Re: MIT Prelim Unusual Occurrence

[sandy_perle@email.fpl.com]

     Ken. I would suggest that even though the exposure "may" turn out to 
     be less than allowed by regulations, the event was "unplanned" and as 
     such has most likely violated procedures within the facility. In that 
     event, the NRC still likes to use the terms "had the potential to 
     exceed regulatory limits" and the only reason the incident "might be" 
     less than regulatory limits, it was only by chance and without any 
     interaction/intervention by the licensed facility. In the nuclear 
     power industry we have seen many facilities cited for this very 
     problem, the potential to exceed while not, after a thorough 
     evaluation of the actual dose to be assigned, or shall I say, the 
     "engineered" dose reconstruction, which miraculously seems to be just 
     under the regulatory limits.
     
     The fact that the incident was reported makes it an unusual event in 
     itself. After a review of the facility I surmise that they will at a 
     minimum be cited for violating their procedures, not having the proper 
     precautions in place to preclude this incident from happening, and 
     probably a citation of inadequate training.
     
     In any event, the incident was unfortunate and should not have 
     happened in the first place. Remember, the regulatory limits don't 
     imply good health physics practices. Those below being good and those 
     above meaning bad. Even with a small unexpected uptake or a small 
     external exposure is an indicator that the process is in trouble and 
     needs some serious evaluation. Countermeasures are necessary with a 
     follow-up program to ensure that the system functions as necessary.
     
     Sandy Perle
     Supervisor Health Physics
     Florida Power and Light Company
     
     (407) 694-4219 office
     (407) 694-3706 fax
     
     sandy_perle@email.fpl.com


______________________________ Reply Separator _________________________________
Subject: MIT Prelim Unusual Occurrence
Author:  radsafe@romulus.ehs.uiuc.edu at Internet-Mail
Date:    10/21/95 12:20 PM


The NRC prelim notification of unusual occurrence states that MIT 
assessed the _maximum_ uptake to be 579 microcuries.  Clearly, 
independent verification is warranted; however, my point is that since 
this is not an event which requires NRC notification why is the NRC 
making it an unusual occurrence?  
     
I agree that any "media" event involving licensed material should be 
reported to the NRC, and that the NRC should take appropriate inspection 
and enforcement actions if _violations_ of the regulations occurred.  
But, categorizing an uptake of radioactive materials under the allowable 
limit as a unusual occurrence (thereby reporting the occurrence to 
Congress) seems unwarranted.  At the time of the "Preliminary 
Notification of Event or Unusual Occurrence" the NRC had no knowledge of 
whether any regulations had been violated.  I maintain that if this had 
been an external exposure the event would not have been categorized as such.
     
What is (or should be) of concern to RSOs at Universities is whether this 
is a copycat of the NIH incident.
     
Kent Lambert
LAMBERT@hal.hahnemann.edu
     
Standard disclaimer.