ML20214V829

Responds to NRC Re Violations Noted in Insp Rept 50-362/86-24.Violation Denied Since Health Physics Computer Data Sys Orad Archive Documents That Alleger Had Respirator in Possession & Nasal Swabs Did Not Show Contamination

ML20214V829
Person / Time
Site:	San Onofre
Issue date:	11/03/1986
From:	Baskin K SOUTHERN CALIFORNIA EDISON CO.
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20214V799	List: IR 05000362/1986024 ML20214V829
References
NUDOCS 8612090861
Download: ML20214V829 (12)

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Southem Califomia Edison Company:q <p ,

P. O. BOX 800 .

2244 WALNUT GROVE AVENUE ROS EM EAD. CALIFORNIA 98770 n En~ Erw e e^$'"N WCE

• RESIDENT November 3,1986 m r** <

3:3 303-840a U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region V 1450 Maria Lane, Suite 210 Walnut Creek, California 94596-5368 Attention: Mr. J. B. Martin, Regional Administrator

Subject:

Docket No. 50-362 IE Inspection Report No. 50-362/86-24 Response to Notice of Violation San Onofre Nuclear Generating Station, Unit 3 Mr. R. A. Scarano's letter of October 3,1986, issued IE Inspection Reports 50-206/86-35, 50-361/86-26 and 50-362/86-24, and forwarded a Notice of Violation (NOV) resulting from the July 28 through August 1 and August 11 through 15, 1986, inspection conducted by Messrs. H. S. North and J. E. Russell. In accordance with the requirements of 10 CFR 2.201, I Enclosure A to this letter contains the SCE response to the alleged violation. {

SCE was in compliance with all applicable regulations and procedural requirements regarding the respiratory protection requirements for the work performed on valve 531208MR135 under Radiation Exposure Permit 83001 on January 3, 1985. Although the retained records alone are not sufficiently definitive to conclusively show all the details of what occurred, SCE is certain beyond any reasonable doubt that work was not performed in violation of the Radiation Exposure Permit. The basis for our position does not rely on any single record but rather is based on the preponderence of evidence as discussed in detail in Enclosure B, " Statement of Fact and Circumstances."

SCE requests the NRC withdraw the alleged violation.

Very truly yours, vWh

Enclosures:

As stated cc: F. R. Huey (USNRC Senior Resident Inspector, Units 1, 2 and 3) 8612090861 DR 861203 ADOCK 05000362 PDR

. J2Wl 2

h ENCLOSURE A Response to the Notice of Violation contained in Appendix A to R. A. Scarano's letter of October 3, 1986.

Appendix A to Mr. Scarano's letter of October 3, 1986, states:

" Technical Specification 6.8.1 specifies that written procedures shall be established, implemented and mr.intained. Procedure 50123-VII-9.9, Revision 3, Radiation Exposure Permit Program, specifies in Section 6.3.3 that all personnel covered by the REP must follow the requirements specified in the REP. Radiation Exposure Permit 83001 required use of a respirator while working on Valve S31208MR135.

" Contrary to the above requirement, an individual performed work on Valve S31208MR135 under REP 83001 on January 3, 1985, and did not wear a respirator as required by the Radiation Exposure Permit.

"This is a Severity Level IV Violation (Supplement IV)."

RESPONSE

1. Denial of Violation Based on careful review of the evidence, and on the sworn statements of individuals involved, SCE denies that an individual performed work on valve S31208MR135 under Radiation Exposure Permit (REP) 83001 on January 3, 1985, without wearing a respirator as required by REP 83001.

2. Basis for Denial .

SCE, as discussed in detail in Enclosure B, believes that the preponderance of evidence demonstrates the allegation is false. As a result of an extensive investigation into this matter, SCE has determined the following facts:

• The Alleger was accompanied by a contract HP technician, who provided a sworn affidavit that he wore a respirator and would not

. have permitted any individual whom he accompanied to perform the job without a respirator.

• The Health Physics computer data system ORAD archive on the Alleger's respirator use documents that the A11eger had a respirator in his possession for his task under REP 83001.

• Records indicate that the Alleger's nasal swabs did not show contamination, which should have been present had he not worn a respirator.

• The need for a respirator on REP 83001 was clearly established by a previous radiation survey. Available HP foremen and technicians have stated it was " common knowledge" that a respirator was required for entry into this area, and that they are not aware of any confusion regarding REP 83001. No HP personnel recall denying the Alleger a respirator.

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? ENCLOSURE A

2. Basis for Denial (Continued)

The Alleger made no statement to his supervisor, who has provided a sworn affidavit, regarding any unusual health physics / radiological activities or concerns about the work under REP 83001. Over 18 months have transpired since the work under REP 83001.

3. Corrective Steps Which Have Been Taken and The Results Achieved Notwithstanding that SCE believes this allegation is baseless and unsubstantiated, SCE, in reviewing this issue, identified enhancements made to the HP program either prior to, or subsequent to, the allegation and following the alleged event. These actions include:

(1) Administrative controls on the documentation of worker respiratory protection used during REP entries were strengthened prior to becoming aware of the allegation; (2) SCE issued a notice on October 31, 1986, which will be periodically reissued, to HP personnel to remind them of the importance of their sensitivity to a worker's concerns regarding REP requirements; and, addressing those concerns prior to commencement of work activities; and, (3) the existing counseling program has been expanded to include all radiation workers.

4. Corrective Steps Which Will Be Taken To Avoid Further Violations No corrective steps to avoid further violations are necessary in regard to this allegation.

5. The Date When Full Compliance Will Be Achieved SCE was in full compliance with all applicable regulations and procedures for the respiratory protection requirements for work performed on valve S31208MR135 under REP 83001 on January 3, 1985, 2

1

j ENCLOSURE B Statement of Fact and Circumstances

Background

San Onofre Unit 3 was returned to service in early December 1984 following a steam generator repair outage. At the time of the Unit 3 restart, Unit 2 had been shut down two months for its first refueling. Upon Unit 3 resuming operation in December 1984, airborne activity from gaseous fission products occurred whenever leaks developed in valves associated with the Unit 3 letdown system. The gaseous fission products were present in the Reactor Coolant System as a result of fuel cladding defects.

During the first 2 days of January 1985, several leaking valves in the Unit 3 side of the 24' level pipechase were identified. Attempts were made to mitigate the resulting airborne activity by: (1) identifying the leaking valves and initiating appropriate repairs; and (2) hanging a herculite barrier across Room 206 between the Unit 2 and Unit 3 ends of the pipechase, thereby attempting to confine airborne radioactive gases to the Unit 3 end.

Initial Attempt to Repair Valve MR135 Valve S31208MR135 (MR135), located in the 24' level pipechase, was identified as leaking on January 2,1985, and Maintenance Order (M0) 85010116 was written to repair the valve. The M0 instructions were " attempt to tighten leak (sic) pipe cap".

Boiler and Condenser (B&C) mechanic, Mr. Dan Reed, was assigned to correct the condition noted in the M0. He attempted to initiate work on the M0 the .

evening of January 2, 1985, but found that due to radiological condition (known airborne contamination in the 24' level pipechase area), he was not permitted by HP at the HP Control Point to perform work under the Radiation Exposure Permit (REP) for " Minor Maintenance", REP 82151. This was because the REP did not require sufficient dosimetry, protective clothing, or respiratory protection equipment. Therefore, at 0100 on January 3, 1985, Mr. Reed submitted a request for a new REP specifically for this M0. A new REP, 83001, was issued, which required that a survey be performed upon each entry and that protective clothing (PCs), special dosimetry and a respirator be worn, in addition to varying field dosimetry, plastic rainsuit and extra booties and gloves.

Mr. Reed obtained his PCs, dosimetry and a respirator and at 0715 entered the 24' level pipechase under REP 83001 to repair valve MR135. Mr. Reed was accompanied by an HP Technician, Mr. M. Greene, who took air samples specifically in preparation for the entry by Mr. Reed. Mr. Greene and Mr. Reed both wore respirators in accordance with REP 83001.5 Mr. Greene's radiation survey was documented as Survey #5003-14. The air sample results 5 NOTE: Mr. Greene provided a sworn affidavit that they both wore respirators in accordance with REP 83001. Mr. Reed's respirator useage is also recorded in the Health Physics computer ORAD archive.

Health Physics technicians, because they make many entries per shift, have not recorded their individual entries in order to minimize unnecessary paperwork. Therefore, HP technician respirator ,

useage documentation is not available in ORAD. '

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,- ENCLOSURE B Initial Attempt to Repair Valve MR135 (Continued) were: 85% MPC particulate activity, 51% MPC iodine activity, and 123% MPC noble gas. Furthermore, Mr. Greene noted "... boron covers virtually the whole valve, vv is approximately 8 feet from floor,10" wide boron lined river on floor (water) leading to nearest drain hole."

When attempting to perform the repair, Mr. Reed was unable to reach the valve and noted this fact as a comment on the M0 "...but could not get to cap. I am too big. Dan Reed.". Since the leak remained, another, smaller individual was selected to work on the valve.

Second Entry for Valve MR135 Repair At 1441 on January 3,1985, a second B&C mechanic (the A11eger), entered the 70' level HP control point on REP 83001 and began preparations (i.e.,

obtaining appropriate dosimetry, respiratory protection and donning protective clothing) to enter the 24' level pipechase. The A11eger entered the pipechase at 1515, accompanied by Mr. Patrick Corbett, contract HP Technician2 .

Mr. Corbett performed airborne radioactivity sampling, specifically for the Alleger, as Mr. Greene had done for Mr. Reed, with similar airborne activity results: 55% MPC particulates; 205% MPC Iodine; and, 532% MPC noble gas.

The record of the Alleger's entries and exits on January 3,1985, were recorded in the Health Physics computer data system ORAD archive. For his entry at 1441 under REP 83001, the Alleger's entry into Job Location Code (JLC) 404, the 24' level pipechase, was tracked by use of an Individual MPC-hr Tracking Card (IMTC) or personnel log, which was used as the source document from which data were entered into the ORAD. The data entries into the ORAD are separate and independent from any requirements listed in the REP (i.e.,

the ORAD does not use the REP as a source document). The Alleger's record in ORAD is as follows:

Time Respirator Enter Exit JLC' Type

• 1441 1515 598 04 1515 1535 404 (Blank) 1535 1536 404 04 1535 1700 598 04 8 JLC - Job Location Code:

598 - Radwaste Building common area 404 - Radwaste Building 24' Elevation (location of valve)

• Respirator Type - 04 used to identify MSA Ultra View respirator with High Efficiency Particulate Air (HEPA) cartridge 8 NOTE: Mr. Corbett provided a sworn affidavit that, for work performed in the 24' level pipechase area, he wore a respirator and he would not have permitted the B&C mechanic (A11eger) to perform the job without a full face respirator.

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,. ENCLOSURE B Second Entry for Valve MR135 Repair (Continued)

The 34-minute period 1441 to 1515 is considered a reasonable time for job preparation and donning protective clothing. The 20-minute period 1515 to 1535 was for the actual work performed on valve MR135 at location 404. The ORAD data documents that the A11eger had a respirator in his possession at the start (1441) and conclusion (1535) of his task, confirming REP 83001 required a full face respirator.

The 1515 to 1535 entry for respirator type is blank; however, this entry was corrected by the ORAD computer clerk by adding a one minute record from 1535 to 1536. Making a second entry was the only method of correction available to the computer operator (the system would not accept a correction once data was entered). Therefore, the ORAD correction record of 1535 to 1536 was in full compliance with HP ORAD computer practices.

It is important to note that no other valid reason exist:; for this computer entry, since no worker would re-enter the work area for 1 minute wearing a respirator. In further support of the one-minute record being a correction to the previous 1515 to 1535 entry, is that the period 1535 to 1536 is " double counted" by being contained in the subsequent entry period of 1535 to 1700. If ,

the one-minute record were not a correction, the next entry wou d have been 1536 to 1700.

Post Repair Activities The A11eger and Mr. Corbett exited the pipechase at 1535. The 24' level HP Log noted that the valve was still leaking approximately 1 drip /second at the time of exit.

Upon reaching the 70' level HP Control Point, all personnel are required to check themselves for inadvertent contamination by radioactive material. When the A11eger performed this " frisk," he discovered facial contamination. Facial contamination has been found to occur as a result of improper removal of a person's respirator (i.e., when " pulled off" improperly, any material on the exterior edges of the mask will fall on or be dragged across the face). The HP Technicians at the control point completed a Personnel Contamination / Injury Report in accordance with established procedures.

As reported on the contamination form, the external skin of the nose was contaminated to 500 cpm. This external skin contamination was reduced to 200 cpm by decontamination and further reduced to 100 cpm by allowing decay of short-lived isotopes (the counts decreased with time). The short lived radioisotopes are typically daughters of noble gases; the key characteristic of this type of external skin contamination is the very short halflife (Rb-88,17 minute halflife). Therefore, for the Alleger's contamination, time was used to permit radioactive decay. The skin dose was conservatively estinated to be less than 1 mrem.

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,. ENCLOSURE B Post Repair Activities (Continued)

A nasal swab of the inside of the nose for internal contamination was obtained prior to decontamination activities and the results were negative. The absence of activity on the nasal swab is significant because had the A11eger not worn a respirator, detectable levels of contamination should have been found on the nasal swab. Calculations have shown that detectable levels of particulateTshould still have been present on the nasal swab had the Alleger failed to wear his respirator.

In accordance with procedures regarding facial contamination, a whole body count was required. The Alleger received a whole body count at 1811 on January 3, 1985.

The " action point" for initiating further HP investigation is 1% of the Maximum Permissible Organ Burden (MP08). Procedures require a more extensive body count (lay down counter) if an isotope exceeds 1% MPOB, or a dose evaluation if the level exceeds 5% MP08. For the A11eger's January 3,1985 count, Co-58 was detected at approximately 0.7% MP08, which is below any action level. Since the effective halflife of Co-58 in the human body is 8.4 days, no significant reduction in the detectable level of the isotope would have occurred between the time of first detection (frisking) and the time of the body count (less than 0.9% difference assuming contamination occurred at 1535, and body count at 1811). In any event, since the level detected was not significant and was orders of magnitude below allowable exposure limits, nc further action was necessary or taken.

SCE Investigation into the Allegations -

SCE has reviewed the NRC inspection report 50-362/86-24 and has thoroughly investigated its allegations:

I. A11eger was denied use of a respirator On October 21, 1986, SCE legal counsel met with the Alleger and his attorney. The Alleger again stated he had been denied the use of a respirator. However, the A11eger did not know the name of the HP person (s) who denied him the respirator, nor did he believe he would be able to identify them from pictures of HP staff obtained from site badge photographs. The Alleger further stated that the Technician who accompanied him on REP 83001 (he could not identify him) did not wear a respirator either.

As previously discussed, the ORAD documents that the A11eger had a respirator for work performed on January 3, 1985, under REP 83001.

The A11eger was accompanied by a contract HP technician who has provided a sworn affidavit that he wore a respirator and would not permit any individual whom he accompanied to perform the job without a respirator (this directly contradicts the Alleger's statement that the HP technician did not wear a respirator).

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i; ENCLOSURE B 2 I. A11eger was denied use of a respirator (Continued)

If the Alleger had not worn a respirator, he would have had detectable levels of particulate activity on his nasal swab. Since no activity was present and he had a respirator issued to him as .

discussed above, we corclude the A11eger wore a respirator. .-

As documented by the ORAD archive for Mr. Reed and the sworn affidavit obtained from Mr. Greene, both individuals wore respirators for the 0715 entry. Therefore, it would be inconsistent for HP to change the respirator requirement of the REP subsequent to s the 0715 entry. "',t SCE discussed with the on duty HP Foreman the need for a respirator for the 24' level pipechase. The HP General Foreman on duty

January 3, 1985, Mr. S. Jones, provided a sworn affidavit that he ,

was fully aware of Mr. Greene's survey (performed prior to the <

Alleger's entry), and based on that data he would not have permitted any work on the MR135 valve under REP 83001 without the use of a respirator; nor does he believe any confusion resulted from his correction on the REP. _

Discussions with available HP personnel who were on duty on ..

January 3, 1985, established: (a) personnel did not recall denying anyone a respirator; and (b) personnel recalled it was " common knowledge" that work performed during January 1985 in the Unit 3 end of the 24' level pipechase required a respirator due to the airborne activity and boric acid crystals. On the contrary, HP personnel .

state they would not have permitted personnel to enter the area -

without a respirator, nor would they have entered the area ,

themselves without one. It is inconceivable that an HP technician ~

t would wear a respirator and not require accompanying personnel.to wear one. ,

The Alleger's supervisor, Mr. J. Kipfstuhl, provided a sworn .

affidavit that the A11eger never made any statement (s) regarding any -

unusual health physics / radiological activities or concerns about the j work on MR135 under REP 83001.

Therefore, there is a preponderance of evidence that the A11eger wore a respirator.

II. A_11eger notation on M0 documented denial of respirator As stated in the NRC inspection report, the wording on the MO states:

. . . Also: A respirator should be worn as there are boron -

crystals approx. 1" thick covering this VV and connecting pipes. It is not possible to avoid stirring up airborne contamination." The NRC inspection report further states, "With respect to his (A11eger) notation, beginning with the word 'Also:' was meant as a warning to l others who might be called upon to work on that specific valve or in

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---w.- ---- , - - - -, - - , - - - --c,., . - - - - . - - - - - - -

,- ENCLOSURE B J II. Alleger notation on M0 documented dental of respirator (Continued) that area." This caution on boric acid crystals could as easily be interpreted as a fact that should be known (similar to the notes on the presence of boric acid crystals in Mr. Greene's 0715 survey results) and net as difficulty in obtaining a respirator.

Therefore, the specific wording of the M0 neither supports nor rejects the allegation that the Alleger was denied a respirator.

~

III. A correction on the REP caused confusion The NRC inspection report states that REP 83001, which was used for both Mr. Reed and the Alleger's entry, contained a correction, as follows: "In the Section V - Respiratory Equipment, portion of the REP, the block indicating Full Face Particulate had been checked and footnoted with a circled 3. Footnote circled 3 in the REP Section VI - Special Instructions to Workers specified, ' required for entry into Unit 3 side of pipe chase'. The circled 3 in the Section V and the circled 3 footnote in Section VI had been lined out and initialed by the then HP Foreman, Individual 'B'."

The NRC report concludes "... the interviews with the HP Foreman, s Individual 'B', and the job coverage technician, Individual 'E',

indicate that a respirator was both required and would have been used... It appears that as the result of confusion concerning the requirements of REP 83001, no respirator was issued or used contrary to the requirements of REP 83001."

In the sworn affidavit obtained from the HP General Foreman (Individual 'B'), he states that he deleted the footnote on respirator usage in the Unit 3 end of the pipechase to ensure that a respirator would be worn at the specific jobsite. The HP Foreman t further states: he remembers this job because of the physical condition of the area (boric acid crystals); and recalls specifically discussing with other HP technicians immediately

)-

after ("tailboard") the Greene/ Reed entry, the necessity for respiratory protection for future entries. Both the HP Foreman and the HP Technician covering the job, in the sworn affidavits obtained

- state that they were not confused by the correction to the REP.

S.CE, because of the length of time (18 months) since the incident, has not been able to contact all HP personnel who were on duty on January 3, 1985; however, of those persons contacted, none has ixpressed confusion as to whether the 24' level pipechase would have raquired a respirator. '.

During the day on January 3, 1985, prior to the A11eger's entry the

" computer" record copy (i.e., the "hard copy" original of the REP is posted and a copy is used to enter a computerized version of the REP into the HP computer system) of REP 83001 was changed and the REP respirator requirement was erroneously deleted. Although the ORAD a chive documentation that the Alleger wore a respirator is

. unaffected by this condition (0 RAD does not utilize the original or computer copy of the REP), it may be that the computer data entry clerk (not an HP technician) was confused by the correction when 6

__ __ _ , . , , _g_... - . , . . . - . _ , _ ,

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• 3. .

ENCLOSURE B j III. A correction on the REP caused confusiort (Continued) he/she entered the REP into the computer system. Notwithstanding I.

the computer clerk's apparent confusion, no HP technicians who would V have controlled the job have expressed any confusion regarding this correction.

Therefore, SCE considers the NRC statement that confusion existed on the part of the HP Foreman and HP lechnician, to be mistaken.

! . IV. A11eger spent an hour straightening aut mistakes on the REP The NRC inspection report; states "...under 'the Work Done section of the M0 85010116 the Alleger made the following entry: 'obtained proper REP 8300-1 had to wait I hour to have std-6 (refers to t special dosimetry package) made up, also had to wait another hour trying to straighten out mistakes on REP'". The NRC report further states ".. .with respect to his notation on M0 85010116, he stated that the one hour he spent, ' ...trying to straighten out mistakes on the REP', whs expended in attempting to obtain a respirator for the work from the radiation protection staff."

SCE had obtained from the ORAD entry record for the Alleger, that prior to inititting work on MO 85010116, he had entered the radwaste building from-1335 to 1351, under REP 82152, " Minor Maintenance."

Upon exiting the radwaste building at 1351, the A11eger may have spent time getting his next assignment (M0 85010116). From his 1351 exit on the prior job until he re-entered radwaste to initiate MO 85010116 at 1441, only 50 minutes elapsed. From the ORAD data, the A11eger then spent 34 minutes (1441 to 1515) danning protective gc clothing and traveling to the job location. Therefore, the Allegee's statement that he spent two hours getting dosimetry and

" straighten out mistakes on the REP" is inconsistent with his documented entry / exit times. In fact, he apparently spent less than an hour (expected time) getting ready for the job.

V. Alleger received a bloody' nose during decontamination As stated in the NRC inspection report, the Alleger stated "...that the nasal swabbing resulted in a bloody nose. Individual 'F' (the HP Technician who performed the decontamination) stated that while he could not recall the specific event, his activities in this respect had never resulted in a bloody nose." SCE obtained a sworn affidavit from the HP Technician (Individual 'F') confirming his statemant to the NRC that he never caused anyone a bloody nose while performing decontamination activitie=.

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C, ,

• ENCLOSURE B VI. A11eger was held at the Control Point for 2 - 2 1/2 hours The NRC inspection report states "The A11eger stated during the July 30, 1986, interview that he had been held at the access control point because of the contamination for 2 to 2 1/2 hours, until a health physics representative on an oncoming shift directed him to go to the whole body counter." SCE reviewed the ORAD data for the Alleger and Mr. Corbett, which documented that the job-was completed at 1535 and the A11eger was released from the Control Point at 1700. Therefore, the maximum time was only 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and 25 minutes.

This time included removing the respirator and protective clothing, returning the special dosimetry, frisking, decontamination, and completing the personnel decontamination report. Therefore, the A11eger's statement that he spent 2 to 2 1/2 hours at the control point is inconsistent with his documented entry / exit times.

VII. A11eger was overexposed The NRC inspection report states "The letter, dated July 21, 1986, specified that .. 2 (The A11eger) was exposed to radiation in excess of regulatory limits." SCE examined the A11eger's exposure records, and provided them to the NRC. As further discussed in the NRC inspection report, "The licensee concluded that a total of 0.68 effective MPC hours exposure occurred. However, if a respirator had not been used, the exposure could have been increased to 0.86 MPC hours. Exposures of up to 40 MPC hours per week are permissable as specified in 10 CFR 20.103... In regard to the second allegation with respect to the exposures in excess of regulatory limits, the  !

allegation is not substantiated." -

Summary

1. Documentation from ORAD archives coupled with sworn affidavits obtained from the HP Foreman and the accompanying HP technician refute the l

allegation that the A11eger was denied use of a respirator.

~2. Interviews with participating personnel (HP foremen and technicians) establish that sufficient awareness and data (from Mr. Greene's 0715 radiological survey) was available to establish an obvious, clear requirement for a respirator. SCE believes, as supported by statements and affidavits from HP personnel, that no confusion existed among the HP technicians anc loremen regarding the REP respiratory requirements.

3. No detectable activity was present on nasal swabs; had the A11eger not worn a respirator, particulate activity should have been detected.

4. The Alleger was not overexposed to radioactive materials. In fact, his exposures were a small fraction of allowable exposure limits.

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Oa s e ENCLOSURE B Summary (Continued)

5. The A11eger is not considered credible as demonstrated by:

(1) his apparent misstatements on receiving a bloody nose, being held 2 - 2 1/2 hours for decontamination decay, and spending 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> getting dosimetry and straightening out mistakes on the REP; (2) the contradictory evidence, discussed above, from sworn affidavits obtained from other individuals; (3) that he never expressed any concern to his supervisor regarding work performed on valve MR135 nor on any aspects of his health and personnel protection against radiation from this event; and, (4) that it took 18 months for the A11eger to express any concern to SCE, and when the A11eger did so it was through a Workman's Compensation Claim against SCE for disability benefits due to the psychiatric trauma of being denied a respirator and being overexposed.

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