ML20151W181

Attachment I to Ltr,Consisting of Response to Allegation a Re Deliberate Reduction of Radiation Survey Results to Avoid Further Surveys

ML20151W181
Person / Time
Site:	Pilgrim
Issue date:	08/16/1988
From:	BOSTON EDISON CO.
To:
Shared Package
ML20151W177	List: ML20151W174 ML20151W181
References
FOIA-88-84, FOIA-88-A-36 NUDOCS 8808230369
Download: ML20151W181 (4)

Text

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Attachment !

RH ow. +. n Olegation A l Boston Edison Compar.y Docket No. 50-293 Pilgrim Nut ' ar Power Station 1.icense No. OPR-35 l l

Descriotion otADegation A On January 26, 1988 the following allegation was described to the Pilgrim  !

Station Chief Radiological Engineer by the NRC Senior Resident Inspector. The source of the allegation was not revealed. l 4 )

A Radiation Protection Technician submitted a survey that recorded loose surface  !

activity concentration greater than the threshold that would have required i further surveys. Upon review, a Radiation Protection Supervisor noted that l further surveys were required due to the smear activity level and brought this  !

to the attention of the technician. The technician, in the presence of the  !

sepervisor, reduced the recorded activity to a value less than the threshold i requiring alpha analysis. The technician resubmitted the survey for review by l the supervisor and it was accepted.

The allegation implied that survey records were commonly altered to avoid having

, to perform additional surveys, 3 l

Sumary Resoonse l

Prior to being informed of the allegation, Boston Edison had identified the problem and taken initial corrective actions. l An event was identified in which a survey record was alte6 3d in an attempt to resolve a supervisor's request for alpha activity information. Upon review, the supervisor identified the altered survey data.

\ Initial corrective actions which were completed on December 22, 1987, included correcting the titered radiation protection survey, and reprimands and reinstruction for the involved individuals. The issue of records falsification was not addressed by the initial corrective actions. Subsequent corrective actions included termination of the technician that altered the survey data.

Investigations revealed no additional evidence of records falsification, nor was the posting and control program compromised.

Detailed Resnonse

Background:

Guidance for performing contamination surveys is provided in Station Instruction i

"Contamination Survey Techniques" SI-RP.3510. Alpha activity analysis is required for each contamination survey with results greater than 50,000 dpm/100ceZ.

For these survtys the smear with the highest activity level that is

less than 500,000 dpm/100caz is analyzed for alpha activity. The upper activity limit for alpha analysis is to prevent contamination of the counting equipment.

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Attachment I (continued) F Management personnel

,<Investigation Methodology: d by both Radiological d SectionInvestigatio -

./ ical Assessor. F" l eview of past survey recor s.the Investigations were conducteand were postulated to be: rvey resultsIndepend value 5

personnel interviews and rof records falsifica Indicators t rcorrections than 50,000 dpm/100ca2 (presumably in Incidents of (

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1. where levels of grea e 2 l

of less than 50,000 dpm/10are cm2 known to 49,000to be greater dpm/100cm than dpm/100cm arga contamination IcVelsistently reported as Surveys where/100cm' that are cons 2 50,000 dpTd dpm/100ca .

i n (RP) TechnicianThe Z Description of Event:contractor Radiation Protect 4 o

18,1987, a for supervisory review. l as 4 milli-rad /hr/100ca On Decembersubmitted recorded as 50,000 level was a drywell surveycontamina 00cm 4 dpm/

highest loose surface The next highest contamination1987, the Boston rded forEdison the 50,000 Compa dps/1t d the Upon review on December activ uired, 19,ity theThesupervisor was not recoannota ereje unting).

recognized that alphaAlthough analysis be performed. not procedurally esentative) req smear. for correction (i.e., alpha cot form directing ts.

that alphadelivered to th i d The technicianto activity discuss leveli 2 the greater survey commen thanHe also repor Rather, he required for smearequal to 50,000 dpm/100 ific guidance. cm the . di issue levels t give the Technician spec that the smears had been just fix it...".

The Site Coordinator did nostated, *...I'm bu d not want 50,000 himdpm/100c to isor. isory review discussion thatd the therecorded Sitefurther smear with the activity BEco fS a

The survey form ith the The Technician thea to 48,000 dps/100cm .

2 ltere eviewed the survey f r alpha activityand analysis obser win was A second BECo RP Supervisor Supervisor After discussing the needr owas referred to the or activity. matter The BECo Sr. Radiological BEco Sr. Ri Technician, the action. llowing initial actions. a tech Supervisor forevent andived initiated anthe oral fo reprimand b

- The Site Coordinator receSupervisor f

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Attachment ! (continued)

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. ,/ Investigation Hethodology:  !

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Investigations were conducted by both 8tadiological Section Manaqement personnel l'

and the Independent Radiological Assessor. Investigations cons'sted of i personnel interviews and review of past survey records. I Indicators of records falsification were postulated to be:  :

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1. Incidents of corrections (line outs) on contagination survey results l l where levels of greater than

of less than 50,000 dpe/100ca'[0,000 dpm/100ced were chang 6d to a value l dpa/100ce' to 49,000 dpe/100cm2)(presumably in the range of 45,000 , )

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, 2. Surveys where area contamination levels are known to be greater than i 50,000 d i I dps/100cg/100cm3thatareconsistentlyreportedaslessthan50,000 Description of Event: l On December 18, 1987, a contractor Radiation Protection (RP) Technician submitteo a drywell survey for supervisory review. The survey recorded the ,

l highest loose surface contamination activity level as 4 milli-rad /hr/100cm3  ;

i The next highest contamination level was recorded as 50,000 dps/100cm3  ;

Upon review on December 19, 1987, the Boston Edison Company (BEco) RP SuDervisor I recognized that alpha activity was not recorded for the 50,000 dpa/100cm3 l

smear. Although not procedurally required, the supervisor annotated the survey '

form directing that alpha analysis be performed. The rejected survey was delivered to the technician for correction (i.e., alpha counting).

The technician went to the Site Coordinator (contractor company representative) i to discuss the survey comments. The technician argued that alphg analysis was l required for smear activity leve11

, levels equal to 50,000 dpa/100 cad. greater He also than 50,000todpa/100ca',

reported not for the site coordinator i

i that the smears had been discarced and therefore unavailable for alpha analysis, The $1te coordinator did not give the Technician specific guidance. Rather, he i stated, "...I'm busy now, just fix it...".

The Technician inferred from the l discussion that the further with the BECo Supervisor. Site Coordinator did not want him to discuss the issue

'! The Technician then altered the recorded smear activity from 50,000 dps/100cm2

to 48,000 dps/100cm2 The survey form was resubmitted for supervisory review.

1 j A second BEco RP Supervisor reviewed the survey and observed the changed smear activity. After discussing the need for alpha activity analysis with the Technician, the matter was referred to the originally involved Btco,RP 4

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Supervisor for action. The BECo Sr. Radiological Supervisor was notified of the event and initiated the following initial actions.

The Site Coordinator received an oral reprimand by the BECo Sr. RP

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i Supervisor for tailure to provide appropriate direction to a technician, i

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,, , ,, . e Attachment I (continue.g m

' The contractor RP Technician received A vritten reprimsnd for failure to follow procedure and was directed to review the "Contamination

, Survey Technique" procedure.

The survey form was changed back tg the originally recorded smear activity level of 50,000 dpa/100ca'. The survty form was also annotated indicating that the 50,000 dpa/100cm3 smear had been disposed.

i Critique of Event:

1 The lack of specific direction provided by the Site Coordinator wps inappropriate considering the leadership role assigned to the position.

The Technician falsified a radiation protection survey in a deliberate attempt to deceive BEco RP Supervision. The circumstances of poor guidance by the contractor Supervisor and the small change in value (less than the known error for the counting system) were not mitigating

) due to the clear intent to deceive.

Radiation Protection Supervision failed to recognize the overriding 3

issue of records falsification which was not addressed by the initial corrective / disciplinary actions.

Follow Up Corrective Actions Taken:

The disciplinary action for the contractor RP Technician was upgraded to termination.

' The situation was described to the headquarters office of the applicable contractor company. The contractor company notified BECo that disciplinary actions were taken against the Site Coordinator

] identified in the investigation.

i The issue of falsification of survey records was discussed with the RP Supervisors.

> The need for prompt notification and corrective action was matter discussed of intent not and that the determination of records falsification is a degree.

i records for falsification indicators was emphasized,The need to continua Resuits of the Review of Survey Records:

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Approximately four months of survey records were reviewed for indicators of i records falsification.

1 identified, No additional evidence of records falsification was

! liovever, the review identified several instcnces in which alpha analysis reviewedhad by RP notSupervision.

been documented when required on survey records that had been enforcement of the requirements for alpha analysis.This evidence showed a l i The corrective actions were to redirect and emphasizt the need for full compilance and enforcement of alpha analysis requirenents.

l A follow up review of records was cerformed approximately one conth af ter the l

Initial evaluation. Thisreviewshowedfullcompilancewiththealphaanalysis requirements demonstrating that effective corrective actions were taken.

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Impact on the Posting and Control Program:

The review of surve/ records showed a lack of adherence to the alpha ana;;iis requirements. Alpha survey results are used to determine a ratto of alpha

! emitting contamination to beta and gasuna emitting contamination. These ratios I are used as a final check to determine the adequacy of an area's posting and t

applied radiological controls.

' Pilgris Station performs waste stream analysis to develop scaling factors that

' allow rapid determination of activity from difficult to detect isotopes such as Transuranics (TRU). Since TRU would be the source of alpha activity at pligrim, the use of scaling factors compared to gross activity li valid to assess the adequacy of posting and controls. Our scaling factors for TRU show the beta and gamma activity to be a factor of approximately 3000 greater than the alpha i activity. The limit for posting as a contaminated area requires a ratio less i I

than 50. Therefore, the lack of adherence to the alpha analysis requirements did not tr. pact the posting and control program.

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