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Information Notice No. 84-59: Deliberate Circumventing of Station Health Physics Procedures
SSINS No.: 6835 IN 84-59 UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT WASHINGTON, DC 20555 August 6, 1984 Information Notice No. 84-59: DELIBERATE CIRCUMVENTING OF STATION HEALTH PHYSICS PROCEDURES Addressees: All nuclear power reactor facilities holding an operating license (OL) or construction permit (CP). Purpose: This information notice is issued to alert licensees to events where station health physics procedures have been circumvented relative to work performed by contractor personnel. In some of these events, the individual(s) involved circumvented plant procedures to underestimate the exposure and thereby extend the period of employment. It is expected that recipients of this notice will review this information for applicability to their facilities. Because the suggestions provided in this notice do not constitute NRC requirements, no specific action or response is required. Description of Events: 1. Dresden Nuclear Power Station In October 1983, two contractor employees were escorted on-site by the electrical maintenance foreman to make repairs to the radwaste processing control system. The Radiation/Chemistry Department was not informed of the visit; consequently, neither person received training or dosimetry devices. During the ensuing maintenance the contractors made several entries to the drumming room, which was posted and controlled as a high radiation area (HRA) and a potential airborne contamination area without health physics coverage. No surveys were taken of the area before the entries. Entry into the locked HRA was apparently possible because of a broken door closer. Station personnel and others frequenting the area knew the door could be forcefully pushed open, circumventing the lock access control. A civil penalty of $140,000 has been issued for this incident. 2. Brunswick Steam Electric Plant The following two events involved a single contractor on the Brunswick site. This contractor has since been denied access to the site as a result of other incidents of falsifying the security documentation of its employees. 84080100333 . IN 84-59 August 6, 1984 Page 2 of 4 On October 28, 1983, a contractor craftsman requested Health Physics (HP) personnel to issue him a hand held radiation detector instrument. While issuing him the instrument, the HP personnel collected and reissued the individual's thermoluminescent dosimeter (TLD). The HP office was in the process of completing the monthly TLD collection and noticed the individual's badge had not been changed. The individual's TLD was subsequently read and indicated 9.9 rems. Although the TLD had the individual's name sticker on it, the serial number was found to be that of an area monitor badge placed in the plant earlier in the year. When confronted, the individual admitted to wearing the wrong badge. He also stated that after the TLD was taken he enlisted the help of a friend who unsuccessfully tried to get the TLD back from the HP personnel. Disciplinary action was taken by the license/contractor against the two individuals involved. On November 1, 1983, while preparing to issue a contractor a respirator, licensee personnel discovered that the individual had been issued a respirator earlier and had not returned it. On investigation it was learned that the respirator checked, out earlier was being worn by another individual in violation of the station respirator protection procedures. Disciplinary action was taken by the license/contractor against the two individuals involved, they were fired. 3. Allegations The following two events involve allegations of contract workers circumventing HP Procedures at the Brunswick Plant. On investigation these allegations could not be substantiated. However, they are added here to illustrate additional methods that could be used to circumvent procedures. On November 1, 1983, the licensee management was notified that two contract personnel, fired that day, alleged that several "extra" TLDs were being held in the contract company trailer. It was alleged that some contractor employees would use these TLDs instead of their own while in radiation fields so that the recorded dose would remain low, which would allow them to work longer at the plant. The allegers stated that when a substitute TLD was worn, the individual would purposely drop his self-reading pocket dosimeter (SRPD) sending it off-scale. Procedures require that when a SRPD goes off-scale a read-out of the individuals TLD be taken to verify that an overexposure had not occurred. Allegedly, the individual would change back to his official TLD before having it read. Therefore, a lower than actual dose would be recorded and the licensee's TLD vs. SRPD comparison program would be circumvented. The licensee unsuccessfully searched the contract trailer for the "extra" TLDs. A similar event, involving a different contractor, occurred earlier in 1983. It was alleged that certain persons would remove the TLD element holding tray from their dosimetry badge and leave the tray outside the high radiation area, thus keeping the recorded exposures below plant administrative limits. Only a close examination of the TLD badge would reveal that the TLD tray was missing. . IN 84-59 August 6, 1984 Page 3 of 4 It also was alleged that the SRPD vs. TLD comparison program was defeated by the use of a second SRPD (also kept in a low radiation zone) or by individuals reading their own SRPD and reporting a lower; exposure value. The resulting investigation could only confirm that some HP technicians allowed workers to read their own SRPD. As part of the actions taken at Brunswick to prevent improper use of TLDs, the licensee has established a special personnel dosimetry surveillance program. The surveillance ensures that selected personnel exiting high exposure jobs report directly to the dosimetry office with the TLD worn at the time they exited the work area. The TLD is checked to ensure it is the one issued to that individual. 4. Indian Point Nuclear Unit 2 A 1981 NRC investigation substantiated that some cleaning and decontamination contract personnel, including supervisors, purposefully circumvented HP procedures to minimize the recorded radiation exposure. Practices similar to those alleged above, including the failure to log actual radiation exposure and the failure to wear required dosimeters were noted. The investigation indicated that some individuals were purposely recording lower than actual SRPD readings then "losing" their film badge just before the monthly badge collection and reading. The investigation noted that these contract personnel "lost" a disproportionately large number of film badges as compared to other groups working at the facility and that the licensee did not identify the abnormal badge loss rate even though some individuals reported as many as three badges lost in a quarter. In addition, the investigation noted that contractor supervisory personnel were removing terminated contract workers badges from the badge rack and wearing them in place of their own. A civil penalty of $40,000 was issued for this incident. Discussion: The licensee is responsible for the activities of onsite contractors. The licensee should be aware that some contractor personnel see an economic incentive in taking short cuts to expedite a job or in falsifying dosimetry records to keep recorded dose low. Some of these contractor personnel do not seem to realize that the health physics program is provided, in part, for their protection. Only the continued application of strict controls can minimize recurrences of these practices. Misuse of personnel dosimetry devices can be minimized by establishing a program that restricts worker access to dosimetry badges other than their own (especially those of terminated employees) and by periodic spot checks to ensure workers are wearing the badges assigned to them. Also, dosimetry procedures should include a program to detect and investigate situations where lost badges or dropped SRPDs occur at a higher than normal rate. . IN 84-59 August 6, 1984 Page 4 of 4 No written response to this information notice is required. If you need any additional information about this matter, please contact the Regional Administrator of the appropriate Regional Office or this office. Edward L. Jordan Director Division of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement Technical Contact: R. L. Pedersen, IE (301) 492-2967 J. E. Wigginton, IE (301) 492-9425 Attachment: List of Recently Issued IE Information Notices
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