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 
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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. 
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                                                            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. 
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                                                            IN 84-59      
                                                            August 6, 1984 
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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

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