ML20132C963
| ML20132C963 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 02/28/1985 |
| From: | Ratner M RATNER, M.G. |
| To: | NRC |
| Shared Package | |
| ML20132C968 | List: |
| References | |
| FOIA-85-208 NUDOCS 8505020150 | |
| Download: ML20132C963 (68) | |
Text
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A
?
t BEFORE THE NUCLEAR REGULATORY COMMISSION Vera M.
English NRC Inspection Reports Nos.
and 70-1113/84-17 General Electric Company 70-1113/84-18 SUPPLEMENTAL PETITION UNDER 10 CFR S 2.206 FOR WITHDRAWAL OF REPORTS 84-17 and 84-18, ISSUED JANUARY 18, 1985; ISSUANCE OF NEW REPORTS CORRECTLY DOCUMENTING AND FINDING ALLEGED VIOLATIONS AT THE WILMINGTON FACILITY IDENTIFIED HEREIN; ISSUANCE OF NOTICE OF VIOLATION ON ALL SUBSTANTIATED ALLEGATIONS, ASSIGNMENT OF APPROPRIATE SEVERITY LEVELS TO EACH FOUND VIOLATION, AND COMMENCEMENT BY NRC OF APPROPRIATE ENFORCEMENT ACTION, INCLUDING THE ASSESSMENT OF CIVIL PENALTIES CHAPTER I This petition supplements our petition of December 13, 1984, incorporated herein by reference, as contemplated therein, p. 2, by discussing reports thus far issued subsequent to the filing thereof.
The new reports were received by counsel on February 11, 1985.
See letter of Deputy Director James M. Taylor to Ratner, dated January 10, 1985 with enclosures.
As of thi[ writing,'we have not yet received Mr.
Ed Clay's report, base <' on his investigation of December 3-6, 1984, and his subsequent inspections, nor have we received any report of 01 investigations of Mrs. English's allegations which are within the " area of its expertise."
(App. 1, infra).1/
1/
kNports84-15and84-16werereceivedonFebruary25, 1985.
Because of the exigencies of time, we defer comment on those reports and submit this document, which is only a fraction of our petition relating to 84-17 and 84-18, labelled Chapter I.
fcGO7O\\"D
,a
I.
INTRODUCTION i
A.
Report Errors and Deficiencies Before turning to No. 84-17, it is important to observe (1) that this report itself establishes that earlier i
j reports, insofar as they find no violation in many allegations, are factually and legally in error; (2) that the reports often grroneously excuse failure to find a violation on the ground that "the commitment involved has not been made a legally i
binding requirement" (49 F.R.
8591, E (2); (3) that the reports show that no attention was paid to the fact that several of the I
i violations previously found were repeat and/or uncorrected i
offenses which require civil penalties (49 F.R.
8589, B, 4, 5);
o (4) that such offenses, and offenses which should have been found, reflect deliberate or at least " careless disregard of j
requirements," i,.e,.,
" willfulness,".(49 F.R.
8588), and were not identified by the licensee or reported to the Commission as required (,id., at 8588-8591); and (5) that the findings clearly 1
i demonstrate " dereliction of duty on the part of [ highest
)
l management] personnel involved in licensed activities" (,id.
i l
8591, VII, Supplement I, C, 3).
Yet, even those findings which were made were illegally assigned the lowest categories of i
j severity levels.
The severity level assigned to the offenses i
found was never more than IV or V.
t i
l Moreover, it is patent that the findings were carefully drafted to make it appear that the violations found were only i
" technical."
In none of the reports, including 84-17, was the l
i l
- I i
j
s b
actual effect on worker health and safety of the found breakdown of protective systems and of avoidable uranium contamination evaluated or considered in the light of "the cumulative total for all violations."
Jd. at 8590.
Nor was a crucial factor, " economic advantage * *
- gained [by management) as a result of the violation [s]," anywhere considered.
Yet it is self-evident that the only explanation of highest management's willful non-implementation of G.E.'s radiation protection program, for which Stohr naively requested an explanation in his letter of January 3, 1985 to Vaughan enclosing Report No. 84-1), is solely economic benefit to G.E.
resulting from disregard of safety requirements in the interest of meeting production schedules.
B.
Defects In NRC Investigation Procedures And Assumptions Some general observations concerning the methodology of the NRC inspections are also required.
The Inspectors assume that because their visits were not announced in advance, management had no opportunity to " clean up" and
~
f alert the workers to be on good behavior, and that, therefore, f
the conditions they observed during inspections were normal.
i This is a totally false assumption.
The inspectors must
\\
l identify themselves at the guard house.
The guards immediately notify management of their presence.
It takes at least fifteen minutes"for the inspectors to get from the guard house to the I
wet lab.
That is plenty of time for management to " cover up" l
l l
3-e k
6 and instruct workers to comply with regulations while the inspectors are at the plant.
Moreover, the Inspectors' reports almost invariably speak of conditions as they existed on the dates of investigation; not as they existed on the dates referred to in the charges.
Such " investigations" are meaningless, because management may meanwhile have changed procedures, destroyed evidence, instructed workers to " clean up" and " shape up" during NRC investigations, or " corrected" conditions.
The investigations typically occur only many months after the charges.
When the investigators are unable to find physical evidence which was under the control of management, they conclude that they are unable to prove the case, instead of applying the universal legal principle, " contra spoliator,"
under which management is presumed guilty of spoliation if it cannot produce evidence which once existed or should have existed.
The Inspectors' conclusions are discussed only with management at an " Exit Interview"; neither the conclusions nor management's " explanations" are discus 4ed with the complainant.
This prevents complainant from pointing out factual errors and erroneous inferences drawn by the Inspectors from information supplied by management and by G.E.-intimidated employees and by employett hostile to complainant.
To the extent employees are interviewed, they are seen on the plant site, in the company of a representative of 1
s management.
Knowing management's vindictiveness, employees typically fear management reprisal, in the form of selection if they tell the truth about for layoff and other means, management-laxity, cover-ups and subtle threats of reprisal.
Further, the covering letters from NRC to the licensee forwarding investigation reports (particularly those finding any violations), virtually always assume that the report is
" privileged and confidential" and invite the licensee to forward his response as a separate document to seoid disclosure.
We submit that practice is in flagrant violation of 10 CFR S 2.790(b).
Lastly, although NRC was officially notified on September 26, 1984, that Mrs. English waived confidentiality, every report written after that date still refers to her as
" alleger" (84-17, par. 4 " note"), sometimes, in context, to the confusion, if not mystification, of the reader.
[
C.
The Reports Reveal Region II Inspectors' And Supervisors' Bias and Prejudice In Favor of G.E. And Against Complainant on the basis of our analysis of defects in No.
84-17 (and the prior reports analyzed in our original petition), which we discuss in detail below, we charge that (1) the technical inspectors who issued, and the supervisors who signed, these six reports are guilty of cover up; of shielding and protecting G.E.
against, inter alia, required civil penalties and accompanying press releases (49 F.R.
8591 (VI, '
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second and third sentences);E/ and (2) tailoring their findings to create evidence against complainant in her current DOL hearing not only by minimizing the nature, number and significance of the violations found, but by making it appear that Mrs. English's charges were largely unsubstantiated and that Mrs. English is, therefore, an unreliable witness.
A material allegation of Mrs. English's Complaint in DOL Case No. 85-ERA-2 is that " General Electric's violations of safety standards were endemic and constant" (Tr. 412).
DOL issued a probable cause finding in that case that Mrs. English was discriminatorily transferred out of the Chemet Lab and subsequently discharged for revealing G.E.'s violations to NRd, in violation of Section 210 of the ERA.
If sustained, that is a Severity I violation.
49 F.R.
8593, Supp.
VII, A, 4.
II.
NO. 84-17 ESTABLISHES A PER SE HIGH SEVERITY 1
1 VIOLATION OF MANAGEMENT'S (ALARA) OBLIGATION r
A.
The ALARA Obligation
,i NRC rules, 10 CFR S 20.1(c), require that "in addition to complying with the requirements set forth in this part, (management must] make every reasonable effort to maintain radiation exposures, and releases of radioactive 1
materials in effluents to unrestricted areas, as low as is reasonably achievable."
(Emphasis added.)
This obligation is i
l l
2/
Ippendix 2, infra, Attachment 2, shows Region II NRC l
Directof J. P. O'Reilly's improper concern for shielding G.E.
from " potential inquiry by the press or others" about a serious i
i safety incident.
l j.
i i
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known as ALARA.
According to the Supreme Court in.Silkwood v.
Kerr-McGee Corp., 81-2159, 52 L.W. 4043, 4044 (January 11, 1984), ALARA is the " standard" to which licensees must conform their conduct.
Not one of the reports we have been furnished so far so much as mentions this obligation.
G.E.'s Criticality Safety Control, Chemet Lab, C 2.0-QA-201, in effect since at least 1976, provides, p.
1, 2.1 (App. 3, infra), " procedures must be written as part of the criticality safety program and become a part of the license.
The procedures shall be strictly adhered to in order to comply with safety requirements and to assure criticality safety in our operations."
(Emphasis added.)
10 C.F.R. 5 19.12 requires that licensees not only instruct workers "in precautions and procedures to minimize exposure" to radioactive materials or radiation, but instruct them to report to management "any condition which may lead to or cause unnecessary exposure to raciation or to radioactive material." See also, S 20.206.
Section 19.11 requires management to post copies of "the operating procedures applicable to licensed activities."
Section 21.6 requires posting of " procedures adopted pursuant to the regulations in that part."
Appendix to NRC Reguiatory Guide 8.29, " Instructions Concerning Risks from Occupational Radiation Exposure" App. 4, -Jnf ra ) defines ALARA to require (p. 8, par. 13, see also, p.
14, par. 7, last sentence):.
"All * *
- operating procedures should be reviewed with the objective of reducing unnecessary exposures."
The Instruction explains the health risks involved in acute and chronic exposure to radiation, pp. 3-4.
At par. 5,
- p. 4, the Instructions state:
" Chronic exposure, which may cause delayed effects but not prompt effects, refers to small doses received repeatedly over long time periods; for example,20-100 mrem (a mrem is one-thousandth of a rem) per week every week for several years.
Concern with occupational radiation risk is primarily focused on chronic exposure to low levels of radiation over long time periods."
Further (p. 6, par. 9i, " cancer resulting from exposure to radiation usually occurs 5 to 25 years after the exposure The Instructions warn (p. 7, par. 9):
"A worker * *
- should make every effort to keep exposure to radiation ALARA to avoid unnecessary risk.
The worker, after all, has the first line responsibility for protecting himself from radiation hazards."
B.
The Radiation Hazards Against Which Licensees Must Establish and Enforce l
Protective Systems, e.g.,
Air-Intake Monitoring; Rad Safety ~ Inspections; Body Monitoring and Frisking I
10 CFR (rev'd as of January 1, 1984),
SS 20.101-3, specifies the maximum " occupation dose" of l
radiation to which workers may be subjected, i.e., 1 1/4 rems t
per calendar quarter, or 5 rems per year.
The " air dose" must be "meashred by a properly calibrated appropriate instrument in air at or near the body surface-in the region of highest l
dosage rate."
(Emphasis added.) !
"[I]ntakes must be evaluated and accounted for by techniques and procedures as may be appropriat e to the circumstances of the occurrence.
Exposures so evaluated shall be included in determining whether the limitation on individual exposures in r
5 20.103(a)(1) has been exceeded."
(10 CFR S 20.103, n. 4).
(Emphasis added.)
10 C.F.R.
S 20.iO3(a)(3) provides:
"For purposes of determining compliance with the requirements of this section the licensee shall use suitable measurements of concentrations of radioactive materials in air for detecting and evaluating airborne radioactivity in restricted areas and in addition, as appropriate, shall use measurements of radioactivity in the body, measurements of radioactivity excreted from the body, or any combination of such measurements as may be necessary for timely detection and assessment of individual intakes of radioactivity by exposed individuals."
(Emphasis added.)
S 20.103(b)(1) provides
"(b)(1) The licensee shall, as a precautionary procedure, use process or other engineering controls, to the extent practicable, to limit concentrations of radioactive materials in air to
~~
levels below those which delimit an airborne radioactivity area as defined in S 20.203(d)(1)(ii)."
(Emphasis added.)
The licensee must also maintain the records required by 5 20.103(b)(2), last sentence, and 5 20.405.
Subsections
\\
i 405(a)(1), (i) and (2), require reports to individuals and to NRC of exposure in excess of applicable limits.
S 20.405 (c)(2) requires that reports "must describe
"(i) The extent of exposure of individuals to radiation or to radioacti.ve material; (ii) Levels of radiation and concentrations of l
- s radioactive material involved; I
l (iii) The cause.of the exposure, levels, or concentrations; * * *."
l l l
Subsection 405(a) (iii) requires that the licensee report to NRC
" Levels of radiation or concentrations of radioactive material in a restricted area in excess of any other applicable limit in the license."
10 C.F.R.
S 20.201(b)(1) and (2) requires that every licensee make " measurements of levels of radiation or concentrations of
. radioactive material present" as "are reasonable under the circumstances to evaluate the extent of radiation hazards 10 C.F.R.
S 21.21 (Reporting of * *
- Non-Compliance) requires licensees to " adopt [and post S 21.6] appropriate procedores for (i) [e] valuating deviations [(ii)(b)(1)],"
notifying [within two days, S 21.21(b)(2)] NRC of "information reasonably indicating a failure to comply * *
- affecting (i)
- an activity subject to, inter alia, Parts 30, 50, 70, 71, 72 of Gais chapter; and reporting to NRC the "[n]ature of the
- failure to comply and the safety hazard which is created or could be created by such * *
- failure to comply."
S 21.21(3)(iv).
10 CFR S 21.51 requires the licensee to maintain records "as may be required to assure compliance with the regulations in this part," including inspections and testing of any facility.
In short, it is not only the legal obligation of management to minimize (ALARA) the danger to workers of contamination by radiation, but, to that end, to adhere I
absolutely to the NRC's requirements to maintain and use
! l i
accurate systems for measuring and testing of worker radiation intake levels, accurate record keeping and reporting.
The five earlier reports virtually ignore not only the former but the latter obligation.
The findings in 84-17, and earlier reports, properly analyzed, demonstrate that G.E.'s highest management wilfully, calculatedly or by " careless disregard," and by deception, for its own profit, destroyed the utility of at least four of the systems it was required by law to maintain to guard against exposure te radiation hazards (1)Wsir intake monitoring; (2) Rad. Safety Inspections; (3) frisking and (4) body counts.
In consequence, G.E. was, at the time of Mrs.
English's complaints, and at least until December 6, 1984, unable to ascertain or accurately to report the intake of radioactive contamination by wet lab employees.
Th'e NRC's entire employee protection program was aborted.
C.
The Findings In No. 84-17 Establish Willful Per Se Violations of the Entire Contamination Control Program The Report (p. 1, par.- 2) finds " weaknesses in the contamination control program in the Chemet Lab."
The
" weaknesses" found relate to the " frequency and scope of contamination surveys, survey requirements for removing paperwork, samples and personal items from the lab, and management attention and commitment to a radiologically clean l
working-environment in the laboratory."
(Emphasis added.)
As we shall demonstrate below, these " weaknesses" are amply supported by the subsidiary findings.
Indeed, Stohr's covering 11 -
-,,,,.---..,-..--.-------r-
letter to Lees of January 31, 1985, voices NRC's concern "about the implementation of your radiation protection program that permitted this situation to develop."
(Emphasis added.)
But these " weaknesses" are reported only in the " Exit Interview," and there only in the context of management's agreement "to review this area and to take appropriate action to improve the program."
And the " concern" expressed in Stohr's letter likewise merely invites a response from G.E.
which " describe [s] those particular actions taken or planned to improve the effectiveness of your program."
Now, possibly, management's willingness or commitment to take remedial action in the future might be relevant if the issue were whether G.E.'s license should be " modified, suspended or reycked" (10 C.F.R. 70.61(d)), or whet'her a projected civil penalty should be reduced.
49 F.R.
8589, B 2.
Bet that is not the issue.
The issue is what formal violation findings and civil penalries should be imposed for the past and current violations found and reported in the exit interview, reflecting top " management's (in] attention and (non] commitment to a radiologically clean working environment," supra, p.
11.
l l
If only top management's " careless disregard" for a f
" radiologically clean working environment" were shown, that i
itself would be a willful, m s_e, violation of ALARA.
49 C.F.R. g588, III, " Severity of violations."
Management's willingdess and commitment to reform, to take corrective action in the future, is not a defense but an admission of willful 12 -
l i
violation, inherent in management's attitude, "which permitted this situation to develop," unremedied and unreported by G.E.
to NRC.
Indisputable proof that management was not only well aware of the deficiencies in operation of its safety protection and quality control systems, but that " inattention" and
" careless disregard" was a management policy deliberately adopted and enforced upon the employees to increase production and adhere to delivery schedules, for G.E.'s profit, is a memo from Supervisor Coke McLamb to Chemet Lab Manager Preston Winslow, dated 10/21/83, attached hereto as App. 5.
That memo j
shows that management knew that Chemet Lab personnel felt under l
inordinate pressure to cover up OAL and OCL results and to release only results " acceptable" under " biased" standards i
established "in order to satisfy production oriented egos."
Yet the violacions documented in these reports all continued after that date.
d 4
Moreover, after NRC Safeg.uards Engineer, Ed Clay, on December 3, 1984, discovered chaotic contamination in the off-Rad-Safety-inspection-limits isotopic room, the room in which the LEA measurement system is located, and vast contamination on a wet lab Gall, floor and work benches, management's so-called " clean up" effort was designed to " cover up" rather than " clean up."
A portion of the flooring in the
~
lab was ripped out, but it was found that the foundation 13 -
1
._____._.-,.r
actually was " hotter" than the floor.
The foundation was not torn out, instead, a new floor was laid on the " hot" base.
G.E. personnel worked overtime all night to clean contamination from the wall.
They did not succeed in removing a substantial portion.
Instead of stripping the plaster, McLamb instructed the workers to paint over the still heavily
. contaminated wall.
A Rad Safety man observed that NRC would require that the paint be removed, and effective action taken to remove the contamination.
When Ed Clay asked supervisor Sutton why they had painted the wall, he replied "to cover up rust spots."
(Emphasis added.)
Clay apparently swallowed this lie, because he did not require that the paint be removed.
One employee, having been alerted to the pre'sence of excessive contamination everywhere in the Chemet Lab, on December 5, 1984, inspected six chairs on which employees sat virtually all day to perform their work.
He discovered they were " hot."
An employee asked McLamb what he was going to do about the hot chairs.
McLamb became agitated and angry, denied the chairs were " hot," and said, "whoever discovered they were hot had better clean them up."
1 4
We infer, although without putting Clay and BatAs under oath, and comparing their contemporary notes and the draf ts of I
84-15 and 84-16 they submitted to McAlpine with the final drafts of the reports in those cases that he signed on their l,
behalf, we are obviously unable to: prove, that the reason I
i i
McAlpine signed those reports when Clay and Bates were out of f
town is that they may have objected, had they seen those reports, to sign such a " white wash."
McAlpine's motive for J
playing down the findings is self-evident.
He was in charge of investigators and his investigators should have uncovered the obvious defects and deficiencies in health safety protections over the years before Mrs. English made her changes.
He was covering up to save his own skin, and to disguise the immunity he had unlawfully give G.E.
over the years.
D.
Low Severity Levels Were Illegally Assigned To the Violations Found and Which Should Have Been Found We reiterate that, whether intentional or deliberately careless, management's disregard for proper implementation of G.E.'s radiation protection systems defeated NRC's entire i
regulatory safety program, and must, therefore, be treated as ene most serious possible violation.
The NRC Rules recognize (49 F.R.
8588) that "the severity level of a violaticn may bc I
increased if the circumstances surrounding the violation involve careless disregard of requirements, deception or other l
indications of willfulness."
(Emphasis added.) Without considering the pending allegations of G.E. deception and other indications of willfulness,* top management's careless disregard for " implementation of the radiation protection system" is itself willful breach of ALARA and of each and every
" requirement" which was not observed.
Because G.E.'s found actions frustrated not only a single protection system, but l
l L
~
i
)
NRC's entire radiation protection function, it is necessary to consider all together, and to " aggregate" all violations which were, or as herein shown, should have been, found, before assigning them a severity level.
Id.
Applying the " relative importance" and "significant regulatory concern" standards, 49 I
F.R.
8588, the violations should all have been assigned Severity Level I, and Civil Penalties of multiples of $100,000 per day assessed for the entire period, thus far unascertained, of management's " careless disregard for implementation of the
~
radiation protection system."
Id. at 5889-5890.
NRC's policy on " Civil Penalties" states (49 F.R.
8589):
l "NRC attaches great importance to comprehensive licensee programs for detection, correction, and reporting of problems that may constitute, or lead to violation of regulatory requirements."
4 Eacause that is so (id.)
" ineffective licensee programs for problem identifiction or correction are unacceptable.
In cases involving willfulness, flagrant NRC-identified violations, repeated poor performance in ag area of concern, or serious breakdown in management -
controls, NRC intends to apply its full enforcement authority * * *."
At minimum, the " careless disregard" violation should i
have been assigned severity category II, for that violation disabled
(,id., at 8591, B, 1), "a system designed to prevent or mitigate serious safety events [from] being able to perform its intended [' function. "
In G.E.'s case, however, several systems were disabled.
I L
NRC states, at 49 F.R.
8590, B(3), that:
"to focus on the fundamental underlying causes of a problem for which enforcement action appears to be warranted, the cumulative total for all violations which contributed to or were unavoidable consequences of that problem may be based on the amount shown in the table for a problem of that Severity Level, as adjusted.
If an evaluation of such multiple violations shows that more than one fundamental problem is involved, each of which, if viewed independently, could lead to civil penalty action by itself, then separate civil penalties may be assessed for each such fundamental problem.
In addition, the failure to make a required report of an event requiring such reporting is considered a separate problem and will normally bg assessed a separate civil penalty, if the licensee is aware of the matter that should have been reported."
Under this test, the " laxity" violation should have been assigned Severity Level I, under Supplement IV, " Health Physics," A, 1,2,5 (,id. at 8592), because it disabled management from ascertaining and reporting how much radiation exposure a worker was subject to.
(Cf.
"B, Severity II (6),
and C. Sevetity III, 7-9).3/ Severity IV and V were arbitrarily and illegally assigned by McAlpine, Barr and Stohr to save their own skins and to justify their historical nonfeasance against G.E.
3/
Under Health Physics, Supp. IV, Severity III level is assigned (id. 8593, par. 9) to:
"9.
Cumulative worker exposure above regulatory limits when such cumulative exposure reflects a programmatic, rather than an isolated weakness in radiation protection;"
(Emphasis added.)
l.
_,,n
(
s l
E.
The " Management Disregard" Conclusion Is Supported By Subsidiary Findings in 84-17 Par. 4 (f), pp. 5-6 of 84-17, finds that the l
l allegation that " Radiation Safety Personnel were lax on i
monitoring for contamination and requiring cleanup * *
- was 1
partially substantiated."
The allegation specified (id.):
" Radiation safety people * *
- do not know what to look for."
The report identifies some sources of licensee's obligations in this area.
l
" License Condition 9 requires that licensed material be used in accordance with statements, 5
)
representations and conditions of Part I of the licensee's application.
Part I, Section 3.2.4.6 discusses the minimum frequency, action limits for L
removable surface contamination, and maximum delay
- permitted in initiating decontamination action.
Plant Procedure Nuclear Safety Instruction 0-6.0, 4
j Rev. 14, Contamination Measurement and Control, provides the guidelines for the conduct of the contamination measurement program, evaluation and documentation of the results and the required action based upon the contamination survey findings."
(Emphasis added.)
The section does not mention the obligation, delegated by management to Rad Safety, to make accurate " surveys," 10 CFR S 20.201, although in "n" at p.
13, the Inspector acknowledges i
l that management is obliged under 5 20.103(a)(3), to use i
" suitable measurements."
Nevertheless, the Report concludes "no violations or deviations were identified."
l!
What the Report calls " partial substantiation" are the following findings:
i;
"[s]urveys performed by the radiation safety
=
i
' technicians are generally in the same locations which are often not the areas with the highest i
potential for becoming contaminated.
The inspector stated that the licensee should familiarize the t,
4
radiation safety technicians with the operations in the CHEMET Lab so that they can ensure that the survey those areas where the potential for spi s
exist (sample preparation area, weighing area, etc.).
Random surveys for contamination should be performed at least daily and detailed surveys of the entire lab should be performed weekly since the licensee utilizes the same administrative limits for contamination as are required for uncontrolled areas and there is a greater potential for a contaminating event."4/ (Emphasis added.)
In short, Rad Safety inspectors monitor frequently enough, but only in the wrong places.
In addition, G.E. uses improperly excessive administrative limits for contamination.
Thus, the results of Rad Safety inspections and surveys are utterly useless for NRC's intended purpose.
Like the one air sampler in the main work area of the Chemet Lab (par. 5, pp. 17-18), these procedures provide an illusion of radiation safety protection which bel:cs reality.
At p.
13, first sentence, the Inspector found:
"The licensee uses an assigned airborne exposure value derived from the time spent in the work area to determine compliance with 10 CFR 20.103(b) and to calculate the internal dose assigned to the individual."
The inspector does not compare the performance of Rad.
i l
Safety Inspectors, or G.E.'s use of improper administrative f/
Under Supp. IV, Health Physics, Par. 10 assigns to severity Category III, " Conduct of licensee activities by a technically unqualified persons."
If we accept the Inspector's inference that Rad Safety personnel did not know where to look for contamination (rather than the fact that management instruc(ed them to shut their eyes) (p. 17, last par.) the inescapable conclusion is that the Rad Safety Inspectors were
" unqualified" or inadequately trained under 10 CFR S 19.12, and j
S 20.206.
-l
j I
limits for contamination, with the obligations imposed by the documents he cites.
Moreover, as noted, the obligations i
imposed by 10 C.F.R.
S 20.101-103, and particularly by 5 20.103(a)(3) and (b)(2), are not considered in this connection.
Only in another connection does the Report j
acknowledge the obligation imposed by 10 C.F.R.
S 20.103(a)(3), upon every licensee, to "use suitable measurements of concentrations'of' radioactive materials in air for detecting and evaluating airborne radioactivity in restricted areas."
The ALARA obligation imposed by S 20.103(b)(2) is never mentioned.
The Report shows that the Inspector merely undertook to instruct or counsel management as to what it should do in the future, as if management, by its failure to do what it knew or must have known was required by its license and by law, had not viulated any legal obligation.
The Inspector's assumption, albeit unarticulated, is that management did not know what it should have done, and, therefore, was not culpable and merited instruction.
That assumption is utterly false, as we now demonstrate.
NRC was told by Mrs. English and other employees a long time ago that G.E. management, as well as'the Chemet Lab employees, knew that the isotopic room was the " hottest" spot in the lab.
She had never smp.n a Rad Safety inspector in that room.
On December 3, 1984, NED's Ed Clay inspected the Chemet Lab in the company of Coke McLamb, Chemet Lab supervisor, and Earl Rouse, Safety.
P
Technician.
Ed Clay instructed Rouse to accompany him into the Isotopic Room, where they discovered enormous visible contamination.
Two days later, Bob Torres, Manager of Rad Safety, asked Rouse "Why were you investigating in an unassigned area?"
He replied, "because NRC asked me to do it."
This incident was reported to Mr. Bruno Uryc, Region II, Supervisor of Investigations.
Torres' admission that the isotopic area was " unassigned," and his displeasure over its entry by a Rad Safety inspector, demonstrates that G.E.
deliberately concealed from Rad Safety and forbade monitoring of the hottest spot in the lab.
So much for the pretense that G.E.'s " careless disregard" was innocent!
On the contrary, what Torres' questioning of Rouse proves is that G.E.
fraudulently concealed from NRC that'its Rad Safety' inspection
~
system, like its air monitoring system, its body count system ano its compulsory self-frisking system was a fraud.
This requires that the violations be assigned Severity Level I, under " Miscellaneous matters,"
1.,
2, 3; 10 CFR S 21.21(b)(3)(iv).
F.
The Inspector's Finding No. 84-17, p. 6 That G.E. Has No Policy Requiring Notification'of Radiation Safety in the Event of a Spill In the Lab" Is Demonstrably False The Inspector does not point to any G.E.
document as the source of this finding.
Obviously, he must have accepted G.E. management's representation to this effect.,
--m
~
Official G.E. documents belie the finding.
G.E.'s " Job Hazard Analysis Chemet Lab-970" dated 10/1/81, revised 3/1/84 and 3/1/85, App. 6, hereto, provides:
6.
Clean spills immediately and notify radiation protection."
(Emphasis added.)
G.E.'s " Course for Hourly Workers," in effect since 11/13/72, when Mrs. English began working in the lab (App. 7, hereto, p. 4), details the steps to follow in the event of a spill:
" Step 2:
Warn other personnel - Call Radiation Protection."
(Emphasis added.)
Page 5, 6 I, says "For a know[n] or possible radioactive spill, minimize its spread and notify Radiation Protection."
(Emphasis added.)
Had the Inspector found that G.E. did have the policy it disclaimed, he could not have escaped finding that its widespread violation, testified to by Mrs. English and acknowledged by G.E. management, was a serious and major violation.
Nor, had he inspected the documents Mrs. English offered in proof of the policy, could he have failed to find G.E.'s denial fraudulent.
G.
The Inspector's Finding h, p. 7, That G.E.
"Does Not Have a Procedural Requirement, Nor Do They Rope Off Or Otherwi.se Mark Contaminated Areas" Is Demonstrably False The Inspector found that while Mrs. English's complaint was factually substantiated, it constituted no violation.because "the marking off of contaminated areas is not required by NRC regulations, license conditions or licensee procedures."
(Emphasis added.)
The Course for Hourly Workers i,
n,.
(App. 7, infra), p. 4, par. 5.
B. specifies " procedures to be followed after a spill of material (liquid or solid)" and details the " basic steps":
" Step 1.
Stop the spill Step 2.
Warn other personnel - Call Radiation Protection Step 3.
Isolate the area."
(Emphasis added.)
Page 2, B, 1 (id.) provides:
" Contaminated areas [should be]
roped off - control signs."
(Emphasis added.)
The Course Outline defines " Dead Zone" as a " safety zone, usually 12" in width, surrounding all limit areas.
It is designated with a 2" wide red tape."
G.E.'s Criticality Safety Control Chemet Lab, C.
2.0-QA-201, in effect since at least 1976 (App. 3, hereto),'
- p. 1, 2.3.2 provides " Dead zone - a safety zone shall be marked with a two inch wide red border surrounding all limit areas."
Par. 4.5.1, p. 4, says " Stay 12 inches away from any limit area."
Had the inspector consulted the relevant documents, instead of naively accepting management's fraudulent verbal misrepresentation, he could not have failed to find wilful violation of the license requirements on both the substantiated practice and management's misrepresentation to him.
H.
The Inspector's Conclusion (p. 8, 1) That Allowing " Heated Uranium Scintered Pellets To Cool In Uncovered Containers Outside a Vented Hood" Is Neither Prohibited Nor "A Radiological * *
- Safety Problem" Is False s.
The only sources the Inspector claimed to have examined in connection with this allegation are identified in.
A
the first three lines of the second paragraph of his
" Discussion."
He also missed the factual point.
The cooling scintered pellets emit visible particles of uranium dust, which settles on counters, instruments, etc., where they are inescapably inhaled and ingested by lab personnel through breathing.
When originally established, the system called for covering the stainless steel container into which the pellets were dumped with a air-tight cover.
Lab personnel were told by supervision that the covered containers were to be placed under a vented hood.
The covers disappeared after a time and the open containers were never placed under a vented hood.
The supervisors' instructions to cool scintered pellets under a vented hood are legally binding on G.E.
under its license.
l The Inspector looked for rules requiring cooling material containing uranium under vented hoods in the wrong P ace.
Safety Opereting Procedure, No. 0.3.4, issued 4/2/73, l
l
- p. 2, H, App. 8, infra, provides:
"All compounds of uranium that could become airborne shall be handled inside of hoods with air flow of 80-120 LFM through the apertures.
Examples of this is (1) Opening of powder sample containers (2)
Crushing of pellets, weighing, etc., (3) Dumping and compositing samples for return to Shop Operations, (4) Dissolution 'and concentration of uranium samples by heating."
(Emphasis added.)
COI Instruction 4409, April 9, 1982 (App. 9, infra), p. 3, pt.
3.11,.pfovides:
" Remove tray from microwave oven and place in
hood to cool."
(Emphasis added.)
Nuclear Safety Release 1CR04, Rev. 3 issued April 22, 1982, (App. 10, infra),
provides (p.
1, pt. 5), "take extra care to prevent airborne contamination."
Pt.
1, p. 2, provides:
" Conduct all activities which could generate airborne contamination * *
- under * *
- vented hoods."
(Emphasis added.)
4 Analytical Test Method 5.2.9.6. Rev. 2, dated D,c.
1, 1979 (App. 11, infra), states (pt. 5.1, p. 2):
" Proper radiation protection precautions should be taken to prevent inhalation of solid or liquid samples containing uranium during all handling operations."
Appendix to NRC Regulatory Guide 8.29, " Instruction Concerning Risks from Occupational Radiation Exposure,"
i undated, but published after 1980, which was distributed to all Chemet Lab personnel ( App. 4, infra), explains, pp. 12-13:
"The uptake of radioactive materials by workers is generally due to breathing contaminated air.
Radioactive materials may be present as fine dust or gases in the workplace atmosphere.
The surfaces of equipment and workbenches may be contaminated.
Radioactive materials may enter the body by being breathed in, taken in with food or drink, or being absorbed through the skin, particularly if the skin i
is broken.
"After entering the body, the radioactive material will migrate to particular organs or particular parts of the body depending on the biochemistry of the material.
For example, uranium will tend to deposit in the bones where it will remain for a long time.
It is slowly eliminated from the body, mostly by way of the kidneys.
Radium s
will also tend to deposit in the bones.
Radioactive iodine will seek out the thyroid glands (located in the neck) and deposit there.
"The dose from these internal emitters cannot be measured either by the film badge or by other ordinary dosimeters carried by the worker.
This means that the internal radiation dose must be separately monitored using other detection methods.
" Internal exposure can be estimated by measuring the radiation emitted from the body or by measuring the radioactive materials contained in biological samples such as urine or feces.
Dose estimates can also be made if one knows how much radioactive material is in the air and the length of time during which the air was breathed.
(Sic!)
" Internal exposure is controlled by limiting the release of radioactive material into the air and by carefully monitoring the work area for airborne radioactivity and surface contamination.
Protective clothing and respiratory (breathing) protection should be used whenever the possibility of contact with loose radioactive material cannot be prevented."
(Emphasis added.)
In short, contrary to the Inspector's conclusion,
" cooling scintered pellets in the open and not in a vented hood" is "a radiological * *
- safety" hazard.
It is not only a violation of ALARA, but of management's obligation under 10 I
CFR S 19.12, to avoid " unnecessary exposure to radiation or to radioactive material," (emphasis added), as well as of the l
specific rules quoted above.
It is especially noteworthy that dosage from " internal emitters cannot be measured.either by the film badge or other ordinary dosimeters carried by the worker."
Since there was no air-intake monitor over the' uncovered containers, and Rad Safety did not " carefully" monitor the cooling area, if it monitored that area at all, G.E. had no way of measuring l 1
the air contaimination content of the cooling area or the dose of contamination to which workers in the Chemet Lab were subject as a result of cooling the scintered pellets in the open, except by measuring samples of urine.
Incredibly, G.E.
never made any tests for contamination by examining feces.
G.E. took care to assure that these measures would be unrepresentative, inter alia, because it took body samples only i
after the absence of the worker for several days from the lab and did not make or keep required historical records.
The violation is of the highest severity level.
I.
The Inspector's Conclusion (pt. J, pp. 8-9)
~
That "Neither NRC Regulations, Nor License Conditions" Prohibit " Dichromate Titrations Outside A Hood" Is False The Inspector admits that G.E.'s referenced Manual (p. 8, par.
1, " Discussion"), requires that " proper radiation protection" should be taken to prevent inhalation or ingestion of * *
- uranium during all handling operations."
He also found that the titration did release not only acid fumes but radioactive uranium fumes into the atmosphere.
He discounted the latter on the ground that the " airborne radioactivity hazard" was minimal.
The only evidence he offered for that was the weekly radiological contamination surveys performed by Rad Safety in 1984 did not " identify contamination above the action level' at this work station."
Given.tlh Inspector's findings under (f), p. 6, that Rad Safety inispected only in the wrong places; used inappropriate I.
,,e
measures for " administrative limits for contamination," and under 5, p. 17, that review of contamination surveys during 1984 showed contamination above G.E.'s allowable limit, this finding is utterly unsupportable.
The Inspector concluded that no violation was shown, because he found no " specific requirement that dichromate titrations should be done under a vented hood."
The demand for such specificity is misguided.
It overlooks the general requirement that licensees use all " proper" and "necessary" means of protection against airborne radioactivity hazards, which G.E. was therefore required by ALARA and its license to do.
Performance of dichromate titrations under a vented hood is the most obvious measure imaginable to reduce the hazards of airborne uranium contamination.
G.E. violated the law by failing to do this.
The Inspector also found that because "the procedure contains no precaution concerning the inhalation of acid fumes that evolve from the titration," G.E. was not obligated by its license to take any precautionary action against that danger.
But he overlooked Part 20, App.
B, footnote 4.
The authorities cited in G above apply to handling of all radioactive materials which emit radioactive fumes or dust.
The Inspector ignored all of these obligations, which, of course, are legally binding on G.E.
Moreover, a memorandum s:
dated-Nouember 9, 1981, from Bowman to Hendry (App. 12, infra),
states that " analyses of the 9 air sampler filters in the ADU _
vaporization room" showed airborne contamination levels " exceed 300 times the maximum permissible concentration."
How did it get that way if weekly Rad Safety surveys were indicative?
In short, the substantiated allegations of pars. 4 (i) and (j) establish that unknown, unmeasured and unmeasurable by G.E.'s processes, amounts of radiation contamination were inhaled or ingested by wet lab employees on a daily basis.
Moreover, the amounts were not timely measured by full body counts.
Is this not inescapably a Severity Lev 4 I violation under Supplement IV, A, 49 F.R. 8592?
END OF CHAPTER I More To Follow Respectfully submitted, f
1d uL
/J Yg i
Mozart G. Ratner Suite 610 1900 M Street, N.W.
Washington, D.
C.
20036 (202) 223-9472 O HwN74 7
(g/
Arthur M.
Schiller Suite 1300 1000 Connecticut Avenue, N.W.
Washington, D.
C.
20036 (202) 331-8508 Counsel for Vera M.
English February' 28, 1985 i t 4
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UNITED STATES e
e NUCLEAR REGULATORY COMMISSION
,{
y W ASHINGTON, D. C. 20555 8
JAN ; O 1985 s...../
Mozart G. Ratner, Esq.
Suite 610 1900 M Street, NW Washington, DC 20036
Dear Mr. Ratner:
This letter acknowledges ~ receipt of the Petition of Ms. Ven M. English filed on her behalf by yourself and Mr. Arthur M. Schiller on December 13, 1984. The Petition makes reference to fi'e Inspection Reports reviewing v
activities at the Wilmington, North Carolina facility of the General Electric Company (Licensee). The Petition asserts that these Inspection Reports are deficient for failing to identify a variety of deviations and violations in the activities of the Licensee at its Wilmington facility.
The Petition requests that all five Inspection Reports be withdrawn, that new Inspection Reports be issued correctly documenting the alleged violations and deviations at the Wilmington facility as identified in the Petition and its attachments, that Notices of Violation be issued, and that the Nuclear Regulatory Commission commence appropriate enforcement action, including the assessment of civil penalties, consistent with the Commission's General Policy and Procedure for NRC Enforcement Actions, 10 CFR Part 2. Appendix C, as revised, 49 Federal Register 8583 (March 8, 1984). The Petitioner also requests the institution of proceedings pursuant to 10 CFR 6 2.202 and the scheduling of hearings on the matters ra'ised in the Petition.
The Petition, which has been referred to my Office for action, is being treated under 10 CFR 2.206 cf the Commission's regulations. The NRC staff will review the Petition and I will issue a formal decision with regard to it within a reasonable time. A copy of the notice that is being filed for publication for the Office of the Federal Register is enclosed for your information.
Sincerely, 4mesM.Tay1
, Deputy Director Office of In ection and Enforcement
Enclosure:
as stated cc w/ enc 1'.:-
Arthur M. Schiller, Esq.
Suite 1300 1000 Connecticut Avenue, NW Washington, DC 20006 General Electric Company Appendix 1 Wilmington, NC
3 J..
[7590-01]
NUCLEAR REGULATORY COMMISSION DocketNo.[70-1113]
GENERAL ELECTRIC COMPANY (Wilmington, North Carolina Facility)
RE0 VEST FOR ACTION UNDER 10 CFR 2.206 REGARDING ACTIVITIES AT THE WILMINGTON, NORTH CAROLINA FACILITY OF THE GENERAL ELECTRIC COMPANY Notice is hereby given that, by her Petition of December 13, 1984, Ms. Vera M. English (Petitioner) requests that the Nuclear Regulatory Commission review and withdraw ce-tain Inspection Reports whic5 allegedly improperly dismiss certain alleged violations and/or deviations associated with the activities of the General Electric Company at its Wilmington, North Carolina facility. The Petition requests that new Inspection Reports be issued properly documenting violations and deviations in the activities carried out at the Wilmington facility. The Petition also requests that the Commission issue Notices of Violation and take enforcement action as appropriate including the imposition of civil penalties.
Petitioner further requests the institution of proceedings ~ pursuant to 10 CFR 2.206 and the scheduling of hearings on the matters raised in the Petition.
The Petition is being treated pursuant to 10 CFR 2.206 of the Commission's regulations and appropriate action will be taken on the i
I w
e 1
1 -
. request withinsa reasonable time. AcopyofthePetitionisavai}gkle for inspection in the Commission's Public Document Room, 1717 H Street, N.W., Washington, D.C.
20555, and at the local Pubic Document Room for the Wilmington facility located at [ insert address ].
Dated at Bethesda, Maryland this 4 E'* day of January 1985 FOR THE NUCLEAR REGULATORY COMMISSION y
a:es M. Tay1
, Deputy Director 0 ice of I pection and Enforcement
[
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MDIO TO DISTRIBUTION - November 9, 1981 AMACEv. INT 2 G EN EH AL h ELiCTRIC em comu. 8*292-5748 ears.
September 17, 1981 copics.
er,s.
WILMINGTON MANUFACTURING DEPARTMENT asonssi. M/C J-02 sussect. ITEM OF INTEREST J. A. Long, General Manager Wilmington Manufaccuring.Cepartment FOLLOWUP CN UF6 GAS RELEASE As reported earlier, a UF6 qas release occurred Tuesday morning in the FMO vaporization area.
Although the release was well contained, the incident had to be reported to the NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> because of the time required for cleanup activities.
The reco : was made Nednesday morning within the required time neriod.
Subsequently, J.
P. O' Reilly, Director - USNRC Region II, called to inquire for mors information, including details of employee exposures, stack measurements, and site boundary conditions.
We supplied the information, which c'1carly indicated that there had been no exposures to employees or the public in excess of allowable limits.
It is apoarent that Mr. O' Reilly was concerned for the potential inquiry by the press or others, and he wished to be well crepared for it.
To the best of our knowledge, there has I
been no external interest in the incident.
a:
fj t ww E. M Lees, Mdager Quality Assurs: Ice 1
/sbm Appendix 2 9
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T;*,'LE : CRITICALITY EAF;TY CONTROL ISSUE DATED:
'I CHD:ET LAL g
l PAGE 1 07 5
, ISSUII:5 U..'IT Process Control Eng.
f.PP.'. OVALS :
1.0 PL'P.POEE l'O SCOPE The purpose of this procedure is to establish and outline the general criticality safety rules, practices, and precautions for the Chemet Laboratory necessary to ec ply uith AEC regulations, license requirements and General Electric policy to. protect the health of employees and cc=pany property.
Separate instructions are pre'ared for specific ecrh or operations uhere special requirements pertaining to criticality safcty cre necesscry. This precedure applies to the vet Chemistry Lch, the E ;:troscopic Lab, QC Corner, and the PCE Dispctchars Office.
2.0 DEFINITION 5 2.1 General
~~
Uranium enriched in the U-235' isotope to a acximum of 4.0 weight percent 'is a fissile caterizi and is processed in the fuels manufacturing shop.
It is capcble of undergeing a nucicar chain racction cuch the sama as in nuclear r:acter eithout bansfit of rcactor contrcls. Due to tha potentially lethal nature cf the rest.lting nuciccr radiation, physicci and procedural controls are estchlished to minimice the probability of such an occurrence.
Bacause fissila r.atorici is peccesstd in this plant, cll operations =ust be licensed by the Atenic Ener;y Cc missien. Due to tha nature of our license, procedures cas t b: ~ritten as part of the criticclity safety pregran and become a pcrt of the license.
The proceduras shall be strictly cdhered te in order to ec ply with the licerse requirements cnd to cerure criticclity safety in our c;crations.
2.2 Primary Concepts 2.2.1 Physical control-retains material in a specific location, operation, or geometry.
2.2.2 Adminstrative control-limite the caterial to a specific operation by approved procedures ONLY where physical controls are not practical.
2.2.3 Area Manager-the louest supervisory position fully responsible for the specific cetivity or functien eith thich the torn is associated (i.e., Manager Quality A::uren:r';.
2.3 Applicerions 2.3.1 Limit Area-an identified location in which uranium can be handled, processed, er stored in accordance with specific posted criticality c fety linitatienc. Lirit arccc for portable er,uipment shall ba tarhed u.ch L scite rcd lina :.
in:hss.ido.
2.3.2 Da:.J cen.-e sciety coao shall bc -.rhed eith a tuo inch uide red border
..croundin-r.il lin!t rant. Erm.iu. t hall rot be handled, stored, or Ur. nir-n ?1 1..cs threu:h. deci ccne'enly to
.. c. : a :-
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Appendix 3
}.-.C h_.. LU,,-
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i ISSU3 DATE 11:5TRUCTION to.
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SUPERSEDES
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1 TITLE: CRITICALITY SAFETY CONTROL ISSU5 DATED:
CFD;ET LA3
.l
%." 'f N.G2 2 OF 5 s
i
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2.3.3 Safe bctch-the allon bic quantity of uranium one may handle in any dne place in the ich is defined to be:
2.3.3.1 A total of 635 samples.
2.3.3.2 A total of 35 UO, fuel rods.
2.3.3.3 45 percent of a minimum critical mass.
1;0TE:
IN A VOLU'iE OF 23 QUARTS, A LIMIT OF 3.0 UEIGHT % U-235 IS
. ASSUMED IN SEITING THESE LDIITS.
2.3.4 Criticality limit sign-method of postin; limits HTd instructions concerning type of material to be handicd, type of criticality control for a epecific area.
Each saic latch controlled are t mus: have a criticality limit sign.
3.0 CT.IIICf.LITY SAFETY RESPONSI:ILITIES 3.1 I;cepen:1.bilities r s;t Q pre:clu c:-
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CHE;4ET LAB N;
pAGE 3 OF 5 i
3.1.3 The Manager, Chemet Lab shall correct and resolve all nuclear safety procedural deviations discovered by ES&L audits, requesting training, consultation, etc. cs necesscry.
4.0 PROCEDURE 4.1 The Spec Lab is limited to one safe batch.
4.1.1 All incoming scmples shall be placed into the slots in the marked drawers in the desh on the south call pf the room.
These slots hold a total of 635 samples. Do not store sa:ples anywhere else in the lab. Do not accept any more sc:.ples into the lab when the drawers are full.
y/4.1.2 In the hood recove as much uranium as necessary from each sample to
~
p3rform lab teres cc dir cted.
4.1.3 P.cturn the empty or partially empty containers to the drawers.
When testing is complete, c:ke the vial, rentining contents, and all recoved portians of the sample to the s::ple return can in tne wet lab.
Ch ::. paperrerb to assure s11 pcrtiens cf the sample are c: counted for.
NOTE: De not overfill the sc=ple return can.
Empty vials, i.e., those which h:ve only traca a cunt: cf uranius so that you ccn see through tha ratple vial ca; ba rauced or placed in plcstic bags in the net lab naar the hallucy for dis;ortl.
4.1.4 Inventory the lab'vechly disposing of any excess.
4.2 The Pet Lt.b is limited to three safe batches:
4.2.1 One of these is UO reds. Do not accept core than 35 rods into the 9
Uat Lnb. All rods ~shall be stored in the southwest portion of the ich.
4.2.2 One scfe batch is the sample return can located under the MICS Terminal.
4.2.2.1 Use a standard pail (23 quart pail). Do not overfill the can.
Store it in the limit area.
4.2.2.2 Weigh the can (or add the neight added if knoun) each time samples cre put in th: cen. Record the vei;ht en the sheet of the can; de not c::cced 44.5 Kg.
4.2.3 The other safe batch is at large throu2h the area cnd is centrolled by n'uabar of semplec. A tott.1 of 635 rarples in vials or in c2xieum 1 C:llen bottle's of liquids in any cerbinaticn constitutes ona rafa brtch.
L.l.a.1 Enter each r,rcup cf cr.ples on the Pat Lcb Sr.mple Sheet (E::hiti: 31 Da no t e:<co:.: : ru:. in tot:1 of 63.~ r:tyles.
Theca resples e
c a c r.et.. :. - -. o in ti.: ret inh c: Npt in the red t:tci.
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ISSU3 D?.TE INSTRU~TIO:4 NO.
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.u ISSU DATED-TITLE-CRITICALITY SAFETY CONTROL d
1
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CHEE T LAB l
PAGE 4 OF 5 l
4.2.3.2 In a hoed remove as much uranium as needed from the sample containere ena per_a.r. Acooratorv teste ne directec.
split portions of samples may likeuise be stored.at will in the area.
4.2.3.3 When through, dump samples:
If solids-into a beaker in either the sample receiving hood a.
or cac vacoizn_a asoc.
(A maximum or enree maximum ovo el becuers may be in each hood.).
b.
If liquids-into a caximum five gallon bottle. A maximum of onc bottic per hood as above.
c.
Place 5 pint bottles on t.ie tray near the hallway entrance to the icb.
4.2.3.4 Trcn:fer colids to th2 satple return can (.:zighing the basi;cr cud Odjectin ccn U:ight) and liquids to tha prcess arca as r.ced.f _.
4.2.3.5 Indiccte the number cf samples dumped on the vet lab sample sheet and figure th: balan:c. Check paperterk to assure all portiens of the split sa: pics have been dumped.
4.2.3.6 Inventory the lab weekly disposing of any excess.
4.3 The QC cornar is limited to cicht scie batches, seven en the ficor in the merked crecs, one in the hood.
4.3.1 Keep the seven cafe batchas en the floor in standaro roduct pails in the limit arces. Do not overfill the cans or double stack them er place sm:11er containers of uranium on them, etc. L'eigh the can with each addition (or if you know the weight being added just add
(
it) and record the neu weight on the sheet on the can. Do not c::cced 44.5 Kg. per can or 3.0 w/o U-235.
4.3.2 Flace incoming sample vicls nd liquids in eaximum 1 cc11cn c--tiin?rs fB ene no~' - 5 6., ticnaming, ana cisposing of samples using the preccdurc ft.r the wat7c5 n.'ve excen' Get en. or one seven a_nzt arcas may be~uicd for the sample iccucn can.
I e.
4.3.3. Laventcry weekly f ollouing the same proccdure as for the wet lab.
i 4.4 The hc11..sy it limited to one s fe 'r:tch.
F1cco t.11 inconin; st=ples and If.quido in c:::inet. 5,cclica cent.ciners in the 11.it avec oa the coun:cr.
Do no Cc.bic etech cc.r;1ce or bcgr. of samples. Do not ac:cpt sny rare
(
ceujlt..h n this crea 1; full.
- t: uit.
.:t.;t in trtncit in t d cui of thu ich c3 necccd.
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ISSUE D*TE INSTRUOTION NO.
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s TITLE CRITICALITY St.?ETY CONTROL ISSUE DATED:
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f PAGE 5 0F5 l
4.5.2 The following may be transported together as one intransit unit.
a.
Any number of loose sample vials b.
One bag of sample vials c.
One 5 gallon (23 quart) or smaller vessel d.
Six capped fuel rods 4.5.3 Only cne intransit unit may be moved per person per trip. Do not leave intransit units unattended.
4.6 Festing, labeling, and marhing 4.6.1 All areas shall be pected using the ferrat shoun in Exhibit-2 to re'flect the licits given in this procedure.
4.6.2 Tellow cil posted instructions. Phan in doubt refer to this procedure fer details or contact ycur superviser.
4.6.3 All cent:incre of uran,ium shall be identified with enrichment tape.
4.6.4 Obrerve limit arca cnd dead ene m: rhin:.s fer:
a.
Rod ctorene crc -limit area cnd dead zone around the southwest portion o~ the wat lab.
b.
Each product pail storage arca-a linit area around each pail ar.d a deed zen cround each pail or group of p 11s.
c.
QO corner-dead zone markings around the entire QC corner.
4.6.5 Do not store esterici in dead zoner. L'renium may pass through a dead zone only to enter or leave c limit area.
4.7 Encrgency Situationc (cce E::hibit 3) 4.7.1
!!uclect t'arning alcrn will crund a continuous loud tone in the event gf,c criticality cccident.
4.7.2' Ell perconnel chall cvecuate ac quichly cs pessible to the nearest exit.
4.7.3 Co directly cc:y fron th: building cnl proceed to the staging arca rh:tT. en the ettcched dr.r.gre.n.
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I; U.S. NUCLEAR REGULATORY COMMISSION APPENDIX TO REGULATORY GulDE 8.29 INSTRUCTION CONCERNING RISKS FROM OCCUPATIONAL RADIATION EXPOSURE This instructional material is intended to provide the The biological effects that are known to oscur after eser with the best available Laformation concerning what is exposure to high doses (hundreds of rems ) of radiation are 3
currently known about the health risks from esposure to discussed early la the document; discussions of the esti-lonizing radiation.8 A quesdon and answer format has been mated risks from the low occupational does (<5: ens per used. The questions were developed by the NRC staff in year) follow. It is intended that this laformation will help consultation with workers, union representatives, and develop an attitude of healthy respect for the riska asse-licensee representatives experienced in radiation protection cisted with radiation, rather than unaccessary fear or lack traming. Risk estimates have been compiled from numerous of concern. Additional guidance is being or will be devel.
sources generally recognized as reliable. A bibliography is oped concerning other topics in radiation protection inclu'ded for the user interested in further study.
traanang.
s e
e e
e 1.
Whatis meant by nisk?
assume that.some health effects do occur at the lower expo-mare levels.
Risk cm be defined in seeral as the psobability (diance) cf injury, illassa, or death resulting from some activity.
J.
Wher is meant 47 prompt effecar, deisped effees, and However, the perception of risk is affected by how the 8'#N*##I indrvidual views its probability and its severity. The intent af this docurnenzas to provide assimates of andexplain the
- a. Prompt effectsareobservableshortlyafterreceiving basis for posable risk of injury, illness, or death resulting a very tarse dose in a abort period of time. For example,a whole-body
- does of 450 rems (90 tienes the annual dose from occupational radiation exposure. (See Questions 9 and 10 for estunates of radiation ask and comparisons with limit for routine occupational esposure) la an hour to as avenge adult will cause vomiting and diarrhea within a few cther types of risk.)
hours; loss of hair, fever, and weight loss within a few 2.
What stv the possibfe heefth effeest of empeantre #8 weeks; and about a 50 percent chance of death within 60 days without medical treatment. "
.mdaarien?
- b. Delayed effects sich as cancer may occur years Some of the health effects that exposure tozadiasian after exposure to radiation.
may cause are cancer (including leukemia), birth defects i the future children of suposed parents, and cataracts.S
- c. Genetic effects can occur when there is radiation
. These effects (with the exception of genetic effects) have
<iamese to the genetic material. These effects may show up been observed in studies of medical radiologists, uranium as birth defects or other conditions in the future children of miners, radium workers, and radiotherapy patients who the exposed individual and succeeding generations, as have received large doses of radiation. Studies of people demonstrated la animal esperiments. However, escess exposed to radiation from atomic weapons have also genetic effects clearly caused by radiation have not been provided data on radiation effects. In addition, radiation observed in human populations exposed to radiation. It has effects studies with laborotory animals have provided a been observed, however, that radiation can change the large body of data on radiation induced health effects'
,,,, g,,,g,,g the human body. Thus, the possibility including genetic effecu.
exists that genetic effects can be caused in humans bylow doses even though no direct evidence exists as yet.
The observations and studie: mentioned above, however, 4.
In teorker protection, mAieh efferis are ofmost cearem involve levels of radiation esposure that are much higher to the NAC7 (hundreds of rems) then those permitted occupationally t: Jay ( <$ rems per year). Although studies have not shown a The main concern to the NRCis the delayed incidence cause effact relationship between health effects and current of cancer The chance of delayed canceris believed to depend levels of occupational fldiation esposare, it is prudent to 3.tetects differ fr.m othet vedisti.n effeeve in thet e sevee6a
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. en how much radiation exposure a person gets; therefore, One theory is that radiation can damage chromosomes in a every reasonable effort should be made to keep exposures asu, and the enti is then directed along abnormal powth j,,,. low, pattems. Anc,ther is that radiation reduces the body's mormal resistance to existing viruses which can then multiply 3.i *,,
Immediate or prompt effects are very unlikely since and damage cells. A third is that radiation activates an
] *.*"% serious radiation accident. Accident rates in the radiation cous causing them to grow rapidly.
1arge exposures would normany occur only if these wasa a existing virus in the body wiuch then atacks seriaal ladustry have been low, and only a few accidents have sesultedin expostros enceeding thalegallimits.The probabil-W tat is known is that, la groups of highly exposed 1
Ity of sonous genetic effects in the future children of people, s higher than normalincidence of caneer is observed.
workers is estimated in the BEIRs aport, based on animal Higher than normal rates of sancer ces also be produced in studies, at less than one third that of delayed cancer (5 45 laboratory amiraals by high levels of radiation. An increased genetic effects per million rems compared to 160 450 incidence of cancer has not been demonstrated at radiation i
sancer cases). A clearer understanding of the causeeffect levels below the NRCliraita.
l 1 relationship between radiation and human genetic effects l
wGI not be possible until additional research studies are 7.
W I rweefwe a redderson dose, does sket meer Iser l
sompleted.
sersein se ser esseert i
i J.
Wher de the diffennae Aerween acuse and chronde Not at all. Everyone sets a radiation doss overy dsy (see l
espesure/
Question 25), but most people do not get cancer.Even with doses of radiation far above legal limits, most individuals Acute radiation asposure, which causes prompt effacss will experience no delayed consequences. There is evidence and may also cause delayed effects,usuauy refers to a large that sorne radiation darnage can be repaired. The danger
, dose of radiation received in a short period of time; for from n distion is much like the dangi r from adgarette smoke.
exarnple, 450 rems received within a few hours orless. The Only a fraction of the people who breathe cigarette smoke effects of acute exposures see well known from studies of set luas cancer, but there is good evidence that smoking radiotherapy pationts, some of whorn received whole-body increases a person's chances of getting lung cancer. Similarly, doses; atomic hornb victims; and the few accidents that there is evidence that the larger the radiation does, the have occurnd in the early days of atomic weapons and larger the increase in a person's chances of getting cancer.
l- -
reactor development, industrial radiography, and nuclear Aiel procesang. There have been few occupationatincidents Radiation is like most substances that cause sancerin i
that have sesulted in large exposares. NRC data indicate that the effects can be seen clearly only at high doses.
i that, on the average, I accidental overexposure in which Estimates of the risks of cancer at low levels of exposure j
any acute symptoms are observed occurs each year. Most are derived from data available for exposures at high dose l,
af these occurla indMal'adiography and involve exposures levels and high dose reten. Generally, forTadiation protection af tas nanos ratner taan tae waose body.
purposes these estimates are made using the linear mode!
(Curve I in Figure 1). We have data on health effects at high i
Chronic esposure, which may cause delayed effects but doses as shown by the soJd line in Tigure 1. Below about, not prompt effects, refers to smau doses received repeatedly 100 rems, studies have not been able to accurately measure over long time periods; for example, 20100 mrom (a the risk, primarily because of the small numbers of exposed l
mrom is one thousandth of a rem) per week overy week for psople and because the effect is small compared to diferences I
several years. Concern with occupational radiation risk is in the normalincidence from year to year and place to place.
primanly focused on chronic exposure to low levels of Most scientists believe that there is some degree of risk no radiation over long time periods.
matter how small the does (Curves I and 2). Some scientists believe that the risk drops off to aero at some low dose d.
New does radiation eeuse seneer?
(Curve 3), the threshold effect. A few believe thatrisklevels off so that even very small doses imply a significant risk How radiation causes cancer is not well understood.
(Curve 4). The majonty of scientists today endorse either It is impossible to te!! whether a given cancer was caused by
- the linear model (Curve 1) or the linear quadratic model radiation or by some other of the many apparent causes.
(Curve 2). The NRC endorses the linear model (Curve 1),
Hswever, most disesses are caused by the interaction of which shows the number of effects decreasing as the dose several factors. General physical condition, inherited traits, decreases, for radiation protection purposes, j
age, sex, and esposure to other cancer cauang agents sich as cigarette senoke are Pfbw possible contributing factors.
It is prudent to assume that smaller doses have some chance of causing cancer. This is as true for natural cancer, i
j vousers such as sunlight and natural radiation as it is ihr those that are man made such as cigarette smoke, smos, atd s
man made radiation. As even very small doses may entsil NeYNrtYe#*d' ten
$EEY.NoYAf*=*n*eE*ieIo some small risk, it follows that no done should be taken
{
sh:
IenT.as**e E [e# " N e 7 N **d' Ee Y or'o*d*7 U.*e die without a reason. Thus, a principle of radiation protect >n, a pe s.
'is to do more than merely meet the allowed regulaton I
8.29-4 i
f, i.-
4 u2
om espesure to redierient ofredieuoa4neesedesieer. la 1956, the Nationa! Academy otSciences established I rem, we cr,uld esumate that three would develop cancer advisory committees to considerTadiation riska. The first of becauas of that exposure, although the actual number could these was the Advisory Committee on the Biological Effects be more orless than three. (f Atomic Radiations (BEAR) and more recently it was renamed the Advisory Committee on the Biological Effects The American Cancer Society has reported that approsh tf lenizmg Radiation (BEIR). These committees have mately 23 percent of all adults in the 20 to 65 year age periodicaHy reviewed the extensive research being done on bracket will develop cancer at some time from au possibla Ce health effects of loniains radiation and have published sauses such as smoking, food, alcohol, drugs, air poUutanta, estimates of the risk of cancer from exposure to radiation and natural background radiation. Thus in any group of (1972 and 1980 BEIR reports). The IntemationalCommission 10,000 workers not exposed to radiation on the job, we can on Radiological Protection (ICRP)and the National Council expect about.2,.500 to develop cancer. If this antire group on Raalataan trotecuon and Measurement (NCRP)are two of 10,000 workers were to receive an occupational radiation other groups of scientists who have studied radiation effects dose of I rem each, we couldastimate that three additional and published risk estimates (ICRP Publication 26,1977). cases might occur which would give a totalof about 2,503. These two groups have no goven. ment affiliation. In This means that a 1 rem dose to each of 10,000 workers addition, the United Nations established an independent might increase the cancer rate from 25 percent to 25.03 study group that published an extensive report in 1977, percent, an increase of about 3 hundredths of one percent. including estimates of cancer risk from loniains sadiation (UNSCEAR,1977). As an individual, if your cu mula tive occu pation al radia. i tion dose is ! rem, your chances of eventually developing Several individual research groups cr scientists such as cancer during your entire lifetime may have increased from AUce Stewart, E.S. Gilbert, T.F. Mancuso, T.W. Anderson, 25 percent to 25.03 percent. If your lifetime occupational 13 name a few, have published studies concerning low-level does is 10 rems, we could estimate a 25.3 percent chance of i radiation effects. The bibliography to this appendix includes developing cancer. Using a simple linear model, a lifetime several articles for the reader who wishes to do further, dose of 100 rems may have increased your chances of study. The BEIR.80 report includes analysis of the work of cancer from 25 to 28 percent, many independent researchers, The normal chance of developing cancer if you receive P. What are the estimeres of the risk e/cencerfrom pedia. no occupational radiation dose is about equal to your chance ries taposuref of getting any spade on a single draw from a fuU deck of playing cards, which is one chance out of four. The addh The cancer risk'est'Imates(developed by the organlaa. tional chance of developing cancer from an occupational tiins identified in Question 8) are presented in Table I, exposure of I rem is less than your chances of drawing an ace from a fuu deck of cards three times In a row. In an effort to explain the significance of these estimates. we will use an approtimate average of 300 escess cancer since cancer tosuiting from exposure to radiationusus!!y cases per million people, each exposed to i tem ofioniaing., occurs $ to 23 years after the exposure and since not all radianon, if in a group of 10,000 workers each recerves cancers are fatal, another useful measure of risk is years of 8.29 4 .mm ~ _ _ _ _ _ _ _ _ \\ i life es pectancy lost on the average from a radiation-induced TABLE 2 sancer.'It has been estimated in several studies that the 1 average loss of life espectancy from esposure to radiation is Estimated Less of Life Espectancy from Health Riska* i about I day per tem of esposure. In other words, a person esposed to ! rem of radiation any, on the average, lose I day of life. The words "os the average are important, Estamasas af Days of however, because the person who gets cancer from radiation Life Empestancy Last, raay lose several years oflife espectancy whBe his coworkers Neelth Risk Avesege 4 suffer no loss.The ICRP estimated that the average number of years of life lost from fatal ladustrial accidents is 30 Smoking 20 cigarettes / day 2370 (5.3 years) while the averess number of years of life lost from a fatal Overweight (by 20%) 935 (2.7 years) radiation-induced sancer is 10. The shorter loss of life All accidents combined 435 (1.2 years) espectancy is due to the delayed onset of eencer. Auto accidents 200 Alcohol consumption (U.S. average) 130 i It is impossant to realise that these risk numbers are Home accidents 9$ t only estimates. Many difficulties are involved la designing Drowning 41 research studies that saa accurately measure the small Natural bachgronad radiation, a j; increases in cancer cases due to low esposures to radiation calculated as compared to the normal rate of sancer. There is still Medical diagnostic x rays (U.S. 6 l uncertainty and a great deal of controversy with regard to everage), calculated j estimates of radiation risk. The numbers used here resalt All catastrophes (earthquake, etc.) 3.3 i from studies involving high doess and high does rates, and I rem occupational radiation dose, 3 j they may not apply to doses at the lower occupational esiculated(industry everage for levels of exposure. The NRC and other agencies both in the the higher dose job categories la i United States and abroad are continuing entensive long range 0.63 rem /yr) tessarch programs on radiation sisk. I rem /yr for 30 years caleulated .30 j .Same members of the National Academyof Sciences SEIR Advisory Comtruttee and others feel that risk estimates e 4 - myses, Eet! 34.Jene ie79.from Ceewn ed f.ee. "A Casalesme et Rists." Nemic I Ade in Table I are higher than would actually occur and topressat ' an upper limit on the risk. Other scientists believe taat j the estimates are low and that the risk sould be higher. A second useful comparison is to look at estimates of .6-j However, these estimates are considered by the NRC staff the average number of days of life espectancy lost from the the best available that the worker saa use to make an esposure to radiation and from commonindustrial accidents i informed decision conceraias acasptance of the risks asso-at radiation related facilities and to compare this number it.J.hh sque su diadun. A worker who decides to with days lost from other occupational accidents. Table 3 secept this risk should make every effort to keep esposure shows everage days of life expectancy lost as a result of t3 radiation ALARA to avoid unnecessary risk. The worker, fatal work.related accidents. Note that the data for occupa-l, after all, has the first !Lne responsibillry for protecting himself tions other than radiation related do not include death risks 1 from radiation hasards, from other possible hasards such as exposure to tesic chem. 4 icals, duets, or unusual temperatures. ' Note also that the i
- 10. New een we sempem redtesies risk.re other Made of unlikely occupational esposure at $ rems per year for $0 l
AselA Ns&st years, the maalmum allowable risk level, may result in a i risk comparable to the average riska in mining and heavy i perhaps the most useful unit for comparison among construction. l health risks is the average number of days oflife espectancy j lost per unit of esposure to each particular health risk. Industrial accident rates in the nuclear industry and Estimates are calculated by looking at a large number of per-related occupational areas have been relatively low during j sons, recording the age when death occurs from apparent the entire history of the industry (see Table 4). This is { causes, and estimating the number of days of life lost as a believed to be due to the early and continuing emphasis on result of these early deaths. The total number of days of tight safety controls. The relative safety of various occupe. i life lost is then averaged over the total group observed, tional areas can be seen by companns the probability of i death by accident per 10,000 workers over a 40. year Several studies ha3p, compared the projected loss oflife working lifetime. These figures do not include death t espectancy resulting from esposure to radiation with other from possible causes such as esposure to losic chemleals or [ health risks. Some reprFsentative numbers are presented in radi.ation. 1 l Table 2. j iI, Can a worker breeme stente erimpotentf>em erewpe. These estimatesindicate that the health risks from occu. Weaal mdishen espesuref eational radiation esposure are smaDer then the riska asse-I usted with many other eventsor actmties we encounterand Observation of radiation therapy petsents who receive accept in normal day.to< lay activities. localiasd espos.stes, usually spread over a few weeks. has 8.26 7 l 6 TABLE 3 shown that a dose of 500 800 mms to the sonads can produce permanent sterility in males or females (an acute Estimated Lens of Life Expectancy from industrial Hazarda' whole-body does of this magnitude would probably asult in death within 60 days). An acute does of 20 rems to the i testes can result in a measurable but temporary reduction in Estimates of Days of sperm count. Such high exposures on the job sould result Life Expecsancy Lost. only from serious and unlikely rediationaccidents. Although ladustry Type Average high doses of radiation can affect fertility, they have no effect on the abuity to function sexually. Likewise, exposues A!! industry 74 to permitted occupationallevels of radiation has no observed Trade 30 effect on fertility and also has no effect on the ability to Manufacturing 43 function sexuauy. kMa 47 Government 5$
- 12. What en the NR C estemal radiation dose limits?
Transportation and utilities 164 Agriculture 277 Fed czal regulatiens cursentlylimit occupational external Construction 302 whole body radiation dose to 1% rema in any calendar Mining and quarrying 328 quarter er specified 3-month period. However, when there Radiation accidents, death from <l is doc.iriented evidence that a worker's previous occupa-exposure tional 4 see Is low enough, a licensee may permit a dose of Radiation dose of 0.65 rem /yr 20 up to 3 rems per quarter or 12ansas per year.The accumulated (industry average) for 30 years, dose may viot exceed $(N.18)ter'is where Nis the person's calculated age in years, Ls., the lifetirne occupational dose may not Radiation dose of 5 rems /yr for 250 exceed an average of 5 rems fot each year above the age 50 years of 18. I;.dustrial accidents at nuclear 58 faculties (nonradiation) An additional whole body dose of approximately 'j $ rems per year la permitted from laternal axposure. (See [ Question 28.) .aAnapted rtom Cohen ene t.ee. "A Catalosue of Risk." Neelan 4 .Pnuses. Vol. 3s. June t 919; ane weste Hesstn orsasussuon.Jinaun .l.i. Whatit meant by Al,4RA? /mpdateness e/NastJearfomerfredwesrom. December 197s. In addition to providing an upperlimit on a person's y permissible tsdlation exposure, the NRC also requires that its licensees maintain occupational exposures as far below
- ~.
the limit as is reasonably achievable (ALARA).This means TABLE 4 that every activity at a nuclear facility involving esposure to radiation should be planned so as to mirdmize unnecessary 8 Probabil.ty of Accidental Death by Type of Occupation exposure to individual workers and also to the worker popula tiott. A job that involves exposure to radiation should be scheduled only when it is clear that the benefit Number of Accidental justifies the riska assumed. Au design, construction, and Deaths for 10.000 operating procedures should be reviewed with the objective Occupation Workers for 40 Years of reducing unnecessary exposures. MLning 2$2
- 14. Has the ALARA eeneopt been applied if, instead of Crnstruction 228 reaching dose limits during the first week of a quarter, Asticulture 216 the werker's dose is spreedoutever the whole quarter?
Transportation and public 116 Etilities No. For radiation protection purposes, the risk of AU industries $6 cancer from low doses is assumed to be proportional to the Government 44 amount of esposure, not the rate et which it is received. N: clear industry (1975 data 40 Thus it is assumed that spreading the dose out over time or excluding constructiorb), over larger numbers of people does not reduce the overau Manufactunas 36 risk. The ALARA concept has been fouowed only when the Services 28 individual and couestive doses are reduced by reducing the Wholesale and trade 24 time of exposure or decreasing radiation levels in the "The NRC hu pubushes a peoposed rule eneate ter puttle temment that woulJ elemanate the stN.1 a) retmula. This penposal se g g,,,,4 g,,, y,,,,,,, g,g,,, g,,,,gg,,4,,',,,,, g,,,,, g,9 e t eurfently uneet tentaderalsen by a test rette renemns a&l er to Cr A a Part to. Recent EPA twidence recommenes etsmanetens the stN.ls) ane Atemse Eneter Commatean. Operenoaad Asea.sents and Atadas. termula. It adeelen,the maasmem allowed saamas done mil be s tems sea s'aposure sapemense.
- A3H t 19s. lf f s.
tather than 43. 8.29 8 e Individual and couective doses are reduced by reducing the sancer for the worker population. At best, the total risk time of esposure or decreasing radiation' levels in the remains the same, and it may even be increased. The only working environment, way to reduce the risk is to reduce the conective dose; that een Le done only by reducing the radiation levels, the 1.f. h%et is meent 6p es#eeWee dose and why s4eutd it working times, or both. be mekseined ALARA ? \\
- 17. h%p deoen ir she MtClaspose soNetWee door moder?
j Nuclear ladustry activities es poes an increasing member of people to occupational radiation in addition to the radio-Complianos with ladividual does limits een be ashieved t tion doses they receive from natural backpound radiation simply by using extra workers. However, eomplianas with a l and medical radiation esposures. The collective occupational sonective dose limit (such as 100 person tems per year for a does (person tems)is the sum of au occupational rediation licensee) would require redustaon of radiation levels, esposure received by au the workers in an entire worker 1retking times, or both. But there are many problems population. For esemple, if 100 workers each receive 2 rems, associated with settlag appropriate eeuestive does limits. the individual dose is 2 rems and the collective does is 200 person-tems. The total additional risk of cancer and genetic For example, we might consider applying a shisle effects in an exposed population is assumed to depend os eeuective dose urnit to aulicensees.The election of asch a the conective dose. sonective does lisnit would be almost impossible because of the wide variations la collective doses among lianasses, it shoul.1 be noted that, from thestewpoint of risk to A power reactor could reasonably be arpected to have an a total popu!ation,it is the conectrve does that must be con. average annual conective does of several hundred person-trolled. For a given couestive dose, the number of health nas flowever, a smau ladustrial radiopsphy lisensee effects is aanumed to be the same even if a largersumber of sould very wou have a couestive does of only a few person. people share the dose. Therefore, spreading the dose out rems in a year. may reduce the individual risk, but isot that of the population. Evea choosing a souective dose limit for a poup of Efforts should be made to maintain the couestive does simpar licensees would be almost as difficult. Radiopaphy Al.A RA so as not to unnecessanly increase the overau popula-licensees as a poup had an average couestive does in 1977 tion ancidence of cancer and genetic effects, of 9 person nma. However, the smanest sollectm does for a radiopsphy licenses was less than I person rem, and the fd. la the use of estre workers a seed uey to reduee Ms&s? largest was 401 person roma. 'There is a "yes" answer to this question and a "no" 5etting a reasonable couective does umit foresehind6-answer. For a given job involving esposure to radiation, vidual licensee would also be very difficult. It would the more people who share the work, the lower the everage require a record of all past conective doses on which to base dose to an individual. The lower the dose, the lower the such limits. Setting as annual soussaive dose halt would risk. So, for you as an ladividual, the answer k "yes." then amouat to an attempt to predict a reasonable couestive r does for each future year. In order to do this, it would be But how about the risk to the entire poup of workerst necessary to be able to prodict changes in each licenasd Under assumptions used by the NRC for purposes of protec-actrvity that would increase or deenses the couestive does. tion, the risk of concer depends on the total amount of in addition, annual conective doses vary significantly from radiation energy absorbed by human tissue, not on the year to year according to the kind and amount of mainte-number of people to whom this tissue belongs. Therefore,1f nance required, which sannot generauy be predicted la 30 workers are used to do a job insread of 10, and if both advance. Following au such changes and revises units up youps get the same souestive does (person tems), the total and down would be very difficult if not impossible. However, concer nok is the same, and nothing was gained for the these efforts would be necessary if a conective does umit youp by using 30 workers. From this viewpoint the answer were to be reasonable and help miniml:e doses and riska, is "no." The risk was not reduced but simply spread stound among a larger number of persons. /#, New ser radiaWon dese 14mits esse 64ahed? Unfortunately, spreading the risk around often res lts The NRC establishes occupational radiation does in a larger collective does for the job. Workers are esposed limits based on guidance to Federal agencies from the as they approach a job, while they are getting oriented to Environmental Protection Agency (EPA) and,in addition, do the job, and as they withdraw from the job. The does considers NCRP and ICRP recommendations. Scientific received during theng actions is called nonproductive. If reviews of ressatsh data on biological effects such as the, several crew changes are required, the nonproductive dose SEIR report are also considered. can become very latd. Thus it een be seen that the use of estra workers may actually increase the total occupational For esample, recent EPA guidance recommended does and the resulting collective noks. that the annual whole. body does limit be established at $ rems per year and indicated that esposure, year after year, The use of estra workets to comply w6th NRC dose to $ rems would involve a risk to a worket compatable to hmits is not the way to teduce the nok of radiatioruitiduced, the average tuks incurred by workers in the hither risk jobs 8.29 9 such as mining. In fact, few workers ever reach such a limit, there is danger. Exceeding a limit does not Imply thatyou ' much less year after year, and the risks associated with have suffered an injury. A good comparison la with the actual esposures are considered by the EPA to be comparable highway spees limit, which is selected to limit accident risk to the safer job categories. A 5-rem-rer year limit would and still aUow you to get somewhere. If you drive at 75 aUow occasional high does jobs to be done without oncessive mph, you inemana your risk of an auto accident to levela nak. that are not considered acceptable by the people wiso set speed limita, even though you may not actuaDy have an '
- n. Wherarr ahe ryplest radierten doser meelved by inerArrst accide,nt. If a worker's radiation does repeatedly esoseds 3 rems in a quarter, the risk of health effects could eventually The NRC requires that certain categories oflicensees inemass to a level that is not considtred acceptable to the report data on annual worker doses and doses for au workers NRC. Enceeding an NRC protection limit does not mean t:h3 leave employment with Ilcensees. Data were received that any adverse health effects are going to occur. It does on the occupational dosesin 1977 of approximately 100,000 mean that a licensee's safety program has failed in some workers in power reactors, industrial radiography, fuel respect and that the NRCand the licenses should investigate procesang and fabrication faculties, and manufacturing to make sure the problems are corncted.
J and distribution faculties. Of this total youp,85 percent received an, annual dose of less than I rem; 95 percent if an ot ereu posurs occurs. the regulations prohibit any received less than 2 retas; fewer than I percent exceeded additional occupational esposure to that person during the $ rems in 1 year. The average annual dose of those workers remainder of the cakt:dar quarterin which the overesposure wh3 were monitored and had measurable exposures was occurred. The licensee is required to fue an overeuposure i cbout 0.65 rem. A study completed by the EPA, using report to the NRC and may possibly be subject to a fine, 1973 esposure data for j,260.000 workers, indicated that just as you are subject to a trafGc fine for exceeding the the average annual dose for au workers who received a speed limit. In both cases, the fines and,in some serious or measurable dose was 0.34 rem. repetitive cases, suspension of license are intended to encourage efforts to operate within the limits. The safest Table $ lists everage occupationalesposule s f r workers Ihnits would be 0 mph and 0 fem per quarter.But then de (persons who had measurable exposure above bhkground wouldn't get anywhere, levels) in vanous occupations, based on the XY75 data. l 27. Why 40 some feellitiet esanblish administrative limits TA31.E $ ther are belew the NAClimits? U.S. OccupazionalImposure Easimates' Thors are two tsasons. First, the NRC regulations state that licensees should keep exposuresto radiation ALARA. l Average Whole. Sy requitsng specific approval for worker doses in excess of Occ:pational Body Dose Couective Dou set levels, rnors careful risk benefit analysia can be made as i Sa' ww (mi!11:sma) (person rems) each additional increment of dose is approved for a worker. Secondly, a facility administrative limit that is set lower I Medicine 320 $1,400 than the quarterly NRC 11rnit provides a asfety marsin 1 I;dustrial Radiography .580 5,700 designed to help the licenses avoid overexposures. Source Manufacturing 630 2,500 1 } P:wer Reactors 760 21,400 l Fzel Fabncation and $60 3,l00
- 22. Senre! scientssts have ausgested that NRCIlmits are Reprocesang too high endshould be lowered. Whatere she ersuments Urarlum Ennchment 10 400 forlowennt the limits?
N: clear Waste Disposal 920 100 Uranium Mdis 380 760 In general, those critical of present does limits say that Department of Energy 300 11,800 the individual essk is higher than is estimated by the BEIR Facdities Committee, the ICRP.and UNSCEAR. Based on studies of Department of Defenu 180 10,l00 Iow level esposures to large groups, some researchers have Facdities concluded that a given dose of radiation may be more likely Educational Institutions 206 1,$00 to cause biological effects than previously thought. Some of Transportation 200 2,300 these studies are listed in the bibliography (Mancuso. 4 Archerl and the BElft 80 report includes a section analyn'ns 'Av h ion the findings of these and other studies. Scientific opinton teau ae.end trem ce.m enf.e seeees, oscueeneaet tsevaars se nee,ene.. in,enn a come,eaenen somm n differs on the validity of the rewatch methods used and the 2 j /er s e rs, onte, ta,veameniB reenesion 4eener, methods of statistical analysis. The problem is that the espected additional incidence of radiation caused effects 20. What heppens if e werAer esteeds the guerrerly espo-such as cancer is difficult to detect in comparison with the l aure limit / much larger normalincidence. It cannot be shown without question that thew effects were more frequent in the l Radiation protection timits, such as 3 rems in 3 months, esposed study group than in the uneaposed group used for are not absolute limita pelow whigh it ts safe and above which Comrarison, or that the observed eflects were caused 0.29 10 ,_,_.___,,,.rm,,, _,.,----m r,__._m y,, __-.-_.. by radiation. The SElR committee concluded that claims level radiation according to the linear model empleined in of higher risk had "no substance." Question 7. Based on this approach, the regulationsin WCFR Part 20, " Standards for Protection Against Radiation,also ( The NRCstaff continually reviews the results of research mate that laconsees should maintain au radiation esposures, on radiation risks. With respect to large scale studies of and teleases of radioactive materials in effluents, as low as is radiation.insuced health effects in human populations seasonably achievable. More roosat esientifisreviewsof as orposed to low. level ionising radiation, to NRC and EPA large body of esperimental data, steh as the SEIR 80 and have recently concluded that there is no one population the recent EPA guidance, oentinue to support the view that youp available for which such a study could be espected to mes of a $ rem per year Malt is asseptable in practies, provide a more meeningful estimate of the low level radia-Esperlenes has shown that, under this limit, the average tion risk. This is due, in large part, to the observed and does to workers is near 0.5 rem /yr with very few workers estimated low insidense of radiation health effects from sensistently approaching the limit. low doses. However, the results of ongehns audies, seen as that on nuclear shipyard workers, wGl be sarefuuy reviewed
- e. There is little to gain, and the oevelopment of a radiation worker reestry is being considered as a possible data base for funam studies.
Roducing the dose tiraits, fur suanspleito 0.3 res/yr has been analysed by the NRCstaff. An esdmated 2.6 miBion 2J. h/Aer are the reasons for not loweWar ate #AC dose person reas could be saved from 1980 through the year Jimits? 2000 by suelear power plant licensees if sempliance with the new lient were achieved by lowering the radiation Assuming that the 5 rem per year limit is adopted, levels, working times, or both, rather than by using estra there are three reasons: workers, it is estimated that sosnething like $23 bGlion would be spent toward this purpoes. Spending $23 billion to save
- a. Health risks are already low.
2.6 million person roms would amount to spending $30 to 390 mulion to prevent each potential radiationinduesd The estiansted health risks assoaisted with current premature e.anser death. $osiety senaidersthis son tanese'pt. everage occupational radiation doses (e.g.,0.3 rem /yr for ably high for individual protection. 30 years) are comparable to or less than risk levels in other occupational areas sonsidered to be among the safest. If a
- 24. Are there ony erser of toneem shout sedission #dres person were esposed to the maximum of $ roms per year abet might resntt in eAengest she #AC dose Almim?
fir 30 years, which virtuauy sever osaurs, he er she snight incur a nak somparable to the everage viaks in mining and Yes. Three areas of consess to the NRCsaff are specifn-heavy construction. An oesasional S rem annual does might cauyidentitled below; be necessary to allow some jobs to be done without a significant incrosse in the collective does. If the does limits sAn independent study by Rosed and Maysand other were lowemt e4.iri-*T, e m.ter of people required biologleal research have indleased that a given does of 13 semplete many jobs would incrosse. The sousettve does neutron radiation may be more Mkely to cause biologieel would then increase since more individuals would be effects than was previously thought. Other resent studies receiving nonproductive espoewre whue entering and east doubt on the issue. The NCRP is currently studying the .laavans the work area and preparing for the job. The total data related to the neutron radiation question and is number of health effects might go up as the couestive dose increased. espected to make recomseendations as to whether neutron does limits should be changed. Although the asientifle
- b. The surnnt regulations are sensidered sound, community has not yet come to agreement on this question, workers should be advised of the persibuity of higher risk when entering areas where esposure to neuttons wiu occur.
The regulatory standards for dose Ilmita are based on the recommendations of the Federal Radiation Councu.
- b. It has been known for some time that rapidly At the time these standards were developed,about 1940,it growing living tissue is more sonstive to injury from radiation was considered un!!kely that esposure to these levela during than tissue in which the cells are not reproducing rapidly, a wIrking lifetime would result in clinical evidence of' Thus the embryo or fetus is more sensitive to radiation iglury or disease different from that occurring in the injury than an adult. The NCRP recommended in Report Eneaposed population. The essentific data base for the No. 39 that special precautions be taken when an occupe.
standards conssted primardy of human esperience (s. ray tionaDy empoord woman sould be pregnant in order to espisures to medical practitioners and patients, ingestion' protect the embryo or fetus, in 1973, the NRC lesued cf tsJlum by watch dial flinters, early effects observed in Regulatory Culde 4.13. "Inservation Consermes Prenatal lapsites atomic bomb, survivors, reden espesures of Radiation Esposure.** in which it is resommended that ursMum miners, occupational radiation seeidents)lavolving licensees instruct all workers concerning this special risk. very large doses delivered at high dose rates. The data base The guide recommends that all workers be advised that the also included the results of a large number of animal ltaperiments involving high doses and does rates. The animal NCRP recommended that the manimum permisable does to the embryo or fetus from oseupational esposure of the espertments were particularly useful in the evaluation of mother should not esteed 0.3 rem for the fuu 9 month geretic effests. The observed effects were related to low. pregnancy pened, in addition, the su6de suggests options 8.29 11 e t' avaHable to the female employee who chooses not to Thus, the average individualin the general population' cmpose her embryo or fetus to this additional risk. receives about 0.2 tem of radiation exposure each year from sources that att a part of our natural and man made The United States Department of Health and Human environment. By the age of 20 years. an individual has Services is similarly concerned about prenatal exposure accumulated about 4 rema. The most likely target for from medical x rays in 1979 they published proposed reduction of population exposure is medical uses. guidelines for physicians conceming abdominal mesys for posubly pregnant women.The guidelinesin effect encourage .26. Why spen't medical arposurse considered as part ofe - Ce x ray staff to make efforts to determine whether a workerir allowed dose? female patient is pregnant and to defer x rays if possible until after the child is born. Equal doses of medicaland occupational radiation have equal risks.' Medical exposure to radiation shou'Id be justified
- c. Also of specialinterest is the indication that female for reasons quite different, however, from those applicable w rkers are subject to more risk of cancer incidence than to occupational exposure. A physician prescribing an x ray male workers, in terms of a!! types of cancer except leukemia.
should be cormaced that the benefit to the patient of the the SEIR 80 analysis indicates that.fstnale workers have assulting rnedical information justifies the risk associated a nsk of developing radiation induced cancer that is approxi-with the radiation. Each worker must d. cide on the accept. mately one and one half times that for males. This increased ance of occupational radiation risk just as each worker must risk is primarily due to the incidence of breast and thyroid decide on the acceptability of any other occupational cancer in women. These types of cancer, however, have a
- hazard, high cure rate. Thus the difference between men aad wimen in cancer mortality is not great. Incidence of For another point of view, consider a worker whe receives radiation induced leukemia is about the same for both a dose of 2 rems from a series of x rsys or a radioactive sexes. Female workers should be aware of this difference in medicme in connection with an infury or illnesa This dose the risks of radiation induced cancer in deciding whether and the implied risk should be justified on medical grounds.
or not to seek work involving exposure to radiation. If the worker had also received a dose of rems on the job, the combmed dose of 4 rems would not incapacitate the .23. How much rer.letion does the averste person who worker. A dose of 4 rems is not especially dangarous and is does nor work in the nuclear industry receive? not large compared to the cumulative lifetime dose. Restrict-ing the worker from additional job exposure during the We are a!! exposed from the moment of concaption remainder of the quarter would have no effect one way or ta ionising radiation from several sources. Our environment, the other on the risk from the 2 rems already received from and even the human body, contains naturally occurring medical exposure. If the individual worker accepts the risks radioactive materials that contribute some of the background associated with the x rays on the basis of the medical radiate.. v.c rec:h;. C;1:r.!: radiation originating in space benefits and the risks associated withjob related expcsure and in the sua contnbutes additional exposure. The use of on the basis of employment benefits,it would be unfair to x rays and radioactive matenals in medicine and dentistry restrict the individual from employment in radiation areas adds co isiderably to our population 8 xposur1. for the remainder of the quarter. Table 6 shows estimated average individual exposure Some therapeutic medical doses such asthosetectived in millitems from natural background and other sources. from cobalt 60 treatment can range as high as 6000 rems to a small part of the body, spread over a penod of several TA31.E 6 weeks or months. U.S. General Population Exposure Estimates (1978)' 27. Wher is meent by laternet esposure? Average Individual The total radiation dose to the worker is the external Source Don dose (measured by the film badge and reported as "whole. (mremlyr) body dose") plus the dose from internal emitters. The monitoring of the additional mtemal dose is difficult. Natural background (average in U.S.) 100 Secause there is the possibility of internal doses occurring. a Release of radioactive materialin good air monitortng program should be established when nstural gas, mining, millin g, e tc. warranted. Medical (whole body eqtitvalent) 90 Nuclear weapons (primanly fallout) $8 The uptake of radioscrive matertals by workersis gener. Nrclear energy 0.28 ally due to breathing contaminated alt. Radioactive matenals Censumer products 0.03 may be present as fine dust or gases in the workplace atmosphere. The swfaces of equipment and workberches Total . %200 mram/yr 'uspied trem a reeers av ene laterieener Tsen ra,ee on in. 'n a uneer enes e i.enine nt oonton er reported mediens <s, HeHth Effetu et loaisans #1sJastion pusisned er Ine Department espasure is to perte er ene mode only. An esporure et too mesm to of Health. Education, one welfare. the wnose soJr is moto assnindant than a 100 mrom enest t<sr. 8.29 12 may be contaminated. Radioactive materials may enter the limit. ICRP recommends that the internaland externaldoses body by being breathed in, taken in with food or drink, or should be appropriately added. This recommendation is being absorbed through the skin, particularly if the skin is currently under study by the staffs of the NRC, the EPA, broken. and the Occupational Safety and Health Adminastration (OSHA). After entering the body, the radioactive material will migrate to particular organs or particular parts of the body J0. 7 Tow la a workerir essernsfrediesion dose desermined? depending on the biochemistry of the material For example, uranium will tend to de' posit in the bones where it will A worker' may wear three types of radiation-measuring i remain for a long time. It is slowly eliminated from the devices. A self reading pocket dosimeter records the exposure body, mostly by way of the kidneys, Radium will also tend to incident radiation and can be read out immediately upon to deposit in the bones. Radioactive iodine will seek out the finishing a job involving external exposure to radiation. A thyroid glands (located in the neck) and deposit there, film badge or TLD badge records radiation dose, either by the amount of darkening of the film or by storing energy in The done from these interval emitters carstot be mes-the TLD crystal. Both these devices require processing to sured either by the film badge or by other ordinary dosim. determine the dose but are consaderad more reliable than eters carried by the worker. This means that the internal the pocket dosimeter. A worker's official report of dose radiation. dose must be separately monitored using other received is normally based on film or TLD badge readings, detection methods, which provide a cumulative total and are more accurate. 4 internal exposure can be estimated by measuring the Jf. What arr my options (fidecide not to accept the riskt radiation emitted from the body or by measurms the associated with occuperfonal radiation exposuret i radioactrve matenals contained in biological samples such as unne or feces. Dose estimates can also be made if one If the risks from exposure to radiation that may be i knows how much radioactive materialis in the air and the expected to occur during your work are unacceptable to length of time during which the air was breathed. you, you could request a transfer to a job that doef not involve exposure to radiation. However, the risks associated 2#.' //ow ere the limitsforinternalespesure sert with exposure to radiation that workers. on the average, actually receive are considered acceptable, compared to 1 Standards have been established for the maxarnum other occupational risks, by virtually all the scientific permissible amount of each radionuclide that may be groups that have studied them. Your eroployer is probably %ccumulated in the critical organs' of the worker's body. not obligated to guarantee you a transferif you decide not to accept an assignment req' airing exposure to radiation. Calculations are made to determine the quantity of radioactive material that has been taken into the body and the'tatal dod that wmM -vit. Then, based on.iimits You alsoitave the option of seeking other employment established fo~r particular body orsans similar to I% rems in a sonradiation occupation. However, the studies that in a calendarItuarter for whole-body exposure, the regula-have compared occupational risks in the nuclearindustry to ti:ns specify maximum permissible concentrations of radio-those in other job areas indicate that nuclear work is active material in the air to which a worker can be exposed relatively safe. Thus, you will not necessarily find signif-f:r 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per week over 13 weeks or 1 calendar quarter. icantly lower risks in another job. The regulations also require that efforts be made to keep internalexposure ALARA. A third option would be to practice the roost effective work procedures so as to keep yourexposure ALARA. Be Internal esposure is con trolled by limiting the release of aware that reducing time of exposure, maintaining distance radioactive materialinto the air and by carefu!]y monitoring from radiation sources, and using shielding can all lower the work area for airborne radioactivity and surface con-your exposure. Plan radiation jobs carefully to increase tamination. Protective clothing and respiratory (breathing) efficiency while in the radiation area. Learn the most prstection should be used whenever the possibility of effective methods of using protective clothing to avoid contact with loose radioactive materialcannot be prevented'. contamination. Discuss your job with the radiation protec-tion personnel who can suggest additional ways to reduce
- 29. fr the dose e person reersvedfrom internal esposure your enposure.
l edded to that retrivedfrom esternal esposure? Exposure to radidfien that results from radioactive materials takin into therbody is measured, recorded, and The following list suggests sources of usefutinforma-reported to the worker separately from external dose. The tion on radiation risk: l internal dose to the whole body or to specific organs does ) nit at this time countagainst the 3 rem per-calendar quarter
- a. Your Employer N e U Eu eIa N uYas5hvro.'s I0r 's
'ajIe* The radiation protection or health physics office een a eeviana twoouun mienats wui epacentrare.I saken entn ame hoey. in the facility where you are employed. 8.29. I J l 1 -i,.-
- b. NuclearRegulatory Comminion
- e. Department of Health and Human Serw'ces ~
Regional Offices Office of the Director Bureau of Radiological Health (HFX 1) King of Prussia, PA 19406 215 337 5000 Department of Health and Human Services Atlanta,GA 30303 404-221-4503 5600 Fishers I.ane Glen Ellyn.IL 60137 312 932 2500 Rockville,MD 20857 Arlington,TX 76012 817 334-284I Walnut Creek, CA 94596 415-943 3700 Telephone: 301 443-4690 Headquarters
- d. EnvironmentalProtection Agency Occupational Radiation Protection Branch Office of Radiation Programs Office of Nuclear Regulatory Research U.S. Environmental Protection Agency U.S. Nuclear Regulatory Commission 401 M Street, SW
. ashington, D.C. 20555 Washington, D.C. 20460 W Telephone: 301 443-5970 Telephone: 703-557 9710 T e e O O 6 $S S e 8.29-14 l BIBLIOGRAPHY American Cancer Society,1979 Caneer Facts and Figures, International Commission on Radiological Protection,Radle-1978. rien Protection, Recommendations of the International Commission on Radiological Protection,ICRP Publication 36, Anderson, T.W., " Radiation Exposure of Hanford Workers: Pergamon Press, January 1977. A Critique of the Mancuso, Stewart, and Kneale Report," Health Physics, Vol. 35, December 1978. Kelsey, C.A.," Comparison of Relative Risk from Radiation Exposure and Other Common Hazards," Hasith Physics, Atcher, V.E., " Effects of Low Lavel Radiation: A Critical Vol 35, August 1978. Review," Nuclear Safety, Vol. 21 No. I, January February 1978. Lapp, R.E., De Radiation Controversy, Reddy Communica-tions, Inc., Greenwich, Connecticut,1979. Atomic Energy Commission, Operational Accidents and Raduttion Exposure Experience, WASH 1192, Fall l975. Lapp, R.E., A isbrker*: Guide to Radiation, AtomicIndustrial Foeum, August 1979. Bamett, M.H., De Biological Effects ofionising Radiation: An Overview Depattment of Health, Education, and Welfare Linos A., et al," Low Dose Radiation and Laukemia, Mayo Publication (FDA) 77-8004,0ctober 1976. Clinic and Foundation, Rochester, Minn.," New England fournal of Medicine 1980; Vol 302, pp.11011105. Cohen B.L., and Lee, l.S., "A Catalog of Risks," Health Phystes, Vol 36, June 1979. Mancuso,T.F., Stewart, A.,and Kneale,G.," Radiation Expo-sures of Hanford Workers Dying from Cancer and 0,ther Cook. J., an d Nelson. D.,0ccupationalExposures to lonizing Causes," Health Physics, Vol 33, November 1977. Radiation in the United States: A Comprehensive Summary fer 1975, EPA 520/4-80 001, Environmenta! Protection Muller, R.,* Natural Radiation 3ackground ys. Radiation from Agency. Nuclear Power Plants," Journal of EnvironmentalSciences, August 1972. Department of Health, Education, and Welfare, Eiolatic Effects oflonising Radtarion, Report of the Science Work Najarian, T., and Colton, T., " Mortality from Leukemia and Group of the Interagency Task Force on Radiation, June 1979. Cancer in Shipyard Nuclear Workers," Lancet,I: May 1978. Dreyer, N.A., et aL, De feastbility of Epidemiologiclaves-National Academy of Sciences, De Effects on Populationr siaauuns of she Heaish Effccis ofLow LevellonisingRadia: of Exposure to Low Levels oflonising Radiation, Report tion, NUREG/CR 1728, Nuclear Regulatory Commission, of the Committee on the Biological Effects of lonizing November 1980. Radiation (BEIR),1980.
- Gilbert, E.S., " Assessment of Risks from Occupational Rossi and Mays, " Leukemia Risk from Neutrons," Health Exposure to lonizing Radiation," in Energy and Health Physics, Vol. 34, pp. 353 360,1978.
Proceedings of the Conference on Energy and Health, June 26 30,1978 SIAM Publication, Philadelphia,1979. Schottenfeld, D., and Haas, J., " Carcinogens in the Work-place," CA A Cancer Journal for Clinicians, Vol 29, No. 3, Gofman, J.W., "The Question of Radiation Causation of May June 1979. Cancer in Hanford Workers," Health Physics, Vol 37 Nt,vember 1979. United Nations Scientific Committee on the Effects of Atomic Radiation, I977, Sources and Effects of lonizing Gatchy, R.L " Estimation of Life Shortening Resulting Radiation Report to the General Assembly, UN Publica. frsm Radiogenic Cancer per Rem of Absorbed Dose," tion No. E.77.lX.1,1977. Health Physics, Vol. 35, October 1978. Upton, Arthur C.," Radiation from Nuclear Power Exagger. Hall, E.J., Radiation and /.ife, Pergamon Press,1976. sted," New England /ournelof.tledicine, VoL 302, p p.1205-1206, May 22,1980. International Commission on Radiological Protection, Problems invotred in OPrelapsnt an Index of Harm. Annals Wottd Health Orgamzation, litalth implications ofNuclear af the ICRP,ICRP Publication 27, Pergamon Press, May 1977. ber Production, Report of a Working Group, December 1975. 8.29-15 O ~.. . m.. t !,o-V S ~ .n.'d e /s-W D 4 Ar~l CC. y. f L m 1 4 l ".. dna.% o) C e., f l., A__4._._..s.__ ~- v.... ,.e ... d.....~.c.).? ....m Q.... a, m .. W - A...../ m. k..a d. u W.*.... ...a ....h/ ....g......u..w a... eM....................... l .....a.......... ........n..... 1 ....... e ..-..v. ? Y'....M4.....'d...R.C..?.......... N.... m h ........ L.. M b u.r 4 ,.. A. a- .a !.w...... m4.....o....,w..... 8 o....c..,.......o. r. J N =..... L.......,,, b~~.... ...rA $......a.a / ' u...S '......
- J
. /.2. e.,.... .......././,../ 19. \\.,...... ..__.....x.. 9_. -................e....v......r.... .....a. ....y........ ......a. ........ u..........................f........f............ ' wA .........-n.... dLn - O I A....g.,.,...x u... ~............ .....o.........................g......................... ..... p........g I. . w.. 1 1 s .................'g........... ............................(.........s............................ s, i I i T ee i l............... ..... ^. (o l .... a *..t<.. ' DUI: t.4AME PLAINLY i Appendix 5 l ' i JOB CCMPONENT: Chemet Laboratories - 970 NUMBER: CL-JllA-01 HAZARD 3h ANALYSIS h PROCESS: Nuclear liatcrials em au Prepared by: _PR Jasinski 9/18/79 Date issued: 10/01/81 Reviewed by: b '/h c 49 (Indust. Safetv1 Review date: ' c
- I.
J///E4"l'.A+ / Approved by: W IJ (Manaoer) Replaces: New
- 1. Safety Glasses (Minimum) l PERSONNEL PROTECTIVE
/J. Rubber or Polyvinyl Chloride Gloves <3. Laboratory Coat EQUIPMENT REQUIRED:
- 4. Safety Shoes 1
- 5. Face liask (Half) when scribing pellets or working with airborne materials in' unusual c.ircismsD nces.
l POTENTIAL HAZARDS SAFETY REQUIREMENTS A 1. Radioactive contamination I. Pass Radiation Safety Test before working in a controlled of skin. Lab Section, f
- 2. Ciological injury from 2/I'rotective clothing, glasses, sofc:y equipment are to be radiation, used.
<, 3. Inhalation of Airborne
- 3. Fql1n" M iation and criticality safety recuirements.
7 m radioactive materials.
- 4. Hear radiation monitoring badge:, as required.
W. Introduction of Radioactive 5 -Control limits are not to be exceeded (safe batch). f litdterial into Cuts or V'6. Clean spills inrediately and notify radiation protection. abra d nne
- 7. Bioassay sample must be submitted when required.
- 8. Only qualified personnel should handle radioactive material l
- 9. Monitor feet and hands before leaving controlled areas.
l
- 10. Notify supervision and liedical Unit of all injuries,
<'ll. Notify supervision of all unsafe conditions and practices. e'
- 12. If in doubt, contact your supervisor.
I See Also: JHA J CL-JHA-04, SEALED RADI0 ACTIVE SOURCES AND X-RAY I l l I !.(f l ) [,'(v Appendix 6 I i ll} ssl72, COURSE OUTLI!3 FOR EOURLY EMPLOYEES 1. Radiation exposure contrcl A. Limits J 1. Radiation External Radiation for radiation worker 5 rea/ year 1250 ares / quarter rem = umit of biological measurement of radiological exposure year = 52 weeks quarter = 13 consecutive weeks 4k. Non-radiation worker = 500 mres/yearr 2. Release Limits a. Air & Water ~I ~11 10 x 10 pci/cc airborne limit for 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> week 400 x 10 pci-h'r/ s ~ 3 x 10 UCi/cc water limit pCi/cc air released to the environment 3 x 10 b. Contamination 8 200 dpm/100cm loose surface contamination 8 2200 dpm/1V cm fixed surface contaminatien B. Seriousness of violating instructions on radiation warning signs i) exposure 11) contamination iii) punitive measure iv) dismissed from the company v) loss-of confidence C. Discuss procedures and methods for minia' ning exposure i 1) time - distance - shielding 11) internal D. Potential sources of radiation / contamination exposure associated with work performed by the employee. er E. Aiscuss where film badge and desimeters should be placed upon individuals body. 2. Contamination Control A. Discuss how contamination is controlled during radioactive work. 1. Disposition of contaminated materials 2. Use of glove boxes Appendix 7 3. Work tents 4. Personnel protection from contamination by wearing protective clothing. 4 s. Lab coats - caps - rubbers - gloves b. Coveralls
- 1) no street clothes under coveralls c.
Raspirators 1 i) half mask 11) full face mask tii) chemical mask iv) fresh air d. Proper collection and disposal of. radioactive solid waste Liquid waste must be collected, treated and disposed of properly e. 1) poly bottles 11) cans / buckets f. A well trainer worker g. Detected in order to control it 1. Methods to detect 1. Swipes 11. Ins truments 111. Air samplers iv. Water / soil samples 2. Detected on personnel
- 1) Self frisking 5.
Discuss procedures for preventing contamination of pessonnel and how contamination is detected on personnel. 1. Contaminated areas roped off - control signs 2. Wearing of proper protective clothing 3. Proper removal of protective clothing.
- 1) Tape 2)
Cap
- 3) Cloves
- 4) Lab coat /coveralla l
- 5) Rubbers 6)
Frisk ~4. Street clothes not worn under protective cove'ralls. i 5. Contamination is detected on personnel with a "f risker" ~ a) proper frisking technique b) location of probe away from body 4 c) detect contamination - actions? .2.-. C. Discuss removal of contamination from objects and personnel 1. Normally removed from objects with a cloth dampened in plain water. 2. Normally removed from personnel by washing with soap and water. D. Discuss the surface contamination limit and the meaning of the units of the limit. E. Demonstrate proper procedure for putting on and removing protective clothing and maak. F. Demonstrate proper procedures for entering and leaving contaminated area - SOP G. Explain what radioactive contamination is. Where it can exist - surface air vater 3. Criticality A. Definitions Criticality - uncontrolled fission Tission - the splitting of the atomic nucleus into two or more parts with the release of energy and neutrons. This may occur with a neutron striking the nucleus and, thus, initiating the fission. Safe batch - the allowable quantity of uranium one may handle. 45% of minimum critical mass of uranium for a given enrichment. as the enrichment increases, the safe batch size decreases. Limit Area - an identified location in which uranium can be handled, processed, or stored in accordance with specific posted criticality safety limitations. Dead Zone - a safety mone, usually 12" in width, surrounding all limit areas. It is designated with a 2" vide red tape. B. Rules i 1. Any time uranium is handled outside of process vessels always handle one safe batch at a time. 1. Limit area 2. Dead sone sk. The limit area is the ogjjt place where you may store a safe batch.. 93. Never place any uranium in a dead none. i 4 Always move safe batches in marked sisloways l 5. Never use an aisleway to " temporarily store" uranium. Geometry - limits size and location. V 6. Never make any equipment. changes without specification cuthtriattien of your imediate supervisor. Procedureal or Adminstrative 7. Obey all posted and written criticality rules 8. If in doubt about anything - ask before you act. 4. Waste Disposal Discuss how the individual workers can reduce the amount of radioactive liquid and solid waste A. One of the best ways is to minimise radioactive waste is to teach the worker the characteristics of radioactive contamination and the proper methods for contro41ing contamination. 3. Good housekeeping C. Take only material absolutely needed to do a job into control areas. D. Liquids of different vypes sagtegated - HUF - ADU lauudry - grinders, etc E. Liquid waste not normally radioactively contaminated should be collected separately. F. Do not dump contaminated liquida into sinks or showers that are not specifically designated for radioactive contamination. 5. Radiological Incidente A m auese the need for consulting radiation protection personnel when questions or incidents occur. 1. Common sense 2. Redistion protection personnel are trained to cope with the situation. a. They have the material, equipment, and tools to handle the problem. 3. Discuss procedures to be followed af ter a spill of material (liquid or solf 1. Action must be taken af ter a spill has occurred otherwise contaminatior could be spread around. 2. If action is not taken after a spill s. personnel could track contamination around . b. It could become airborne 3. There are five basic stepe to be followed in the event of a spill. Step is Stop the spill Step 2: Warn other personnel - Call RadiationJrotection Step 3 1eolate the area Step 4: Minimise your own contamination 5 Step 5: Secure unfiltered ventilation C. Diocuss prrc dura to b3 fellowed when estified that airborne radioactivity is above the limit. 1. Stop any operation that may be causing airborne radioactivity - 2. Leave area immediately or put on respirator. 3. Follow Radiation Protection's instructions. 6. Responsibilities of Individuals Rules to minimize radiolonical problems A. Obey stop work or evacuation orders B. Obey posted, oral and written radiation protection instructions C. Wear film badge and/or dosimeter and/or lapel sampler where required. D. Do not loiter in controlled arena E. Do not smoke, eat, drink,or chew in controlled areas. F. Wear protective clothing and respirat srs properly and when they are required. G. Remove protective clothing and respirators properly. H. Frisk yourself when leaving a control area I. For a know or possible radioactive spill, minimize its spread and notify Radiation Protection. J. Do not unnecessarylly touch a contaminated surface or allow your clothing, tools, or equipment to do so. K. Place contaminated tools, equipment and solid waste en disposal surfaces when no in use, and inside of bass when work is finished. L. Limit the amount of material to be decontaminated or disposed of as radioactive waste. M. Report the presence of open wounds to Radiation Protection prior to work and report immediately if a wound occurs while in the area. N. Obey all Criticality Rules. t se e e e 9 v REDUCTION OF AIRBORNEEXPOSURE 1. Use of Containment 2. Proper air flows in Hoods, work stations, and/or duct work 3. Air sampling to control exposure 4. Notification when systers break down 5. Preventative maintenance 6. Following Procedures 7. Containing all contaminated Materials 8. Cleaning up Spills immediately 9. Obey barriers and flashing lights
- 10. Comon Sense y
- 11. Use of Mask as a last resort O
e e .E \\ma ].P 3, FUELS M ANUFACTURIF]G OPERATION s s> STANDARD 0PERATING CINERAL ELECTRIC PR0CEDURE $0hMf ~ 0.3.4 Radiation Safety - Lab Operating Procedure y,, g,,, 1 1.0 PURPOSE The purpose of this procedure is to establish and outline the general radiation safety rules, practices, and precautions necessary to prevent airborne exposures, personal contamination, and spread of contamination within the Lab. 2.'0 SCOPE The scope of this procedure is to cover the radiation safety rules and practices and precautions of a very general nature for the Wet Chemical 'pecial requirements outlined in the General , and Spectrography Labs. ~ S Radiation Safety Procedure #1.2.2-8.2.2 and SOP C-2.0-QA-201 shall'be follo ed. 3.0 POLICY A. Eating, storing, or preparing food is not permitted in any areas where uranium is handled. B. Smoking and storing of Tobacco is not permitted in the controlled area. C. The use of food containers (milk bottles, thermos, etc.) for handling or storing uranium is not permitted. D. Employees working with uranium and all other personnel leaving the Lab must completely survey themselves for uranium contamination before I leaving the work area. A separate log is provided for individual clearance of small personal items such as clipboards and paperwork. E. White labcoats, completely buttoned, and gloves, either rubber or disposable y lastic type, is required for working or handling uranium {- or touching.potentially contaminated equipment, i i 'i r. CSMpaNT PalvAfg ~h $r i hR 3 tun Pagptsgo SY 888WIS SY Daft isguge a e v. syngeC8086 P400 WILMING N ENGINEERING [ t - Appendix 8 JD20 m s es ne t. Rcdictica Safety - Lab Oparating Procadure ao 0.3.4 cow 'l F. All spills or leakage of uranium must be cleaned immediately. G. Radiation Protection must be contacted to perform release surveys of all equipment leaving th.e controlled areas. H. All compounds of uranium that could become airborne shall be handled inside of hoods with air flow of 80-120 LFM throuch the apertures. Examples of this is (1) Opening of powder sample containers (2) Crushing of pellets, wefehine, etc., (3) Dumping and compositing samples for return to Shop Operations, (4) Dissolution and concentration of uraMum samoles by heating. k!~L!7 'S Prepared By k Authorized By "V 3 Engineering Concurrence // AS Nuclear Safety Concurrence h)Mt 4 /gp/73 0 99 4 8 A te l C O tt 0 O as d(fxhd'tX omiIed covtYdn inkutiot 1 prokec.te.d utdex \\o c.0R &. M O. G Ge O . ~ ~ .,/ J @A SUBJECT GENERAL C0r4 TROLLED AREA RULES N 3 u e Conduct 1. No food, drinks, gum or tobacco are pemitted in the Controlled Area. 2. Report all injuries to your Supervisor, to the Medical Unit (X-5333) and to Radiation Protection (X-5858). 3. Cuts and skin abrasions must be properly treated by the Medical Unit before working in the Controlled Area. 4. Assume that all surfaces and objects are contaminated unless Radiation Protection advises otherwise. 5 !. Take extra care to prevent airborne contamination. 5 6. If working under a Radiation Work Pemit (RWP), careful'ly read and follow the reouirements. Note any special instructions. If there are any questions, contact your Supervisor or the Radiatiop Protection office (X-5858). 7. Removal of tools, equipment or materials from the Controlled Area requires a release by Radiation Protection (X-5858). Prevent spread of contamination -- clean up spills of uranium or uranium-bearing ). 8. liquids as soon as possible. Report large spills to Radiation Protection (X-5858 u 9. Limit the amount of material to be contaminated or to be disposed of as contaminated waste. 10. Irmiediately report incidents of gross personnel contamination to your Supervisor and to Radiation Protection (X-5858).
- 11. Protective hearing devices (ear plugs, ear muffs, etc.) are not to be worn due to the potential for personnel contamination.
Page 1 of 3 ,2),/h4,, WCMAR ENGNEERNG [ DATE ISSUED W CLctfflim 441MW 5V6M W2 3Ad3. ' AREA MANAER(S) ~ i PLEASE RETURN THIS PROCEDURE TO ITS PROPER LOCATION AFTER READING l ,NF4-048A (6/81) .,, / Appendix 10 . gDg NUCLE AR. S At-t:1 Y Mt:Lt: Mon i mmoatsee.o o e1CR04 / s REYWON 3 h SUBJECT GENERAL CONTROIm AREA RULES Warning Signs / Flashing Lights o For conditions causing a high airborne contamination area, a contaminated area or a high radiation area, one or more of the following may be used to alert personnel: 1. Yellow and magenta (reddish purple) rope or tape and Yellow and magenta signs displaying various warnings or protection requirements (Example: full face mask required). 2. Flashing yellow light only authorized personnel wearing appropriate protective clothing / equipment are permitted within the marked off area. Containment Requirements e-Conduct all activities which could generate airborne contamination, y/. 1 such as transfer or sampling of, uranium, inside glove boxes or vente ggis is necessary to break containment when making equipment If it 2. changes, wear appropriate respiratory protection devices and take extreme care not to spread contamination to the surrounding area, to the air or to the ventilation system. For work which may cause gross contamination, cover the immediate 3. area with paper and establish a step-off-pad to minimize contamination spread. Contact Radiation Protection for assistance (X-5858) prior to start of work. Keep containment hoods securely closed during normal operaticas, and ~4. assure that hood filters are changed as scheduled. Open containers of radioactive materials only inside of approved 5. Wipe visible contamination from containers immediately upon hoods. removal from hoods. A full f ace mask must be worn when breaking containment on equipment 6. or when opening a hood; unless specifically authorized by your Supervisor or Radiation Protection to use a half mask. Page 2 of 3 ~ m NF4-0488 (6/81) d@endix lL omil$d _ %4g Ihbmikio' proTecAccl undet. to cj g g,340, t O s
- MEMO TO DISTRISUTION - November 9, 1981 ATTACEMENT 1 G.EN ER AL h ELECTRIC siat co==.
5369 sart. September 15, 1981 co'its* B. F. Bentley A. Dada scrt. WMD QA Regulatory Compliance G. W. McKenzie G. E. Powers anonces. M/C J-26 C. F. Shipp W. B. Smallev suostet. SEPTEMBER 15, 1981 \\ C. M. Vaughan U,F6 GAS RELEASE W. J. Hendry, Manager Regulatory Compliance Based on chemical analyses of the 9 air sampler filters in the ADU vaporization room, preliminary results reporte?. by Ed Powers indicate that airborne levels averaged over a twenty-four hour period probably exceed 300 times the =aximum permissible concentration. In accordance with P/P 40-12 criteria " Airborne levels in a restricted area averaged over a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period in excess of 300 times MPC. (MPC is 1 X 10"'1 ' uCi/cc)", this has been classified as a Class II incident. W G. M. Bowman, Acting Manager Nuclear Safety Engineering dh eSD Appendix 12 3'