Edison letter to DRO on September 14, 1973.
An individual who
had no previous exposure for the quarter entered a high radiation
area wearing an 0-2000 mren dosineter.
He left the area after
noticing the dosimeter was off scale.
His film badge when
developed read 3210 nren.
3.
An overdose during September 1973 was reported by a
Con Edison letter to DRO on November 23, 1973.
An individual's
exposure during July and August 1973 was 925 nren by dosineter
and 1420 area by film.
His dose by dosimeter for September was
575 nren; when added to the film dose for the previous two months,
this would have given 1995 aren total exposure.
When the Sept-
ember film badge was developed later, it gave an exposure of
2290 nrea for a total of 3710 aren.
4.
An overdose during October 1973 was reported by a Con
Edison letter to DRO on December 13, 1973.
The individual's
exposure earlier'in the conth was 1050 aren by dosineter and
1030 nren by filn.
His next dosimeter reading was 925 nrec, for
a total of 1975 nrem.
When the film badge was developed it
,
read 2700'cren for a total of 3730 nren for the' quarter.
.
Clearly, in none of these four cases would the' 2 ren
1111'_ ' c. e p r i c ; .. t ; d :"::: .:p e r ur c by fil .
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that the AEC would have accepted Con Edison's proposed corrective
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action, had the agency been completely aware of the inadequacies,
as it should have been.
But th.e Regional reply to Con Ediron's
proposed action was little more than an acknowledgment (Region
I letter to Con Edison, May 16, 1974).
Question (3) :
Was the AEC aware of thi's case by case
inadequacy in the co mp any 's corrective action?
If the nEC was
not aware of the inadequacy, why was it overlooked?
If the AEC
was aware of the inadequacy, why did it accept the company's
action?
!
Consolidated Edison's program seems nore inadequate V. - n
compared even to RGE's program to control radiation exposures.
At Ginna, the following controls were in effect prior to the
1.
RGE personnel were assigned to rero the dosimeters
of contractor personnel.
2.-
Daily dosimeter lists were maintained.
3.
Men were restricted from radiation work when the desi-
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neter dose reached 1920 nren.in a quarter.
When a 1.3 factsr
is applied for possible film dose di f ferences , this gives 2500
nren adjusted exposure.
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4.
A daily' dose list with the 1.3 factor was prepared in
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order to restrict nen below the 2500 nrem level.
Authorization
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in writing was required for any man to exceed 2500 nrea adjusted.
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Chairman Ray
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Page Four
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The Con Edison
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than th e
Since RGE's program wRGE program in effectcorrective
action is
before
thus less
it is
even more pu : ling insufficient
the Ginna
effective
as
corrective action without
to prevent overexposure
that the
AEC accepted Con Edison 'o v e re xp o s
.
comment.
s
Question
than general
(4) :
than
guidelinesRegulatory Guides'8 8 a
ments these Guides,
for limiting radiationnd'8.10 give
.
for
does
the AEC have any sta d
nucicar plant
n
exposures. o more
programs
Other
Necessary AEC action:
to
n ards
control
or require-
worker exposure?
It is
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not
different technicalunexpected that di ffe ren t
n on-s tandardization ofsp e ci fi ca ti ens ,
an apparent
plant
in lightnuclear plan ts have
that
in different pla.tshodge podge systems.
of
of worker
is morethe present
It
each plant's
action will resultinstructionsThe AEC should reviewcon trol programsinexpli
.
in advancingfor preven ting overexpand standardize
exists
the
The Ccde of Federal
health of nucleaosures.Sdch
for
Consolidated Edisoncivil penalties in theRegulations,
workers.
The
for over
overexposuresof radiation 10~CFR 20.601, provid
dents
case
action
, year.
the
e r p e r;-
involve overexposures.
tributedto resolve
The
to
-t:n recurring inci-
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company hasthe incidents. film-dosinc ter discre
th e
no disccr.. ilia
In a show
pancies
o previous
established corrective cf callous which co
c
ve r e xp os ur es .a s es
n eg lig e n c e ,n -
For thesewould have been insuffici
action which if applied
caonstrate its
reasons, it is
to prevent
ent
egulations.
concern for worker
urged that
safety by invoking thesthe AEC
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Sincer'ely,
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Ralph Nader
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UNITED STATES
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ATOMIC ENERGY COMM;SS!ON
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AUG
7 1974
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John Gr. Davis, Deputy Director for Field Operations, R0
EXCESSIVE EXPOSURES AT INDIAN POIllT NO. 1 AND GINNA - LTR FROM
R. NADER TO CHAIRMAN RAY DTD 7/27/74 - EVALUATE FILM EADGE VS.
DOSIMETER READINGS AND RESPOND TO QUESTION (4) IN THE NADER LETTER
Ref:
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The letter frcm R. Nader points out significant discrepancies
between dosimeter and film badge dose readings at the subject
nuclear plants.
Per your request, following are some of the
reasons that could result in such discrepancies.
1.
If beta radiation was present, the film badge would rccord
it but the pocket dosimeter would not, due to the thick
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housing of the pocket dosimeters.
Thus, the film badge
would show a higher dose.
In some reactor maintenance
work, the beta radiation could be as much as 90% of the
total radiation.
2.
Pocket dosimeters do not record low energy gara radiation
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whereas the film badges do.
Again, in such situations the ~
film badge would show a higher dose.
3.
There could be a difference in readings if ths film badges
were worn in a different location than the pocket dosimeters.
This would be especially true in working around, and close
to, small radiation sources.
4.
Significant differences in dose readings coul: . rise if the
pocket dosimeters were not calibrated or were Nulty and/or
the film badges were improperly processed or
. iluated.
5.
If neutron radiation was significant, the neutron film (if
provided) would reveal it; pocket dosimeters of the type
probably used at tha subject plants would not t;e sensitive
to neutro1 radiation.
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6.
Intentional exposure of the badge to a radiation source (but
not the pocket dosimeters) would reveal a ligher badge dose.
7.
If storage locations for badges were in an area where
radiation levels were higher than should be and the pocket
dosimeters were stored in a lower radiation level area,
this would nake a difference; i.e. , the badge would show
a higher dose.
8.
Some error, however small, is imminent for all kinds of
dosime te rs .
But such errors should not result in the
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large discrepancies cited in the R. flader letter (provided
the pocket dosimeters were properly calibrated and the
film badges properly processed and evaluated).
9.
Film badges would read higher than dosimeters if subjected
to extremes of high temperature or moisture or if the films
were somehow exposed to light, causing film darkening.
In your request, you also asked for a response to Question (4)
of R. Ilader's letter.
In addition to the cited Regulatory
Guide 8.8 and 8.10, we have 10 CFR 20 which specifies dose
limits for individuals (20.101) and requires surveys to be
performed to evaluate radiation hazards (20.201).
The most
important of these rules for the subject case would appear to
be the requirement for surveys.
In this instance, physical
radiation surveys of the work areas to establish radiation
levels would be in order and stay-time limits established
accordingly, regardless of the use of personnel dosimeters.
In addition, there are three published Regulatory Guides, each
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of which invoke AtiSI Standards.
These are Reg. Guide 8.3,
" Film Badge Perfomance Criteria (AtlSI til3.7-1972)," Reg. Guide
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8.4, " Direct Reading and Indirect Reading Pocket Dosimeters
(NISI ill 3. 5-1972)" and Reg. Guide 8.2, " Guide for Administrative
Practices in Radiation Monitoring (ill3.2-1969)."
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for Radiological, Environmental
and Materials Protection, R0
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ATOMIC ENERGY COMMISSION
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Mr. Ralph Nad r
2000 "P" Street, N ' W.
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7th Floor
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Washington, D. C.
20036
Dear Mr. Ndder:
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I an responding to_your_lsttst.o.f J61y 27, 1974, in which you asked for
information concerning.the ci cQ:stinces surrounding the exposure of
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workers to radiation at the.C5p.~ol_idated Edison Company of New York's
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Indian Point.l_and Rodhsster Gas and Electric Company's R. E. Ginna
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nuelsar facilities.
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As noted ;in.Mb_. Bende: r's. Sep: erber ;3,.1974 letter to you, we deternined
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that the last paragraph of your lhtter represented a request for action
pursaant to the provisions of 10.CFR J2.206 of the Connission's Rules of
Practice.
To provide _c6rrent inf_cr:ation, a special inspection of the
pet svunel muditot ing procclures. 5hd uf the circunstuucas au:counding the
several exposures at Indian Point 1,.was conducted on August 20 through
22, 19.7.4;.a copy of.the_ report.of this._ inspection is enclosed.
Addition-
ally..we_ reviewed the enforcement action which cas taken with respect to
the sev.sral exposures referenced.ih.yos: letter.
Enforcement action in
the form of a no.tice of violation.dited_ April 23, 1974, was taken for
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those Exposur.es whiEh. were reported by the licensee on Nove=ber 23 and
December 13 snd 18, 1973, and Fsbruary 14, 1974.
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No spec 1ric.entorcement actitn was thken with respect to the exposures
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which were reported on Septenbsr ll, Jdne.18, May 17 and April 16, 1973,
and Novs=ber 22, 1972'.
In its report of these overexposures, the
licensee. described tha violations,. ;he cause of the violations, and the
corrective actions to be t2r.en. _Under our procedures then in effect,
a notida 6f violation was not issued sinca the violations were already
a catter of public record :s was the licensee's description of the cause
and the dorrective actions to be taken. .In its letter of May 16, 1974,
in reply to our notice of eiolation dated April 23, 1974, the licensee
described its corrective attions.
The inspection of August 20-22, 1974,
verified that these actions had been implemented, and there had been no
recurrence of such exposures.
Civil penalties have been used when re-
has not initiated
petitive violations occur and in our opinion nanagenent
proper corrective action.
Ecwever, based on the foregoing, that is cor-
rective. action.ha.s been cade,. we do not intend to institute additional
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enforcecent action in the f:r: of a civil penalty as requested in your
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Mr. Ralph Nader
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Accordingly, for the rensens set forth above, no have detornined, in
accordance vith 10 m $2.206, that no proceedin;; vill be inntituted pur-
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au:mt to 10 Cia 32.202 vith reapect to your request. Should additiewt1
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err.osurec occur, enforcr_=cnt action in accordenco vith tha cnclosed
" Criteria for Daterminirst l'uforcanant Actica" vill bo taken.
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Uith respact to ycur specific qucatiens, it cpwar:r that ycu nro 1.-ost
concernad with the systeza for centro 111n: the a posures of vorhers,
dif ferenens botucen direct readinr, docit.ctor and fib bcdce rendiru;s,
standardization of radiction control pro;ra n, and the atailnbility of
guidance to licenseca in the aren of radiation egocuro control.
I will
DPcah to each of thesa arean in the folleuing paragraphs.
Sinca differences betreen direct reading decir.cter cud film badgdnta
cro c phenized in your letter, it is firnt necessary to provido perspec-
tive on hcw the usa of direct rendim; decircenra fits into en overall
radiation control proi;rset.
a part of an effectivo radiation control pro 3ran.The use of direct reading dositaters
Porconnel exposure
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centrol bcr.ina vith 4 cc mit mat by a licensco's cann;;ccent to e:urt ita
best effort to raintain radiation dones at a low lovel.
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The rahvsnt
requirc:cuto c.nd ruidaace to liccuscea cro contained in AEC ne;ulatione,
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AEC Cuidas, eccepted industry str.ndards and guides, and additional apc-
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cific requirceents i pe ed by technic:1 Opecifientiens nd licen:cs.
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Vithin this fren s ori, e v ioyen exposure controla are defined, vritten,
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approvad and inploncated by the licensees utilizing qualified personnel
cylcying proper end appropriately calibrated canipcent.
?craennel
expooure control for n typical radiation-related task at a nuclear
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facility includas n _ny other professienal and technical considerstic: s
such ca adainis trative controlo, training, use of vritten precedures,
'
rediatica batard evaluation, reurf" curveys, rediatica re-nitoring,
of direct rending doolmters for ccnservativu esti ates of radiationuso
egosura, 'and use of persounol ec titoring devices for a permnent record
of inte; rated exposura,
. -
The use of' direct rexiin:; docir.eters as ona tethod cf :easuring tete.1
accun21ated doao over a chort period of tire is appropricto providint
the Wf tations of these desincters are recognized, e.;;., they nust be
-
read frequently during una and inudiacaly folleving their cce; ainca
they are electrceeter=, they can be discharr.ed by leakage or impact;
-
and, they are not capable of detecting beta and Ice energy gnena radi-
ation.
Totc1 dischargo of a domincter as ocentred in the exposure rist
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Mr. Ralph Nador
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vas reported by Consolidated Edicon Co. on Novcaber 23, 1973, results in
l
a reading which only definen the 1cuer beundary of the enposura received
by the ucarer. Ecsincters are used because they permit the vorher and
,
the licensac to gain current infornation en a vorker's estinated expcsure
ca it is received; bcuever, they are used sinoat exclusively as a supple-
.
centary ncesuring device. Differences between direct readina docincter
and film badge results are not unique to Indian Point 1 and Cinna,
,
therefore, in a ocnse one could think of such differences as being
generic. Uccever, en adequcte conitorin.,, prograa vill accc:.redate the
i
differcucca betveen dosinctor and fila results and thus rui=tain radi-
aticu c cpocurca within acceptabic linits. Detailed infornation cu film
badcco, dcaincters and dcoicetry is rendily availabic. The voluno of
such info matica is cutstantial.
'
,
Vith recpect to prcgrca standardization, the AEC, initially thrcuch the
!
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Directorato of Licensing's (DL) review and later threugh the Directorato
,
of Ecgulatory Cperatices' (RO) inspections, encurcs that licenaces have
'
,
i
an ef fective radiatica control progran encocpaesing the salient centrol
featurco discusced above. Duo to naj or dif ferences in licensees'
perconnel, organizations, type, and ccopicrity of radiation-related
activitics, it is not possible that all radiation centrol progrcas be
identice.l. Eccever, the AEC-rcquired IcVel of protection for individual
j
verkere renains unifora as prescribed in our regulatica - 10 CFR Part
.
20.
Additionally, we do not esk that 1.icencces keep us inforned of their
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progresa in progrc:a develepuent but rather va review this progress during
i
our inspecticus.
l
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In regard to guidance provided by the AEC and industry in the area of
'
'
worker radiation exposura centrol, I have previded in Enclosure 3, a
list of the guidance in:cdiately available to lie-ween and the public.
1
Additicnsi requircnents nay ba included in individuni licenses and
'
associated technieni specifications. Guidance in related areas is sino
available in publientiens of tho Internaticnal ccr-1saica en Eadiological
'
Protection (ICCF) cnd Uctional Cc.mittee on 3mMation Protection cud
Hersurcnents (UC2P).
I trust that the above cmmary plus the encicoures adequataly answer
ycur questicus. Uc ccusider cur regulatory progran to be cpen for
.
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Mr. Ralph ::adcr
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ocrutiny and uc veicore specific or general ccurents, cuggestions and
.
re cot.nenda tions. Accordingly, your intercat in these ratters in
!
cppreciated.
I.
Sincerely,
i
l
Original Signett by,
Donald F. Knuth
D. 7. ~nuth
Director of Ecgulatory Operations
Enclocures:
1.
RO Inarcction Eeport
- io. 50-3/74-11
2.
Criteria for Deternining
-
.
'
i
Enforcccent Action
3.
Guides / Standards for
l
Eadiation control
Progre.:s
,
bec st/ a. dnc i s .
L.M.Munt=ing, DR
L.V.Consick, ADR
D.F.Knuth, RO
J.C.Davia, RO
E.C. Case, L
,
L. Rogers, RS
S.II.Sniley, L
J. Murray, OCC
,
II.E.Shapar, OCC
J.P.0'Reilly, RO:I
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C.Ertter, DR 7504
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Donald F.
Knuth
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Director of Inspection and Enforcement ~
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Nuclear Regulatory Commission
f
D.C.
20545
-
.
...
Dear I4r. Knuth:
This is in response to your letter of IIovember 12, 1974,
wherein you described the Nuclear Ragulatory Cetmission (NRC)
criteria for enforcement action and
radiation m.onitoring
programs.
Two important points of my July 27 letter, however,
were not addressed.
One of the questions which I had asked
was not answered.
In addition, your co= ants on rad iation
t
control prn~"an non-standardization were not convincing.
l
Ily July 27 letter pointed out that one of the corrective
actions following radiation overexposures to Consolidated
Edison workers was the establishment oc a limit of 2 rem.
After this limit is reached a worker is excluded from radiation
work for the remainder of the quarter.
The cource for my
state:nent was a letter from Consolidated Edison to the Atamic
Energy Commission (AEC), which said:
,
"Further, we have revised our administrative
control of radiation exposure by precluding any
individual whose cumulative raciation exposure is
in excess of 2000 [2 rem] from '..ori: lng in hi h
E
radiation areas."
{ Letter from William J.
Cahill,
Vice President, Consolidated Edison, to
Janes P.
O'Reilly, Director, Directorate of
Reculatory Operations, Region I,
AEC, Iiay 16, 1974)
I4r . Cahill's letter uent on to state that no new overexposures
/
had occurred since the imposition of the 2 rem limit.
,/
/
I4y July 27 letter listed four cases (out of six applicable)
in which the overexposures that occurred would not have been
prevented by this 2 rem limit, even if it had been in effect
earlier.
These four cases involved men whose dosimeter doses
were less than 2 rem, but whose film badge doses were Creater
-
than 3 rem.
These were cases B,
F, G, and H in Table 1 of
Region I Inspection Report 50-3/74-11.
~
.
The Inspection Report and clarifying conversations between
.
'
my staff and AEC personnel show that there may be extenuating
circum,tances in two of these cases.
That still leaves tuo
cases for uhich application of the 2 rem limit would have been
Jnadecunte.
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I am sure you are aware that Con Ed's proposal to
require permission for an individual to exceed 1250 mrem per
quarter does not represent sufficient corrective action.
One
has the disquieting feeling that this permission will be merely
an administrative formality, part$cularly since it is to be
l
granted before an individual reaches the 1250 mren level.
This
l
disquiet is reinforced oy the implication in Mr. Cahill's
statement that the 2 rem limit represents the real corrective
j
action.
It is further reinforced by the fact that the
dosimeter " verification" level has not been changed from 2000 mrem.
!
The inadequacy of Con Ed's 2 rem limit was perhaps the
'
major factor which prompted my July 27 letter.
Neither your
l
letter nor the Inspection Report addressed the case-by-case
i
inadequacy of this limit.
I there fore repeat the question which
!
you failed to answer:
1
l
Question:
Was the AEC aware of this case-by-case inadequacy
in the company's corrective action?
If the AEC was not aware
of the inadequacy, why was it overlooked?
If the AEC was
j
aware of the inadequacy, why did is accept the company's action?
!
l
To the suggestion that radiation control programs be
ctandardised , you enclosed a list of applicable guides and
'
standards and made this statement:
I
"Due to maj or dif ferences in licensees'
i
personnel, organisations, type and conplexity
of radiation-related activities, it is not
possible that all radiation control programs
i
be identical."
(p. 3, your letter of
November 12, 1974)
Conceivably, this might justify differences in the radiation
control programs of a power plant and a reprocessing plant, for
example.
But there seems to be no reason why different pcwer
,
plants should have different programs.
The Naval Reactors (NR)
'
program, as an example, has for years required the same
personnel radiation control program for each of its submarines.
The NP program is standardised, and has much more detailed
requirements than the list of guides you enclosed.
While the list
of guides and standards you enclosed may seem impressive to the
uninformed you must admit that they provide only general, not
detailed guidance.
The NR program directly addressed the possible problem of
film badge-dosimeter discrepancy by requiring more frequent,
film badge checks as an individual gets closer to his exposure
limit.
This program is more detailed and more comprehensive
than either the Consolidated Edison or Rochester Gas & Electric
progrm.;c mentioned in ny July 27 letter.
The Javy's prccran
'
would have prevented most or all of the Con Ed and Rochester
Liaison between Regulatory Operations and UR
in this matter would seem advisable.
msm
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At present different nuclear plants have different designs
and dif ferent technical specifications.
But since there seems
to be no geographical variation in the effects of radiation
,
on workers, vihy do different poler plants have different
i
radiation control programs?
Your July 27 letter did not adequately
explain this non-standardisation of radiation control procrats.
l
Why does llR have a stricter and standardised program that
9
addresses film badge-dosimeter differences tihile the flRC does not
{
have sucli a program?
l
Sincerely,
. / ,/
-/
/ /
A f/ -
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'Ra1ph Nader
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cc:
William A.
Anders, Chairman
Nuclear Regulatory Cornission
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UNITED STATES
fJUCLEAR REGULATORY CO.*r.!!S lOrJ
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W ASHIN G ton. D.
C.
20555
,
y,Ay 1 91975
.
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Mr. Ralph Nader
!
2000 "P" Street, N. W.
t
/th Floor
Washington, D. C.
20036
j
Dear Mr. Nader:
I
This is in response to your undated letter herein you ask that we
-
expand on our letter of November 12, 1974.
We believad that we had,
by inference, answered your three part question in our Scvcaber 12,
!
letter; hcwever, specific answers to each part of your question are:
1.
Was the AEC aware of this case-by-case inadequacy in
the ccupany's corrective action?
The AEC considered
the company's overall corrective action to be adequate
.
for the situation.
The AEC uas aware of the facts as
reported by the licensee.
!
2.
If the AEC was not aware of the inadec,uacies, why ras
.
it ever!ceked?
See 2r"cer to 1. above.
,
l
,'
3.
If the AEC was aware, why did it accept the cc=pany's
action?
The AEC believed the company's action to be
adequate for the situation.
'
It has been long known in the nuclear industry that the exposures
of film badges and pocket chanbers worn by the sane worker in
i
areas of mixed-type and energy radiation seldom are the
same.
This may be due to such factors as positioning
'
of dosimeters on the body, differing periods of exposure for
each device and exposures to changing energies and to clanging
,
types of radiation.
It is known, also, that for gan=a radiatica -
the type cost encountered for routine operation of reactor
facilities - the correlation between the film badge and the
pocket chceber is c1csest.
In fields of pure gamna radiaton,
experience shows that the correlation usually will be close or
that the pocket chamber will show the higher reading; however,
in fields of nixed radiation - beta and gamma - the differences
i t.
relation will be greater with the film badge showing the
high
ading. Mixed field radiation was the type encountered
in the
sures about which you express concern.
Although the
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ROCHESTER GAS AND ELECTRIC CORPORATION e 89-EAST AVENUE, ROCHESTER, N.Y.14649
c= ANcE R E. CRE EN
m ie=o=t
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..t. coot na 546 2700
March 25,1974
]p
,
Mr. Donald F. Knuth
Director of Regulatory Operations
U. S. Atomic Energy Commission
Washington, D. C. 20545
Subj ect:
Radiation Exposure
R. E. Ginna Nuclear Power Plant, Unit No.1
Docket No. 50-244
Dear Mr. Knuth:
This letter is being submitted pursuant to 10 CFR 20.405 to report the
exposure of forty (40) individuals to radiation doses in excess of 3 Rem
in one quarter. Previous reports concerning four of these individuals
who received greater than 5 Rem in one quarter have been sent to Mr. James
P. O'Reilly, Director of Region I Regulatory Office. All individuals have
been notified as required by 10 CFR 20.409b. The exposures received were
as follows:
29 men - 3000 to 4000 mrem
7 men - 4000 to 5000 mrem
3 men - 5000 to 6000 mrem
1 man - 6100 mrem
All men were employed by Nuclear Installation Services Company (NISCO),
a contractor hired to repair leaks in the spent fuel pit liner. The work had
been in progress since November 1973 and involved cleaning, grinding,
welding and dye checking the liner and liner welds. The dose rate in the
work areas varied from a few mR/hr. at the top of the spent fuel pit to 4 R/hr
on contact with the spent fuel pit wall in some locations. Radiation surveys
of the entire area were made regularly, survey maps posted and all who worked
in the spent fuel pit were informed concerning the high radiation areas. The
high radiation areas were shielded by using lead sheets to reduce the doses
received by the workmen. Wnen not actively working, the men were instruc-
-
ted to enter a lead shielded bucket or to leave the radiation area.
The fellowing procedures were established and carried out to instruct the
men involved in this work and to monitor, record and control their radiation
exposure:
1.
All personnel who worked on the spent fuel pit job were given a one-
hour lecture in Health Physics practices, procedures and hazards.
This lecture included the use of radiation monitoring equipment, pro-
tective clothing and breathing protection, the effects of contamination
. _
r} 1 9 ' x i.e . w _,
CHE5 rER G A5 Ar<:, ELEC rRIC CCRP.
SHEETNO.
2.
- E > , March 25,1974(
/
-
.
,
70
Mr. ' Donald F. Y,nuth
'
'
.
or radiation and radiation dose limits. AEC Form 4's were obtained
so that the allowable radiation dose could be calculated for each
individual.
2
Rochester Gas and Electric Corporation (RG&E) staff personnel were
assigned to zero the dosimeters and to read and record the exposures
of the workmen. *
,
3.
Daily dosimeter records showing the accumulated radiation dose for
each individual were maintained.
4.
A procedure was established that a man would be restricted from entry
into controlled areas when his accumulated radiation dose measured
by dosimeter exceeded 1920 mrem. The 1920 mrem value multiplied
by a factor of 1.3 results in an adjusted level of 2500 mrem, which
is 500 mrem below the quarterly dose limit of 3000 mrem. The 1. 3
factor is applied as a conservation correlation ratio between dosi-
meter and film badge readings; the 500 mrem value is used to allow
for statistical variations between dosimeter and film badge readings.
5.
Daily cumulative dosimeter radiation exposure dose lists, adjust'ed by
the 1.3 factor, were prepared before each shift reported to work and
provided the contractor supervisors in order to restrict these men
recording over 2500 mrem.
An investigation was conducted by RG&E to determine why these men
received radiation exposures exceeding.3 Rem and the findings were as
follows:
1.
The total adjusted cumulative radiation exposure doses from dosimeter
readings for 38 of the 40 men were all under 3000 mrem. The other two
men received 3133 mrem and 3245 mrem adjusted dosimeter readings
(actual readings were 2410 and 2495 mrem respectively). These men
had been permitted to work in the spent fuel pit for some period of time
after their adjusted accumulated radiation dose records indicated that
they had exceeded the established 2500 mrem limit.
2
With three exceptions, all of the 40 men with film badge dose levels
greater than 3000 mrem worked only during the last three weeks of the
job (January 15 to February 5,1974). The other 137 NISGo 3mployees
working on the spent fuel pit during November, December anc January
received less than 3 Rem level.
3.
During November and December 1973, the work was conducted on a
one-shift basis and a check station was set up in a room adjacent to
the spent fuel room and RG&E employees checked the dosimeters as
the men left the working area. During January 1974, because of a
decision to refuel earlier than expected, it became necessary to com-
plete as soon as possible the repairs to the spent fuel pit. The work
schedule was increased to two-shifts, including weekends with con-
siderable overtime. It is significant that in Januar/ a separate check
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SHEET NO.
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March 25,1974
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To
Mr. Donald F. Knuth
.
station for issuing and reading dosimeters for this particular job was
set up in the Health Physics spaces which provided monitoring control
but not the degree of visual surveillance and direct control of the work-
men as the men entered and departed the spent fuel pit room entrance.
4.
No other changes were made in the radiation monitoring procedures,
the dosimeter and film badge equipment, the etntractor employed to
read film badges and other factors that could have resulted in unantici-
pated discrepancies between film badge and dosimeter readings during
the Novembe: 1973 - January 1974 period.
Since commencing operations in November 1969, only three Rochester Gas
and Electric employees have received greater than 3 Rem per quarter and
were reported as follows:
August 19,1970 - 4.20 Rem
July 21,1971
- 3. 09 Rem
June 2 6,1972
- 3. 31 Rem
Because of these exposures, procedures were established to more closely
monitor the cumulative dosimeter readings and apply the 1.3 adjustment
factor and 500 mrem statistical variation factor to ensure that the dosimeter
readings were con ervative and the film badge readings would not exceed
the allowable dose limits. In addition, one subcontractor emplovee was
reported on May 31, 1972 to have had a potential exposure to higher than
permissible dose level due to a face mask not functioning properly. Of the
approximately 600 other RG&E and subcontractor personnel employed at
Ginna Station during January 1974, there were no significant differences
between cumulative adjusted dosimeter and film badge readings. No
personnel, except the 40 NISCO personnel working in the spent fuel pit,
received greater than 3 Rem / quarter, although other repairs were in progress
' The conclusion reached from the investigation is that by not exercising direct
and frequent visual supervision of contractor personnel working in high radi-
ation areas, opportunities were allowed to exist where a workman could
maintain his dosimeter readings lower than the dose levels recorded by his
film badges, and thereby, be permitted to remain on the job for a longer
period of time.
Corrective action has been taken to prevent recurrence by a policy of closely
supervising contractor personnel with RG&E staff employees whenever work
is in progress in high radiation areas.
>
Additional steps have been taken to reduce and control the radiation exposure
levels of all personnel at Ginna Station. A letter to all on-site personnel
reiterating the rules for wearing film badges and dosimeters has been sent
to all Ginna Station Foremen. A revised outline of material to be covered
.
58
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March 25,1974 ~
5HEET NO.
4.
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Mr. Donald F. Knuth
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in Health Physics training has been prepared to ensure that all items required
by 10 CFR 19 are included and to stress the importance of the proper use of
radiation dose measuring devices, the radiation dose records and the individ-
ual's respcnsibility to report any unsafe conditions or violations of procedures.
Very%1y yours,
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rang
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Mr. James P. O'Reilly
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U. S. ATOMIC ENERGY COMMISSION
DIRECTORATE OF REGULATORY OPERATIONS
REGION I
RO Investigation Report No.
50-244/74-01
Docket No.:
50-244
Licensee:
Rochester Gas & Electric Company
License No.: DPR-18
89 East Avenue
Priority:
Rochester, New York 14649
Category:
C
Location:
Ginna Station, Ontario, New York
Type of Licensee: PWR,1520 WT (W)
Type of Investigation: Type B Exposures and Associated Overexposures
Dates of Investigation: Feb. 20, 21, 22, 28, Mar. 1, Apr. 16, 17 8 18, 1974
Repcrting Investigator:
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Accompanying Investigators:
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ai Raciation Specialist
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K. /SnitT, "Investigaf tor
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P.J.Knapp,SeniogttciationSpecialist/ IyATE
Other Accompanying Personnel:
None
DATE
37!
leviewed by:
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EnvironmentalProtection}flogicaland
F.J.
Knapp, Senior, Rad 1
Branch
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REASON FOR INVESTIGATION
The investigation was conducted as a result of a telephone notification
to the Directorate of Regulatory Operations, Fegion 1, on February 15,
1974, from C. Platt, Plant Superintendent, Ginna Station, Rochester
Gas and Electric Company, of 35 overexposures to contractor personnel
employed on the spent fuel pit leak repair job during the fiest quarter
1974.
SUMMARY OF FACTS
The first indication to the licensee that overexposures had occurred
resulted from a telephone co=nunication from their Jilm processor on
February 15, 1974.
The processor reported exposures of over 5,000
millirem for four individuals and over 3,000 milliress for 31 individuals,
the maximum being 6,100 millirems.
A subsequent cc==unication from the
film processor on February 22, 1974 reported thac one additional indiv-
idual had received an exposure in excess of 5,000 millirem and four
additional individuals in excess of 3,000 millirem, the =axi=um being
5,580 millires. A previously reported exposure of 5470 was corrected
to 3110 at this time.
All exposures were subsequently verified and
reported by the film processor in their for=al report to the licensee.
All overexposures occurred during the January 1974 fil= badge period.
A review of the circumstances of the exposures showed that all of the
e.< posed individuals had been employed by a techanical coneneting firm
under contract to Rochester Gas and Electric Company (RG&E) to repair
leaks in the spent fuel storage pit at the Ginna Station.
All of the
contractor e=ployees were hired through local union hiring halls.
Tenure on the job was dependent upon an individual's accumulated
exposure up to a centrol limit of 2500 millirem based on pocket dosi-
ceter results.
A review of the contract between the contractor and RG&E sh sed that
the contractor was to provide qualified craf t labor, procedures for
repairs and nondestructive testing (NDT) and supervise craf t activities.
RG&E was to prepare the spent fuel pit for repairs, provide anti-con-
tamination clothing and dosimeters, remove fuel racks and provide
technical direction on NDT.
Specific provisions for health physics
services were not identified, however, RG&E did previde these services.
A total of 176 individuals were involved in the repair work commencing
on December 4, 1973 and concluding on February 4, 1974.
The work
involved dye penetrant testing, grinding and welding.
Radiation dose
rates ranged from 5 to 1500 millirem per hour in the work location.
Self reader pocket dosimeters ana administrative control limits were
used for exposure control. All dosimeter readings were multiplied by
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a factor that the licensee has routinely used in their exposure control
program to approximate film badge results. Film badge results ranged
from expected values to as much as three times greater than pocket
dosimeter results. The same exp,osure control methods were used during
the December film badge period with no resultant overexposures.
The licensee's consultant reviewed the film badge results with the
film processor and found no apparent film da= age , no change in methods
of processing and no deviation from the nor= ally used methods of inter-
pretation.
Certain rumors were circulating among the workers af ter the
incident, that the craf ts=en had devised a method to bypass their pocket
dosimeters. These rumors re=ain unconfirmed.
The licensee provided information on the event to the Rochester, New
York news on February 20, 1974.
The investigation, which included contacts and interviews with licensee
personnel, contractor management, and contractor craftsmen, showed that
the overexposures resulted from a ec=bination of causes as follows:
(1) The unexplained failure of the factor (1.3) applied to the
pocket dosimeters for purposes of estimating film badge
results to accurately predict them.
(2) Deficiencies in the licensee's exposure control and general
surveillance program.
There is also the possibility that contractor employees devised methods
to extend their work time by shielding or not wearing their pocket
dosimeters but this could not be proven.
Corrective actions that the licensee will take to prevent recurrence were
defined as follows:
Provide closer supervision in the area of exposure control
a.
during jobs having high exposure potential.
b.
Review the need for increasing staff size to provide more
availability of health physics services. (currently in progress)
c.
Reduction of administrative exposure control li=it from
2500 to 2200 millirem.
d.
Review and strengthen the orientation and training program
which will include documentation of the orientation outline,
consideration of a quiz to be given to trainees following
orientation, and a more for=alized system for maintaining
records.
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The Plant Operations Review Committee (PORC) will review
the findings of the licensee's investigation and make
recommendations based on those findings.
The violations of AEC require =ents noted during the inspection were
as follows:
a.
Failure to maintain individual whole body doses within the
limits specified in 10 CFR 20.101(b)(1) .
The excessive
doses were reported by the licensee in accordance with
10 CFR 20.403(b)(1) and 20.405(a)(1) .
b.
Failure to make adequate surveys (evaluations) to assure
that individual whole body doses did not exceed 3 Rem as
specified in 10 CFR 20.101(b)(1) .
(Contributed to cause)
(Details, Paragraph 2e & f, Sc, d, e, f & g)
c.
Failure to limit an individual's exposure within the limits
of 10 CFR 20.101(a), when no Form AEC-4 had been obtained
(Details , Paragraphs 4a-b)
d.
Failure to provide instructions to workers in accordance
with the requirements specified in 10 CFR 19.12.
(Contributed
to cause)
(Details , Paragraph 6a-c)
Failure to comply with Technical Specifications 6.4.2. (d) (4)
e.
which requires an evaluation of effectiveness of the res-
piratory protection program.
(Did not contribute to cause)
(Details, Paragraph Sc)
f.
Violation of Technical Specification 6.4.1 which requires that
the' Plant be operated and naintained in accordance with
approved procedures.
Radiation Control Procedures as required
by Technical Specification 6.4.2 are contained in Administrative
Order A-1.
Failure to comply with these procedures were as
follows:
-
(1) Radiation monitoring devices were not issued in accordance
with Section VI.A.4.
(Contributed to cause)
(Details,
Paragraph Sg)
(2) Training records were not maintained in accordance with
Section II.
(Did not contribute to cause)
(Details,
Paragraph 6b)
(3) Certain individuals failed to sign Special Work Permits
as required by Section VI.B ll.
(Did not contribute to
cause)
(Details, Paragraph 7b)
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(4) Radiation Work Permit No. 21 did not contain certain infor-
nation as required by Section VI.B.4.
(Did not contribute
to cause)
(Details, Paragraph 7c, Item 1, 2, 3 & 4)
(5) Continuous supervision of personnel wearing respiratory
protective equipment was not provided in accordance with
Section VI.E.2.
(Did not contribute to cause)
(Details,
Paragraph 8d)
Persons Interviewed
C. Platt, Plant Superintendent, Ginna Station
L. Lang, Assistant Plant Superintendent, Ginna Station
W. Sandeford, Staff Coordinator, Electric & Steam Departnant (RG&E)
E. DeMerritt, Supervisor, Health Physics & Chemistry, Ginna Station
B. Quinn, Health Physicist, Ginca Station
J. Witte, Cadet Engin?.er, Ginna Station
R. Burt, Health Physics Technician, Ginna Statien
B. Goodman, Health Physics Technician, Ginna Station
Mechanical Contractor Management
Mechanical Contractor Crafts =en
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DETAILS
1.
Introduction
a.
On February 15, 1974, C. Platt, Plant Superintendent, Ginna
Station, notified the Directorate of Regulatory Operations,
Region I, by telephone, that thirty-five contractor personnel
had received radiation exposures in excess of 3000 millires.
Of these thirty-five individuals , four had received exposures
in excess of 5000 millirem.
Mr. Platt stated that the expos-
ures had been reported to him, by telephone, by their film
processor and was a preliminary report.
This was subsequently
verified by official report from the film processor.
Sub-
sequent to the above date, on February 22, 1974, the film
processor reported five additional exposures over 3000 milli-
rem, one being in excess of 5000 millirem.
They further
corrected a previously reported exposure of greater than
5000 millirem, to 3110 millirem.
It was reported as a key
punch error.
This was subsequently verified by the film
processor.
b.
Mr. Platt stated that all individuals were employed by a
contractor involved in leak repair of the spent fuel pit.
According to Mr. Platt, the work had been in progress since
early December,1973, with ccepletion being acccmplished
about February 4, 1974.
Mr. Platt stated that work accom-
plished during December had not resulted in any exposures in
excess of 3000 millirem.
It was reported that all the
excessive exposures were accu =ulated during January 1974
during work of the same nature and at the same work location.
Mr. Platt stated that their preliminary review of the over-
c.
exposures showed that the film badge results, as compared to
the pocket dosimeter results, were significantly higher than
what had been their normal experience. According to Platt,
they had multiplied the pocket dosi=eter readings, used for
day to day exposure control, by a factor cf 1.3 in order to
allow for the expected exposure that would normally be seen
by film badges.
d.
Mr. Platt stated that they had not released information about
the overexposures to the news media; however, it was under
consideration pending official notification of the exposures
from the film processor. A news release was made on
February 20, 1974.
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The licensee reported these exposures in excess of 5,000
e.
millirem as required by 10 CFR 20.403(b)(1) .
Mr. Platt
stated that a 30 day report as required by 10 CFR 20.405
would be submitted.
These overeaposures and other over-
exposures, as made known to the licensee on February 22,
1974, were subsequently reported.
The overexposures resulted free unexplained, lower than
normally expected, pocket dosimeter readings as compared
to film badge results and the licensee 's failure to adequately
supervise and evaluate exposure accumulations.
An investigation into the cause of the overexposures was
conducted by Regulatory Operations, Region I, on February 20,
21, 22, 28, March 1, and April 16, 17 & 18, 1974.
The in-
vestigation included Laterviews with licensee personnel and
contractor personnel regarding the circumstances of the
2.
Licensee's Su==arv of overeroosures
a.
Mr. Platt and other ce=bers of his staff described the
work during which the overexposures occurred and the con-
tractual agree =ents with the contractor performing the
work. As described, the work involved repair of leaks
in the spent fuel pit done under a contract with a mechanical
contracting firm.
b.
The investigator's review of the contract showed that con-
tract responsibilities were defined as follows:
Mechanical Contractor
(1) Provide qualified craft labor for repair work.
(2) Provide procedures for repair and nondestructive
testing (NDT) .
(3) Supervise craft labor.
Rochester Cas & Electric Company (RG&E)
(1) Empty fuel pit
(2) Dispose of radwaste
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(3) Provide anti-contamination clothing and dosimeters
(4) Re=ove fuel racks
(5) Provide technical direction on NDT.
c.
The licensee stated that the contractor was a mechanical
contracting firm with a limited number of permanent employees ,
providing craft labor, through local union halls, en an as-
needed basis.
The contractor began the leak repair work on
December 4,1973 and completed it on February 4,1974
According to the licensee,a Ginna Station Cadet Engineer,
was assigned as Project Engineer, responsible for a record
'
of the work and liaison between licensee and contractor.
Responsibility for health physics services was vested with
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the Ginna Station.
Initially, work was done on a five day
a week, ten hour day work schedule, continuing until
January 7, 1974. On that date the work schedule was changed
to two twelve hour shifts, seven days a week.
d.
According to the licensee, craf t labor tenure on the job was
dependent upon an individual's available exposure up to a
limit of 2500 millirem, the Ginna Station administrative
limit that was employed to maintain personnel exposures within
the AEC li=it of 3,000 millirem.
In a few cases the admin-
istrative limit was raised to 2800 millirem to provide ex-
tended availability of key personnel. Exposure control was
acccuplished by utilizing, on a daily basis, the results of
self reader pocket dosimeters. Actual dosimeter results were
multiplied by a factor of 1.3 and that result used for ex-
posure accumulation centrol.
This factor was to account for
the normally experienced difference between pocket dosi=eter
results and film badge results and is routinely used at
Ginna Station for exposure control and predicting film badge
results.
Reportedly exposure histories (AEC Form 4) were
on record for all individuals.
Administration and control of exposure was acco=plished in two
e.
phases.
Health physics would review and record accu =ulating
exposures on a daily basis and provide those results to the
contractor supervisor and/or the craft foreman.
Exposure
control was then left to the above personnel and the individual
craftsman. An exposure limit of 300 to 400 millirem as deter-
mined by pocket dosimeter (2 worn) was imposed on each individual
for eacii entry into the work area.
No daily limit, other than
the 2500 millires was i= posed.
Multiple entries could be, and
were, made during any one work day.
Timekeeping was not employed
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for purposes of exposure control.
Exposure control was
mainly lef t to the individual and was dependent on the
individual's initiative to read his pocket dosimeters at
frequent intervals.
Radiation dose rates in the work area
were as high as 1500 millirem per hour. Certain work functions
were performed from a lead shielded bucket and from behind
portable lead shields in the high dose rate areas,
f.
According to the licensee work was accomplished during
December with no resulting overexposures.
The overexposures
occurred during January under the same exposure control methods
employed as were used in December.
According to the licensee,
the overexposed individuals had film badge results that were
higher than the pocket dosimeter results by more than the
1.3 factor that had been applied for purposes of predicting
film badge results.
The reason for those variances were not
known.
Certain possible causes, such as the possibility of
the pocket dosimeters being shielded while persons were
working in the lead covered bucket and the possibility of
dosimeters being lef t outside the work area were explored by
the licensee. The second possibility was reviewed because
of a subseauent rumor that some individuals had devised a
method to bypass their dosimeters. According to the licensee,
neither possibility had been confir=ed.
In addition, the
licensee reported that two contractor employees had been
fired secause of suspected discrepancies in recorded pocket
dosi=eter results.
The licensee stated that the circumstances
had not been reviewed by Ginna.
Expogures for the two
individuals were less than 3,000 m1111 rem.
The licensee
stated that af ter this occurrence the responsibility for
reading and recording pocket desi=eter results was assigned
to Ginna health physics personnel.
To that point in time
each individual was responsible for reading and recording
his exposure data.
g.
According to the licensee a total of 176 individuals were
involved in the repair work.
Each individual had attended
a radiation orientation and training program provided by the
licensee.
On February 22, 1974 the licensee reported that
all film badge results had been communicated to them by the
film processor.
These results showed that four individuals
had received exposures in excess of 5,000 m illirem and thirty-
six in excess of 3,000 millirem, the maximum being 6100 millires.
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Investigators' Review And Findings
3.
Personnel Excosures
The investigators reviewed the licensee's records of exposure
a.
for individuals employed by the contractor for the period from
December 1, 1973 through February 4, 1974.
This period covers
the time in which all leak repair work was accomplished.
Records reviewed included pocket dosimeter records, film badge
reports and Forms AEC-4 (Exposure Histories).
b.
The review showed that exposures during December 1973 (4th
quarter) were maintained within the limits defined in 10 CFR
,
Part 20.101(b)(1), the maximum being 2050 millirem.
Exposures
for January 1974 (1st quarter) are summnrized below.
EXPOSURE IN MILLIREM
0-1000
1000-2000
2000-3000
3000-4000
4000-50C:
5000-6000
6000-6100
14
42
80
29
7
3
1
4.
Form AEC-4 & 10 CFR 20.101(a) Limits
_
a.
The investigators determined, from discussions wi-b the
licensee and contractor management, that exposure use plans
included a general approech that all contractor employees
would be utili:cd on the job until their exposures reached
a nn v4 -u
of 2500 millirem as determined by self reader pocket
dosimeters multiplied by 1.3.
The 2500 millirem limit was
subsequently (January ) changed to 2800 millirem. According
to the licensee, Form AEC-4 records were =aintained for each
individual as required by 10 CFR, Part 20.102(b)(1) prior to
permitting any individual to receive exposure in accordance
with 10 CFR 20.101(b)(1) .
b.
A review of the Form AEC-4 records showed that this certificate
of exposure history had been obtained for all individuals
receiving exposure in excess of 1.25 rems, the limit specified
in 20.101(a), with one exception.
The records (film badge
processor's report) showed that this individual had received
a radiation exposure oi 1.84 rems during the first quarter
1974.
This was in excess of the limit specified in 20.101(a)
and no Form AEC-4 nad been obtained for this individual.
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c.
A review of other pertinent records showed that the licensee
maintains a card file on all individuals that enter the
facility under film badge procedures.
The licensee stated
that during their investigation of the overexposures they
had reviewed their card file against the Forms AEC-4 and found
that four of the individuals employed during the lead repair
had failed to indicate previous exposure.
In the four cases,
all had been into the Ginna Station on previous occasions
and had received exposures.
The exposures were low, the
maximum being 230 millirem, accumulated in 1971, and did
not affect the 1973-74 exposures.
The licensee stated that
they normally depend on the integrity of the individual to
provide them with an accurate exposure history. According
to the licensee, exposure history is documented as part of
their orientation program, during which these requirements
i
are discussed.
5.
Exposure Control Methods
a.
The investigators reviewed with the licensee and contractor
management, the methods used for exposure control.
It was
determined that an administrative exposure limit of 2500
millirem was established as the maximum allowed for contractor
personnel.
This was subsequently raised to 2800 millirem for
those individuals having a certain expertise and according to
the licensee was handled on a case by case basis, as it was
requested by the contractor.
According to contractor manage-
ment, this was the case until sometime in January (deter =ined
later to be January 20) when they received a blanke: approval.
for 2800 millirem.
Both limits are provided for by the
licensee 's Radiation Control Manual, anong other ad=inistrative
limits. Approvals to exceed established administrative limits
are verbal and do not require documentation.
b.
It was determined that for purposes of not exceeding the AEC
limits (3,000 millirem per quarter), exposure was controlled
by the use of self reader pocket dosimeters. The results of
these pocket desi=eters were multiplied by a factor of 1.3
and recorded on a daily accumulating basis. The 1.3 factor,
developed over the years at Ginna Station, accounts for the
normally experienced difference between pocket dosi=eter
results and film badge results.
A review of pocket dosimeter
log sheets and the daily su= mary sheets showed that actual pocket
dosimeter results were corrected by the 1.3 factor when trans-
scribed to the daily suc=ary sheet.
The su==ary sheet was pro-
vided to contractor supervision for use at the work site.
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According to the licensee, exposure control, employing the
c.
accu =ulated exposures on the daily su=mry sheet, was the
responsibility of contractor supervision.
This was confirmed
,
by contractor supervisors; however, in actual practice control
was mainly lef t to the individual.
According to contractor
supervisors, individuals were limited to an exposure of 300
to 400 millires for each entry to the work location.
This
limit was then administered by the individual, based on his
attention to reading his pocket dosimeters.
Contractor
supervisors stated that allowed exposures for each entry were
not predetermined with consideration to the 1.3 factor.
According to the licensee, pocket dosimeter results were only
reviewed on a daily basis, even though individuals would
routinely =ake more then ene entry into the work location.
In one such case an individual made three entries, accumulating
2330 millirem, as determined by his pocket dosimeters.
d.
The investigators determined, from a review of pocket dosimeter
results, that of the forty individuals receiving exposure in
excess of 3,000 millirem, nine had pocket dosimeter results
in excess of the 2800 millirem administrative limit, but
less than 3,000 with the exception of one which was 3133 millirem
corrected by the 1.3 factor.
In the case of the maximum, that
individual was, according to the licensee, working under an
administrative Itait of 2500 millirem.
10 CFR, Part 20.201(b) requires, in part, that the licensee
e.
cake such surveys (evaluations) as may be necessary to maintain
individual exposures within the limits specified in Part 20.
101(b) (1) .
In general the licensee failed to adequately
evaluate pocket dosimeter results in keeping with established
plant procedures.
Specifically, in the case of one individual,
.
the licensee failed to properly evaluate his exposure, such
that his exposure for the first quarter 1974, totaled 3310
millirem as determined by the individual's film badge.
In
this case, pocket dosimeter results showed that on January 24,
1974, the individual had received an accumulated exposure of
2639 millirem (corrected) which was in excess of the admin-
istrative limit of 2500 millirem established for that individual.
The records further showed that on January 25, 1974, the
individual received additional exposure totaling 380 millirem
(uncorrected) as determined from pocket dosimeters.
To tal
exposure as determined from corrected pocket dosimeters results
was 3133 for the period.
This was 633 millirem over the
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administrative limit established for purposes of maintaining
the individual's quarterly exposure to 3,000 millirem, or less,
as specified in 10 CFR, Part 20.101(b)(1) .
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Other methods of exposure control as determined from dis-
cussions with licensee representatives, contractor personnel
and from a records review, included; routine surveys by
health physics, observations by health physics, posted
radiation survey results and the use of lead shields.
Radiation surveys showed that radiation dose rates ranged
up to 1500 millirem per hour.
During discussions with con-
tractor personnel it was determined that they were aware of
the posted surveys; however, in general they did not review
them for the various dose rates. They indicated that they
were instructed to avoid certain areas because they were hot.
The licensee stated that ti=eheeping was not e= ployed to
control exposure,
g.
As evidenced by radiation surveys the work location was
determined to be a "high radiation area" as defined by
10 CFR, Part 20.202(b)(3) and the licensee's procedures.
Section VI. A.4. of Administrative Order A-1 Revision 2,
approved July 26, 1972 requires that, "any individual or group
of individuals permitted to enter such areas shall be provided
with a radiation monitoring device which continuously indicates
the radiation dose rate in the area".
According to the
-
licensee no such device was prcvided to personnel in the
work location.
Padiatica control procedures must be effected
and followed as required by Technical Specification 6.4.1
and 6.4.2.
6.
Training
With respect to training, the licensee stated that all con-
a.
tractor personnel were considered visitors or te=porary
e=ploycea and received training as described in Administrative
Order A-1, referenced in paragraph 3g above. The investigators
reviewed the training requirements set forth in Section II.D
of the referenced document.
This section requires that these
persons, unless escorted by trained personnel, and according
to the licensee, they were not under escort, be given a
lecture in which the following material is covered:
(1) Shielding and radiation protection
(2) Use of protective clothing and respirators
(3) The Radiation Protection Manual
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According to che licensee the lecture was presented to all
contractor personnel on the first day of entry to the facility.
The lecture included demonstrations in methods to don and remove
,
anti-contamination clothing, use of personal survey instruments
and other things peculiar to radiation zone work.
This was
confir=ed, in general, during discussions with contractor
personnel. With respect to records of training the licensee
provided a written acknowledgement that all contractor
personnel had received the referenced training. The acknow-
ledgement was signed by'a licensee representative and a con-
tractor representative.
Tne document was dated February 12,
1974, a date subsequent to coupletion of contractor work.
A licensee representative stated that the contractor repre-
sentative had presumably checked employee time sheets to
confirm that all individuals had received the training.
Subsequent discussions with the contractor representatives
showed that he had not reviewed time sheets, but rather, had
assumed that all personnel had received the training.
Section
II of the Administrative Order referenced in paragraph Sg above,
requires that, "a record shall be kept of all individuals
trained".
The referenced acknowledgement and the mechanism
by which it was generated does not fulfill the intent of the
licensee's procedure.
It was noted that on January 27, 1974,
near the end of the contractor work, the licensee initiated
a system whereby each individual, af ter receipt of training,
acknowledged same by signature.
Investigation findings showed that training lectures were
c.
presented by members of the health physics staff.
It was
determined that there was no for=al outline identifying specific
areas that had to be covered during the lecture.
During dis-
cussions with individuals, who in this case had presented
lectures, it was found that each individual presented =aterial
that appeared important to them, and not always consistent
with the requirements of the licensee 's procedure , Adminis-
trative Order A-1.
With respect to 10 CFR, Part 19.12,
" Instructions to workers" it was found that the same incon-
sistencies in presentations resulted in a failure to instruct
individuals in all of the areas specified in Part 19.12.
It
was also determined that not all of the instructors had a
working knowledge to properly instruct individuals pursuant
to the requirements of Part 19.12.
In summary, the licensee
failed to instruct all individuals in keeping with requirements
of 10 CFR, Part 19.12, as follows:
(1) Instructions in purposes and functions of respiratory pro-
tective devices in use during the work.
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Specific to this requirement, one instructor failed to
instruct individuals with respect to the use of the full
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face, canister type respirator.
(2) Instructions of responsibility to report promptly to the
licensee any condition which may lead to or cause a vio-
lation of Cc= mission regulations and licenses or unnecessary
exposure to radiation or to radioactive caterials.
Specific to this requirement two instructors failed to
inform individucla of these responsibilities.
(3) Instructions as to radiation exposure reports which
workers may request pursuant to 10 CFR, Part 19.13(c) .
Specific to this requirement one instructor incorrectly
instructed individuals as to the ti=e in which reports
of exposure to radiation would be made available upon
request.
7.
Soecial Work Permits (SWP) and Radiation Work Procedures (RWP)
a.
Investigation findings showed that the contractor work was
performed under authorization of SWP and RWP as required by
Administrative Order A~-1.
A review of these authorizations
showed that the work was initiated under an SWP authorization and
continued under SWP until December 26, 1973.
It was noted that
the SWP was issued on a daily basis as required by procedure.
On December 26, 1973, RWP Number 21 was issued and employed
through work completion.
The RWP is an extended authorization,
valid for up to one year, and is normally used for routine
work. According to the licensee, they felt that as the work
progressed it became a routine job.
b.
With respect to SWP authorizations,Section VI B.ll of Admin-
istrative Order A-1 requires that each individur '. working under
that SWP "shall read and understand its provisions before
entering the radiation zone".
This is certified by the individual's
signature.
A review of SWP authorizations showed that one indi-
vidual entering the work location under SWP Number 527, dated
December 8, 1973, failed to sign the SWP.
This was verified by
the daily pocket dosimeter records that showed an entry to the
work location on that date.
It was also determined that two
individuals entering the work location under SWP Number 528,
dated December 10, 1973, failed to sign the SWP.
Verification
was determined as noted in the previous case.
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Comnencing on December 26, 1973, contractor work was continued
under RWP Number 21.
Section VI B.4, Administrative Order
A-1 requires that each RWP shall contain certain infor=ation.
A review of RWP Number 21 against the requirements of A-1
showed that information, as no ted below, was not included.
(1) The name of groups whose personnel are authorized to
work under its provisions.
(2) The time period for which it is valid.
(3) A detailed description of the work covered.
.
.
(4) A description of the radiation hazards which =ay be
encountered.
8.
Respiratory Protection Program
a.
The investigators determined from discussions with licensee
personnel, contractor personnel, and a review of records,
that respiratory protection equipment was worn for purposes
of controlling exposures to airborne radioactivity. It was
noted that supplied air masks and canister equipped full face
and half face masks were employed, depending upon the work
being performed and the potential for airborne radioactivity.
Air concentrations were monitored on a continuous basis,
e= ploying a continuous air monitor, and on a spot type bas!s,
employing a high volume air sampler with subsequent sample
analysis.
Reportedly, spot samples were taken frequently
during welding and grinding operations , the work having
the greatest potential for generating airborne activity.
It was also determined (PORC Minutes, dated December 17, 1973)
that air flow to and from the work location had been reviewed
and adjusted to provide optimum air renoval conditions employing
the spent fuel handling area supply and exhaust systems.
b.
A review of air sample records showed that air samples were
obtained, analyzed and recorded on a frequent and routine basis.
Gammn spectrometer analysis of various samples identified six
isotopes that re=ained consistent in identity and ratios for
the duration of the work.
In most of the air sample reeards
reviewed, the air concentrations were less than the lim'.ts
specified in Appendix B, Table 1, Column 1 for the ider tified
isotope having the most restrictive limit.
In those cases
where air concentrations were above limits it was determined
that respiratory protective equipment in use, properi" worn and
fitted would have provided sufficient protection facto rs.
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In that respiratory protective equipment was worn for
purposes of controlling individual exposures to radioactive
air concentrations the investigators reviewed the licensee 's
program for evaluating the effectiveness of protective equip-
ment. The licensee's Technical Specification 6.4.2(d)(4)
requires in part, bicassay and/or whole bcdy counts (and
other surveys, as appropriate) of individuals to evaluate
exposures and to assess protection actually provided.
'
According to the licensee neither bioassay or whole body
counting had been performed on contractor personnel. With
respect to other appropriate surveys, licensee representives
stated that radiation surveys external to nasal passages of
individuals were not routinely made, neither were nasal
2= ears
,
taken for purposes of radioactivity analysis.
d.
It was further noted that Section VI E.2 of Administrative
,
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Order A-1 requires that personnel using respiratory protective
l
equipment, "will be continuously supervised by health physics
personnel or designates". According to licensee representatives,
health physics personnel were not in continuous attendance
at the work location.
As to designates the licensee stated
that none had been formally na=ed but they felt that contractor
supervisors were capable.
During discussions with contractor
management it was determined that their expertise and train-
Lag were not sufficient to capably supervise and audit proper
use of respiratory equipment.
They stated that supervisors
and foremen had not received special training for that
purpose .
9.
Pocket Dosimeter Results
A review of pocket dosimeter records, by the investigators,
a.
showed that actual pocket dos 1=eter results as recorded on
the daily dosimeter records were transcribed to daily summary
sheets. Dosireter results, when transcribed, were multiplied
by 1.3, the previously described factor.
Accumulating exposure
for each individual, with the applied factor was then used to
estimate the exposures that would normally be shown by the
film badge, the official mechanism for measuring exposure to
individuals.
In this case, film badge results, in general for
contractor personnel exceeded the pocket dosi=eter results
by a factor greater
ut the 1.3 applied.
Specific to the over-
exposed individuals, tne difference between badge results and
actual dosimeter results ranged from a minicum of 1.3 to a
maximum of 3.6.
According to the licensee, dif ferences of
these magnitudes had not previously been experienced.
It was
noted that licensee personnel working in the fuel pit prior to
turning it over to the contractor did not experience these
differences.
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The investigators reviewed the conditions under which the
work was accomplished.
This included a review of situations
in which work was accomplished from a lead shielded bucket,
fif ty gallon drums and from behind portable shields with
the consequence that the pocket dosimeters could have been
shielded.
It was determined, however, during discussions
with licensee and contractor personnel that in general the
pocket dosimeters were worn in close proximity to the film
badge at about breast high locations on the body.
Subsequent
rumors, to the effect that contractor personnel had devised
methods to bypass their pocket dosimeters, were circulated
among licensee personnel.
These were second and third hand
heresay statements.
According to a contractor employee, there
were some workers that hid their pocket dosimeters or took
ceasures to shield them in order to extend their stay on the
job and had been laid off for that reason.
c.
According to one contractor e=ployee that had been laid off,
his dosi=ecer results at the end of a work shift were disputed
as being too low and since he had an accumulated dose of 2000
millircentgen he was laid off.
The individual stated that he
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had worn his dosimeters at all times and in the manner prescribed
during the training session he attended on the first day at
the job site.
d.
During other interviews with licensee and contractor personnel,
the investigators were unable to corroborate the rumors or
the state =ent regarding the hiding or shielding of dosimeters.
Contractor =anagement stated that they were unable to corrob-
orate this fact as well and individuals were laid off on the
assumption that they had ta=pered with pocket dosimeter results.
The investigators determined that for those individuals laid
off radiation exposures had been less than that allowed by
e.
With respect to the possibility that pocket dosimeters could
have been shielded during work in the shielded bucket the
investigators determined that this could have occurred if the
pockec dosimeters were worn at some location below the breast
and separated from the film badge.
The height of the bucket,
according to measurements furnished by the licensee, was 44
inches.
This would have required an individual to stoop or
squat within the bucket in order for shielding to occur.
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Licensee representatives stated that their observations
during the course of the work showed that personnel were
wearing pocket dosimeters and film badges properly and
shielding was not occurring.
10. Management Controls
a.
Investigation findings showed that management controls with
respect to conduct of the work was not consistent with the
needs.
It was noted that the licensee's Project Engineer
for the job had no responsibility for radiological controls
along with the health physics organization.
It war. noted
that during the period when the overexposures occurred health
physics coverage was cut back from that provided during the
first month of the job.
This was also at a time when two
shifts were effected. According to the licensee, this cut
back was dictated by increased workload on the health physics
group.
Exposure controls were minimal in that administration
,
was mostly left to contractor personnel. Health physics re-
viewed and totaled exposures on a daily basis, however, it
appeared that control through the shif t was lacking in that
.
individuals would make multiple numbers of entries to the
work location.
In one such case an individual accumulated
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exposure to 2330 millires in one day.
b.
With respect to training, the investigators determined that,
in general, it was appropriate but inconsistent in subject
material dependent upon the individual providing the training.
'
The licensee did not determine the level of comprehension by
test or quiz.
The investigators determined, from Laterviews
with contractor personnel, that they were generally satisfied
with the training; however, it was presented in too short
a time frame.
In that most of the contractor personnel were
not normally acquainted with radiation zone work, the licensee
did not establish special audits of perfor=ance.
It was
noted that misunderstandings with respect to established
administrative exposure limits existed betweer. the licensee
and contractor supervisors.
The licensee stated that they
had verbally authorized higher (2800 millirem) limits for
certain individuals. According to contractor supervisors,
their understanding was that as of January 20, 1974, all
individuals were authorized to 2800 millirem.
c.
With respect to plant procedures, the licensee failed to deter-
mine if employees were following the requirements of certain
procedures by appropriate audits and surveillance.
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ATOMIC ENERGY COMMISSION
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DIR ECTO R ATE OF R E GU LATO R Y OPER ATION S
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Rochester Gas and Electric Company
License No. DPR-18'
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ATTN: 'Mr. K. W. haish
Investigation No. 50-244/74-01
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Electric and Steam
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This refers to the investigation of your activities authorized under AEC
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' this office on February 20 through April 18, 1974, with respect to the
'
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four Typa 3 and the thirty-six other overexposures that occurred during
- the first quarter 1974.- This also refers to the discussion of investiga-
tion findings held by Mr. Meyer with Mr. Platt and other nenbers of your
staff on February 22, 1974 and to a subsequent discussion, by telephone,
between Mr. Meyer and Mr. Platt on May 2,1974.
' Areas exanined during this investigation are described in the Regulatory
~
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Operations Investigation Report which is enclosed with this letter. Within
I
these areas, the investigation consisted of selective exanination of pro-
cedures and representative records, interviews with licenseo and contrac-
tor personnel, and, observations by the investigators.
.During this investigation, it was found that certain of your activities
'
appeared to be in violation of AEC requirements. The itccs and refer-
ences to the pertinent requirenents are. listed in the enclosure to this
'
letter. This letter constitutes a notice sent to you pursuant to the
provfsions of Section 2.201 of the AEC's " Rules of Practice," Part 2,
Title 10, Code of Federal Regulations. Section 2.201 requires you to
submit to this office within 20 days of your receipt of this notice, a
-
written staternt of explanation in reply, including: (1) corrective
steps which have been or will be taken by you, and the results achieved;
-(2) corrective steps which will be taken to avoid further violations;
t
. and (3) the date when full eenpliance will be achieved.
In addition to
the need for corrective action regarding these specific deficiencies, we
arn concerned about the implencetation of your nanagement control systess
- that permitted these deficiencies to occur. Consequently, in your reply,
l.
you should describe in particular, those actions taken or planned to
improve the deffectiveness of your manage =ent control systens.
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.._'Aa shown in the enclosure to this letter, Item 5 is a recurring item.
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' January 23-25, 1974.
In your reply to this letter, please give particular _
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- tence. With respect to Item 1, as shown in the enclosure to this letter,
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~ Part 2,. Title 10, code of Federal Regulations, a copy of this letter
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- and the enclosed investigation report will be placed in the AEC's Public
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Document Room. If this report contains any information that you (or
.
,'your contractor) believe to be proprietary, it id necessary that you
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so that proprietary information identified in the application is con-
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tuined in a separate part of the document.
If we do nothear from you
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"in the Public Document Room.
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< pleased to discuss them with you.
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1. Description of violations
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LeBoeuf,Tamh, Leiby & MacRae
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ENCLOSURE
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DESCRIPTION OF VIOLATIONS
Rochester Gas a'nd Electric Company
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Docket No. 50-244
License No. DPR-18
Certain activities under your license appear to be in violation of AEC
requirements.
The following violations are considered to be of Cate-
gory II severity:
1.
10 CFR 20.101(b)(1), " Exposure of individuals to radiation in
restricted area," requires you to limit, during any calendar quar-
ter the dose incurred by individuals in restricted areas to 3 rems.
Contrary to this requirement, 40 individuals working in restricted
areas, received whole body doses in excess of 3 rems during the first
,
calendar quarter of 1974. We note that this was reported in your
letters to the Director of Regulatory Operations, dated March 25,
26 and April 8, 1974.
2.
10 CFR 20.101(a), " Exposure of individuals to radiation in restricted
areas," requires you to limit the whole body exposure of an individual
in a restricted area to one.and one-quarter rems per calendar quarter,
except as provided in paragraph (b) of that section.
Paragraph (b)
allows a whole body exposure of 3 rems per calendar quarter provided
certain specified conditions are met.
One of these conditions is
that you determine the individual's accu =ulated occupational dose
to the whole body on Form AEC-4, or on a clear and legible record
containing all the infor=ation required in that form.
,
Contrary to this requirement, you did not limit the exposure of one
individual, performing work in the Spent Fuel Pit, a restricted area,
to 1.25 rems during the first quarter 1974. A Form AEC-4, or record
containing equivalent information was not obtained for this individual.
3.
10 CFR 20.201(b), " Surveys," requires you to =ake such surveys
(evaluations) as may be necessary to comply with all sections of
Part 20.
'
Contrary to this requirement, such surveys (evaluations) as were cade
to assure compliance with 10 CFR 20.101(b)(1), " Exposure of individuals
to radiation in restricted areas," which limits individual whole body
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dose to 3 rems in any calendar quarter, were inadequate to prevent
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1974.
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4.
10 CFR 19.12, " Instructions to workers," requires that all individual
'
working in or frequenting any portion of a restricted area shall be
kept informed of, and instructed in, certain specifics relating to
that work.
The extent of these instructions shall be commensurate
.
with potential radiological health protection problems in the
restricted area.
Contrary to this requirement, you failed to instruct certain
individuals, employed on the Spent Fuel Pit repair job, in all
-
of the required instructions as noted below:
One instructor failed to instruct those individuals attending
a.
his training sessions in the use ,of the full f ace, canister typ2
.
respirator.
b.
Two instructors failed to instruct those individuals attending
their training sessions of the responsibility of workers to report
promptly any condition which may lead to or cause a violation of
Commission regulations and licenses or unnecessary exposure to
radiation or radioactive materials.
One instructor incorrectly instructed those individuals attending
c.
his training sessions as to the time frame in which exposure
Laformation must be made available to an individual upon request.
5.
Technical Specification 6.4.2.d(4; requires, in p' rt, bioassays
a
and/or whole body counts (and other surveys, as appropriate) of
individuals to evaluate exposures and to assess protection actually
provided.
Contrary to this requirement, you failed to accomplish bicassays
and/or whole body counts and other appropriate routine surveys to
assess the protection actually provided by respiratory protective
equipment worn by individuals during the Spent Fuel Pit repair work.
We note that this is a recurring item, previously identified during
the inspection conducted on January 23-25, 1974.
,
6.
Technical Specification 6.4.1 requires that the plant will be operated
and maintained in accordance with approved procedures.
Radiation con-
trol procedures, required by Technical Specification 6.4.2 are con-
tained in Administrative Order A-1, Revision 2, approved July 13,
1972.
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Contrary to this requirement, certain procedures contained in
Administrative Order A-1 were not followed during the Spent Fuel
Pit repair work as noted below:
A radiation control device wh[ch continuously indicates the
a.
radiation dose rate was not provided to individuals or groups
of individuals entering a high radiation area as required by
Section VI. A.4.
-
b.
Training records were not maintained as required by Section II.
c.
One individual failed to sign Special Work Permit No. 527, dated
December 8,1973 and two individuals failed to sign Special Work
Permit No. 528, dated December 10, 1973 as required by Section
VI.B.ll.
d.
Radiation Work Procedure No. 21, dated December 26, did not
,
contain:
(1) the names of groups' whose personnel were authorized
to work under its provisions; (2) the time period for which it
was valid; (3) a detailed description of the work covered; and
(4) a description of the radiation ha::ards which may be encountered
as required by Section VI.B.4.
e.
Continuous supervision, by health physics personnel, was not
provided for individuals while wearing respiratory protective
equipment as required by Section VI.E.2.
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ROCHESTER GAS AND ELECTRIC CORPORATION
89 EAST AVENUE, ROCHESTER, N.Y.14649
m EITH W AMISH
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July 3,1974
Mr. James P. O'Reilly, Director
Dires torate of Regulatory Operations
Region I
U. S. Atomic Energy Commission
631 Park Avenue
King of Prussia, Pennsylvania 19406
Subj ect:
RO Investigation Report No. 50-244/74-01
R. E. Ginna Nuclear Power Plant, Unit No.1
Docket No. 50-244
Dear Mr. O'Reilly:
This letter is in reply to your letter of June 7,1974, which was received June
13, 1974, concerning the investigation conducted at Ginna Station on February
20 through April 18, 1974 by Mr. R. J. Meyer and other representatives of your
office, with respect to personnel overexposures that occurred during the first
quarter, 1974.
The overexposures in excess of 5 Rem were renorted to you by Mr. C. E. Platt,
Superintendent of Ginna Station, on February 0,1974. The exposures exceed-
ing 3 Rem were reported to you by Mr. G. E. Green, Vice President, Electric
and Steam on March 25, 1974. Further information was provided in letters
dated March 26, 1974 and April 8,1974.
Information concerning the apparent violations noted during the investigation
is presented in the enclosure to this letter. Of the ten items noted as violations
you indicated that six did not contribute to the overexposures cited as violation
one. Of the ten items we feel three are valid violations and of these none are
contributory to the overexposures.
The other alleged violations are, in our
opinion, a matter of interpretation of the degree of action needed for compliance.
Although the " Description of Violations" does not list management controls as
discussed in item ten of the Details of the Investigation Report, it appears
appropriate to provide some discussion of this, including plans to improve
management controls on jobs involving major work in high radiation areas. This
is also provided in the enclosure to this letter.
This investigation report contains no information that is considered proprietary.
Very truly yours,
o
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Keith W. Amish
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Enclosure
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ATTACHMENT
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Violation
1.
10 CFR 20.101(b)(1), " Exposure of individuals to radiation in restricted
area," requires you to limit, during any cal endar quarter the dose
incurred by individuals in restricted areas to 3 rems.
,
..
Contrary to this requirement, 40 individuals working in restricted areas,
received whole body doses in excess of 3 rems during the first calendar
quarter of 1974. We note that this was reported in your letters to the
Director of Regulatory Operations , dated March 25, 2 6 and April 8,1974.
RESPONSE:
In accordance with instructions contained in the letter from Mr. James P.
O'Reilly, no response to this item is required.
2.
10 CFR 20.101(a), " Exposure of individuals to radiation in restricted
areas," requires you to limit the whole body exposure of an individual
in a restricted area to one and one-quarter rems per calendar quarter,
except as provided in paragraph (b) of that section. Paragraph (b) allows
a whole body exposure of 3 rems per calendar quarter provided certain
specified conditions are met. One of these conditions is that you deter-
mine the individual's accumulated occupational dose to the whole body
on Form AEC-4, or on a clear and legible record containing all the inform-
ation required in that form.
Contrary to this requirement, you did not limit the exposure of one
individual, performing work in the Spent Fuel Pit, a restricted area, to
1.25 rems during the first quarter 1974. A Form AEC-4, or record contain-
ing equivalent information was not obtained for this individual.
RES PONSE:
Form AEC-4 had not been obtained in December at the time of training as
the individual had previously been on-site for a brief time in 1971 for a
low exposure job. His exposure record from the work at Ginna Station
had been retained and was thought to be on the appropriate form. Since
the repcrting of this incident Form AEC-4 has been filled out for the
individual, and it shows no exposure other than that received at Ginna
Station.
To prevent a recurrence of this item, a checkoff space has been added to
the visitor's dose card to indicate that a Form AEC-4 is on file. This was
put into effect during the month of May,1974.
3.
10 CFR 20.201(b), " Surveys," requires you to make such surveys
(evaluations) as may be necessary to comply with all sections of Part 20.
Contrary to this requirement, such surveys (evaluations) as were made
to assure compliance with 10 CFR 20.101(b)(1), " Exposure of individuals
to radiation in restricted areas," which limits individual whole body dose
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to 3 rerps in any calendar quarter, were inadequate to prevent 40 over-
exposures to your employees during the first calendar quarter 1974.
RESPONSE:
Physical surveys of the levels of radiation were made at adequate intervals
to keep the health physics section, contract supervisors and workers aware
of the dose rates in various areas of the Spent Fuel Pit. The area was a
stable radiation area and did not have any ti:ae variable dose rates.
Periodic radiation surveys shewed space variable dose rates which were
properly posted at the access con +rol point. A copy of the survey maps
was also given to the supervisors of the job.
A radiation monitoring device which continuously indicated the radiation
dose rate was in operation at the Spent Fuel Pit.
We feel that the overexpocures resulted from one or both of the following
two causes:
a.
Lack of sufficient exposure control through the evaluation of pocket
dosimeter readings by Health Physics personnel. This could account
for the 29 persons who have exposures between 3000 and 4000 mrem.
A closer evaluation should have been made on any individual for
whom the dose limit was raised to 2800 mrem.
b.
Purposeful acceptance of exposure by some contractor individuals
(those exceeding 5000 mrem). Whereas this cannot be proven, we
feel there is sufficient evidence to leave the question cpen.
Corrective measures have been taken to establish a policy of Rochester
Gas and Electric Ginna Station employees closely supervising contractor
personnel whenever they are assigned to work in high radiation areas.
For this purpose, the station Superintendent issued a w-itten order on
April 4,1974 to the Supervisor of Chemistry and Health Physics, Operations
Engineer, Maintenance Engineer, and Assistant Superintendent to confirm
verbal orders given upon being informed of the overexposure of the forty
individuals. The following points appearing in this letter upply to contrac-
-
tor personnel working in high radiation areas:
a.
They will be closely supervised by RG&E Ginna Station personnel.
b.
It will be the responsibility of the Ginna Station Health Physics
personnel to determine the radiation dose levels that the contractor
personnel can receive,
c.
It will be the responsibility of the Maintenance Engineer or his
alternate to arrange for an escort to supervise the contractor personnel.
d.
It will be the responsibility of Operations and Health Physics personnel
to immediately report any violation of these rules to the plant Super-
intendent or his assistant.
Further, a letter was issued to and posted for all on-site personnel on
March 4,1974. reiterating the rules for wearing film badges and dosimeters,
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All assigned personnel must wear a film badge and prescribed
dosimeter when in the controlled area.
b.
Film badges and dosimeters should be worn in proximity to each
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Fil'm badges and dosimeters should be protected from contamination.
c.
d.
Dosinieters are not to be worn on a string or chain.
Close supervision of contractor personnel will include emphasis on
ensuring the above rules are complied with. It will include ensuring
that contractor personnel periodically review posted radiation survey
res ults . It will include ensuring that contractor personnel follow require-
ments prescribed by the appropriate SWP or RWP for the particular job,
and that they abide by other proper radiation protection practices. It will
include evaluation of the exposure of each contractor individual as his
dosimeter reading is recorded. Personnel are to be placed on " limited
entry" status when their quarterly exposure exceeds 2250 mrem; that is,
certain individuels with specialized skills necessary to complete a
particular job with minimum exposure whose quarterly exposure exceeds
2250 mrem will be considered for entry into a radiation controlled area.
Authorization to do so for each individual must be obtained from a Health
Physicist. An individual is to be promptly removed from work in a radia-
tion controlled area when his quarterly exposure reaches 250J mrem.
4.
10 CFR 19.12, " Instructions to workers," requires that all individuals
working in or frequenting any portion of a restricted area shall be kept
infonned of, and instructed in, certain specifics relating to that work.
The extent of these instructions shall be commensurate with potential
radiological health protection problems in the restricted area.
Contrary to this requirement, you failed to instruct certain individuals,
employed on the Spent Fuel Pit repair job, in all of the required instruc-
tions as noted below:
a.
One instructor failed to instruct those individuals attending his train-
ing sessions in the use of the full face, canister type respirator.
b.
Two instructors failed to instruct those individuals attending their
training sessions of the responsibility of workers to report promptly
any condition which may lead to or cause a violation of Commission
regulations and licenses or unnecessary exposure to radiation or
radioactive materials.
c.
One instructor incorrectly instructed those individuals attending his
training sessions as to the time frame in which exposure information
must be made available to an individual upon request.
RESPONSE:
The training lectures which were given to all contract personnel included
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material specifically listed in the Administrative Order, A-1, Radiati6n
Protection Personnel Training and Administrative Procedures, section II.D
as follows:
.
a.
Shielding and radiation protection to minimize exposure.
b.
Purpose anc' functions of protective clothing and respirators.
c.
The Radiation Control Manual.
As this lecture was given by several people at different times, the emphasis
put upon the material would vary.
In order to better standardize the health physics instructions to workers so
that various instmetors will cover all the required material, we have
revised and upgraded an outline for health physics training. The specific
items listed in this outline that are required by 10 CFR 19.12 are:
a.
Notices that are posted indicating the obligation of the RG&E
concerning radiation exposure information.
b.
The responsibility of workers to report promptly on matters involving
violations of Commission regulations or unnecessary exposure to
radiation or radioactive materials.
Instructions on the use of breathing prctection will be included as approp-
riate to the job. Separate, and more extensive training will be given to
individuals on specific jobs requiring the use of masks.
5.
Technical Specification 6.4.2.d(4) requires, in part, bioassays and/or
whole body counts (and other surveys, as appropriate) of individuals to
evaluate exposures and to assess protection actually provided.
Contrary to this requirement, you failed to accomplish bloassays and/or
whole body counts and other appropriate routine surveys to assess the
protection actually provided by respiratory protective equipment worn by
individuals during the Spent Fuel Pit repair wo,
We note that this is a
recurring item, previously identified during the inspection conducted on
January 23-25, 1974.
RESPONSE:
RG&E does not dispute that bioassays or whole body counts were not done
on the group in question. However, we do not feel this is a violation of
Technical Specifications 6.4.2.d(4) as the Technical Specifications do not
require a body count on each individual who uses a mask.
A body count is routinely made on plant personnel and others who have
been exposed to some level of airborne activity. Whenever a body count
is scheduled, persons who have used masks are included. We have never
seen evidence that the mask program was not effective. Therefore, by
applying statistical relationships to these whole body count results, it is
deemed not necessary to count each individual.
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Although we do not agree that a violation ,of Technical Specifications
has occurred in this case, the RG&E has recognized the necessity to
detect short-lived isotopes such as iodine-131 during occasions when
concentrations of such isotopes are known to be present. As stated in
our letter to Mr. Paul R. Nelson on April 11,1974 (response to item 5
of the January 23-25, 1974 Inspection Report 74-02), we had used a
thyroid counter during the steam generator work in 1972. Furthermore ,
it stated that investigation has continued resulting in instituting a pro-
cedure for checking the nose passages of each individual working in
contaminated atmospheres so that internal contamination may be readily
detected and a more thorough examination conducted if necessarf. For
the same reason, we are investigating the installation of an on-site
whole body cour ter.
This investigation had been started in August,' 1973 prior to the above
noted inspection. Although you identify this as a recurring item, it is
truly a reiteration of the same question since the February 20, 1974
investigation took place before the receipt of the Inspection Report 74-02.
6.
Technical Specification 6.4.1 requires that the plant will be operated and
maintained in accordance with approved procedures. Radiation control
procedures, required by Technical Specification 6.4.2 are contained in
Administrative Order A-1, Revision 2, approved July 13, 1972.
Contrary to this requirement, certain procedures contained in Adminis-
trative Order A-1 were not followed during the Spent Fuel Pit repair work
as noted below:
'
A radiation control device which continuously indicates the radiation
a.
dose rate was not provided to individuals or groups of individuals
entering a high radiation area as required by Section VI.A.4.
b.
Training records were not maintained as required by Section II.
c.
One individual failed to sign Special Work Permit No. 527, dated
December 8,1973 and two individuals failed to sign Special Work
Permit No. 528, dated December 10, 1973 as required by Section
VI.B.11.
d.
Radiation Work Procedure No. 21, dated December 26, did not contain:
(1) the names of groups whose personnel were authorized to work
under its provisions; (2) the time period for which it was valid; (3) a
detailed description of the work covered; and (4) a description of the
radiation hazards which may be encountered as required by Section
VI.B.4.
Continuous supervision, by health physics personnel, was not pro-
e.
vided for individuals while wearing respiratory protective equipment
as required by Section VI.E.2.
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RESPONSE:
,
We do not agree that certain procedures in Administrative Order, A-1,
the Radiation Control Manual * were not followed. The Manual is a guide
to provide control over radioactive materials and protection for persens
working with and around radioactivity. Based on our interpretations of
the instructions set forth in the Manual, the following responses are
listed with letters which correspond to the allegations listed above.
a.
A radiation monitoring device which continuously indicates, records
and alarms is mounted at the Spent Fuel Pit and was in operation
throughout this job. This was deemed to satisfy Administrative Order
A-1, item VI. A.4.
Also, detailed radiation surveys were made period-
ically to determine if a change in radiation conditions occurred.
b.
A-1 in Section II states, "A record shall be kept of all individuals
trained . " Said_ record was considered to be the contractor employ-
ment roll or timesheets as all contractor personnel were assigned to
training their first day of entry and film badges were issued as part
of that program. Previously, attendees at training sessions which
were not held for a specific contractor group, signed the roll sheet.
During the aforementioned January 23-25 inspection it was suggested
that the roll sheet be formalized to indicate the extent of training and
the material covered. A new form which indicates the extent of train-
ing and material covered to be signed by each individual receiving
training was put into use February 26, 1974. This should give better
documentation of trained individuals.
c.
The individuals who did not sign the special work permits must have
omitted this as an oversight as they did sign previous and subsequent
special work permits. Reading and signing the special work permit
has always been stressed as part of the training lecture and will
continue to be included. In the future, individuals who are to supwise
work covered by an SWP will insure that this is carried out.
d.
Based on its interpretation of A-1, the Health Physics staff does not
consider these items to be violations of procedures.
(1) The groups authorized to work under a work permit are indicated
by the supervisors' signature which, in this case, is the
Maintenance Engineer and the NISCO Supervisor.
(2) All radiation work procedures are in effect for one year from the
date it is written (See A-1, IV.B.1), unless specifically termin-
ated. The time period for which it is valid is therefore indicated
by the dates shown on the permit.
(3) The job description is given in sufficient detail to di.ferentiate
it from any other work being done at the same time under other
work permits. The Health Physicist enters sufficient detail so
that workers will know which permit covers their particular job.
- Retitled from " Radiation Protection Perconnel Training and Adminir'rative
Procedures" to "Radfation Control Manual" on May 14, 1974.
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(4) The hazard of airborne contamination was indicated by requiring
nasks for grinding and welding. A special instruction was
included to consult the radiation survey sheets of the working
area. Survey maps indicating radiation dose rate levels were
available to all personnel. To improve the description of
radiation hazards to be contained in the RWP, the treatment of
radiation hazards is being reviewed. The new format will include
provisions for noting information on the radiation hazards which
may be encountered.
The Administrative Order A-1, now called Radiation Control Manual,
was reviewed by the Plant Operations Review Committee in May,1974
and changed to correspond more closely to actual use of SWP's and
RWP's and to give closer guidance in the requirements for the use of
protective equipment.
e.
The Health Physics staff expected that the contracter supervisors,
who continuously supervised the Spent Fuel Pit repair job, would
enforce the use of respirators as specified by the SWP's and RWP's,
during grinding and welding. Health Physics personnel, therefore,
made only periodic inspections two or three times each shift, at which
time respirator use was checked.
As corrective action, a policy of closely supervising contractor
personnel with RG&E Ginna Station personnel has been established,
as discussed under Item 3.
With respect to management controls, several basic requirements will be
imposed for the conduct of major werk in high radiation areas where many
individuals are utilized.
1.
A project engineer will be assigned to a particular job who has acquired
experience at the plant and with the responsibility for radiological
controls as part of his overall responsibility for the safety of those
working under his supervision.
2.
As stated in RESPONSE 3, close supervision will be provided by
RG&E Ginna Station personnel during contract work in high radiation
areas. This will include dosimeter exposure evaluations at more
frequent intervals than daily. During two previous projects in the
Ginna containment, a local checkpoint was established for this purpose.
This concept was successful since no incidence of overexposure ever
occurred . The overexposures would have been precluded if a local
checkpoint had been utilized for the Spent Fuel Pit job.
Prior to January, for the Spent Fuel Pit repair work, a remote checkpoint
was utilized and was adequate since this was the only work that was
being performed in the controlled area.
After the first of the year with
the unplanned unit outage, this work was expedited, and additional
work was being performed throughout the controlled areas. As a result,
the surveillance for the Spent Fuel fit work from the remote point
proved to be insufficient.
Establishing a local checkpoint for this
purpose, as well as a center for supervision of the job, will be included
as a standard practice in preparing for projects of this nature.
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3.
Local supervision of each job involving contract labor in high
radiation areas will lead to proper observation of the performance of
the work, and provide better communication between RG&E staff and
contractor labor. In addition to this, special audits of the perform-
ance will be undertaken from time to time by a member of the Health
Physics staff to insure that the proper requirements are being followed.
4.
In the case where an individual has been authorized to return to a
particular job after being placed on limited access status, written
authorization specific to that individual will be issued to the job
supervisor.
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