ML20084H055

Discusses Personnel Overexposures to Radiation at Facility. Review & Standardization of Facilities Instructions for Preventing Overexposures Recommended

ML20084H055
Person / Time
Site:	Ginna
Issue date:	07/27/1974
From:	Nader R AFFILIATION NOT ASSIGNED
To:	Ray D US ATOMIC ENERGY COMMISSION (AEC)
Shared Package
ML19289B354	List: ML20084H045 ML20084H055 ML20084H081 ML20084H085 ML20084H093 ML20084H096 ML20084H099
References
NUDOCS 8304270466
Download: ML20084H055 (4)

Text

. _ _ _-

o o

.- e c c 1 .

4 l

+ ,

~

July 27, 1974

The' Honorable Dixy Lee Ray j , Ch a'irman The Atomic Energy Commission i Washington, D.C. 20545 ,

) t

]

Dear Chairman Ray:

i ,

1 Your attention is called to matters relating to overex-j posures' suffered by workers at the' Indian Point'I and Ginna J

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 overex'posures.- In both~ cases,-

l l the AEC's lack of guid'ance in establishing worker control standards is at l' east partly responsible for the' overexposures.-

~

) {

{ Indian Point overexposures:-

l

• d l The Indian Point cases involve eight' individuals'who were i allowed to exceed their quarterly dose limits, over the period

, November 1972 to December 1973. Two cases involved 18 year j olds who were overexposed before their ages were d.iscovered.

Uncertainty pervades the remaining over'xposures.- e In each'of

}

the six cases', dose by film badge was, greater than 3 ' rem, but i dose by dosimeter was less than 3'ren.

i ,

j In the' worst case, the' film badge dose'was nearly four i

times that of the~~ corresponding doslmeter value (2290'aren vs.

575 mrem, during September 1973;' reported by letter' from Con Edison to Directorate of R,egulatory Operations - (DRO) on November 23, 1973). The' only mention Con Edison makes' of any efforts to resolve the' film-dosimeter discrepancy appears in the Novem-l ber 23 letter. The company assures DRO that Con Edison is

" accelerating our investigation" of the~ discrepancy. Apparently ,

a the acceleration has not been rapid enough to provide answers at this time.

{

The company's proposed corrective action 'for the dis-l crepancies is to require workers to wear thermoluminescent dosimeters (TLD's) as a measuring

• device. But the' company has not determined the causes of th e film-dosimeter differences.-

Nor has it evaluated relative accuracies of the' two methods i when a difference occurs. The company in fact has provided no i public evidence tha't it is investigating eithe'r problem. To i use the TLD's without answers to these problems is merely to add a third potential discrepancy.

y13ug g3Mij0301330

- s ,.

BS :01 FN lE lilf Ph -

g4 0466 750519

~

H OCK 05000244 * ' ' ' " * ' ~ ' '

PDR 4

e

- - - ~_ , , . , , - - . - . e <.

l

.Choirc=Ocr(- O f  !

Pege Two,"

Question (1) : Con Edison's public files'are silent on its efforts to resolve the film-dosimeter discrep'ancies.- Has the company kept the AEC informed of its efforts.to solve  ;

the'se problems? Has the~ABC required the' company ~to adequately l i

inform the AEC of tho' company's efforts?' . -

Ginnaovere$p'osures: f j i Additional problems have occurred at tho' R.E. Ginna plant.  :

In a letter to DRO dated March 25, 1974..Roch6 ster Gas and  !

l Electric (RGE) reported that 40 men ha'd received film badge e v l

doses of 3 ren or, greater in a quarter, while the' dosimeter i

doses for the same men were all less than 2500 mrea. In four cases, th6 ' dose by film badge was. greater than 5 rem.  ;

RGE felt that the' discrepancies'were'due to improper supervision of workers - all'40imon'were employed by an outside contractor for maintenance'on thi spent fuel pit.. As corrective action, Ginna now requires that any contractor personnel be

, closely supervised by RGE personne1~.- RGE was apparently unaware

! of the Indian Point problems, and' believed tha't worker control would eliminate the Ginna problem. In 1ight of similar occur-i ences at two plants, however, the possibility of a generic

! discrepancy cannot be dismissed.

Question (2): Are tho' Indian Point and Ginna cases iso-lated incidents, or does a, generic film-dosimet'er discrep~ancy

~

exist? If a generic problem does' exist, wha't action ha's tho' AEC initiate'd to solve itf..

Inadequacy of. Con Edison corrective action:

As further corrective action for its overexposures, Con .

Edison has established a limit of 2 :ren, after'which'a worke~r e

is excluded from radiation work'for the'~ remainder of thi~ quar-ter. This limit is supposed to prevent the' worker from receiving a dose by film badge'whi'ch might be greater than 3 rem per quarter.

' ~

However, in four out of the six cas'es involving, greater than 3 rem exposure, thi's limit would not ha've prev'en'ted tho'exces'-

. sive doses.- Consider the' following cases:-

1. An overdose during April 1973'was reported by a Con Edison letter to DRO on June 18,. 1973. The' individual received i

1980 area by dosimeter during April'5 and 11. Whe~n his film badges for tho'se' days were developed several days -later', they gave an exposure of 3080 mrea'.-

i C

, . , - , , . - .-y ~ , . . _ . _ . _ - , - . _ . , _ _ _ , _ _ - . . . . , - . . , _ . _ _ _ . . ,, m

.i . '

8

( (

Chcirpo cy Page Three

2. An overdose'during August 1973 was reported by a Con Edison letter to DRO on September 14, 1973. An individual who had no previous exposure for the quarter entered a h.i'gh ' radiation I

area wearing an 0-2000'aren dosimeter. He'left the' area after noticing the dosimeter was off scale. His film- badge who'n developed read 3210 aren.

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 aren by dosimeter and 1420 area by film. His dose by dosimet'er for September was -

575 mrem; when added to the film dose for tho' previous two months, this would have given 1995 mrem total exposure. When the' Sept-ember film badg,e was developed later, it, gave an exposure of 2290 mrem for a total of 3710 mrea.

4. An overdose during October 1973'was reported by a Con Edison letter to DRO on December .13, 1973i- The individual's l exposure earlier' in the' month was 10S0 mren by dosimeter' and 1030 mren by film. His next dosimeter reading was 925 aren', for a total of 1975 mrem. When thehfilm badge was developed it read 2700 'arem for a total of 3730 mrem' for the' quarter.

Clearly, in none of these four cases would tho' 2'ren limit have prevented overexposure by film. It is hard to believe that the AEC would have accepted Con Edison's proposed corrective action, had the' agency been completely aware of th'e' inadequacies,-

as it should ha've been~. But th,e'Rugional reply to Con Edison's proposed action was little more th' n aan acknowledgment '(Reg' ion I letter to Con Edison, May 16i 1974)'.

Question (3) : 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 overlooke'd? If the~AEC was aware of the inadequacy, why did it accept the company's action?

Consolidated Edison's program seems more inadequate who'n compared even to RGE's pr, o gram to control radiation exposures.

At Ginna, the following controls were'in effect prior to tho' overexposures:

1. RGE personnel were assigned to zero the' dosimeters of contractor personnel.

2. Daily dosimeter lists were maintained.

3. Men were' restricted from radiation work when tho' dosi-meter dose reache'd 1920 aren.in a quarter. When a 1.3' factor is applied for possible film dose differences,'this,gives 2500 aren adjusted exposure.

4. A daily dose list with the 1.3' factor was prepared in order to restrict men below the 2500 arem level. Autho'rization in writing was required for any man to exceed 2500 arem adjusted.

._ -.....a.. ....m

, Cheirac I (

Pogo Fou -

cy ( ')

The Con Edison' corrective action is thu~s less effective than tho' RGE program in effect before the Ginna overexposures.

Since RGE's program was insufficient to prevent overexposure, it is even more puzz' ling that the AEC accepted Con Edison's corrective action without comment.

I .

Question (4).: . Regulatory Guides ~8.8 and'8.'10,give'no more than, general, guidelines for limiting radiation exposures.- Other than the's'e Guides', does tho' ABC have'any standards or require-ments for nuclear plant programs to control worker exposure?

Necessary ABC action:

It is not unexpected that different nuclear plants ha've different techn~ical specifications, in light' of the present

> non-standardization of plant systems. It is more inexplicable l

that an apparen't ho'.dge-podge of worker control programs exists

in different plants. The' AEC should review and standardize' each plant's instructions for preventing overexposures'. Such action will result in advancing the' he'alth 'of nuclear workers.

The' Code of Federal Regulations, 10'CFR 20.601,1 provides for civil penalties in the~ case of radiation overexposures.-

The Consolidated Edison overexposures involve recurring inci-dents for over a year. The company ha's taken no discernible action to resolve tho' film-dosimeter discrepancies whi'ch' con-tributed to the incidents. In a show or' callous negligence, ~

the company ha's establishe'd corrective action which if applied to previous cases' would have been insufficient to prevent overexposures.' For these reasons,-it is urged tha~t the' AEC demonstrate its concern for worker safety by invoking th e's e regulations.-

S i n c e r'e l'y ,

t. - -

Ralph Nader l

l

.C

\