Re[2]: MIT Prelim Unusual Occurrence

[sandy_perle@email.fpl.com]

>>The point of my comment is that if the NRC wants licensees to report 
incidents voluntarily (i.e.., even though they are not required to by 
regulation), then the NRC should not take these events into the public arena 
until they have investigated the incident.  Why would a licensee 
voluntarily report events if the NRC is going to report the incident to 
the public and to Congress, before it has conducted a thorough 
investigation? <<

I agree, but it is obvious that they, the NRC as well as other regulatory 
agencies are concerned that if they don't publish everything, even before a 
thorough investigation is completed, that the public will perceive them to be in
league with the industry they are supposedly regulating. We, in the power 
industry, have had to deal with this issue and attitude for a very long time 
now. 

>>I disagree your statement that the fact that it was reported makes it an 
unusual occurrence.  I once reported an exposure on a film badge which, 
after investigation could only have come from the badge being deliberately 
sabotaged (placed in an irradiator).  The individual was not exposed.  
(If she had received the exposure she would have been dead.)  The fact 
that I reported it does not make the incident an unusual occurrence.
<<

If the NRC is going to publish a report or suspected finding, prior to the 
completed evaluation, then I stand by my statement. If the licensee believes 
that they are required, or believe that they "should" report the incident, then 
they come under the heading of an unusual occurrence, and the NRC will put out 
it's release on the incident, as they had done with this situation.

>>Would you agree that it would not be reportable and would not be an unusual
event if this was a case of a 1 uCi uptake due to mouth pipetting?  
Clearly it would be a violation of procedures.  I suggest that if it were 
only 1 uCi, then the NRC would have found it on a routine inspection, would 
have cited the institution, and mitigated the violation due to self 
discovery and prompt, comprehensive corrective actions.  Then the 
question becomes at what level does the event become an unusual occurrence?  I
believe that it should be at the reporting level - a TEDE of 5 rems.<<


I would agree with that, assuming that was the problem. I would be more 
concerned with the root cause of the uptake, rather than the sympton of the root
cause. The uptake is nothing but the outcome, not the causal factor. I still 
believe that if the licensee believes that there is a "potential" to exceed the 
limits requiring reporting, then they need to report the incident.

What this points out is that after all of these years, there are still 
uncertainties in what is rerquired, what is prodent and how should the 
information be published in the public forum and how much of it should be 
provided. It also points out the need for better documentation in the form of 
NUREG or Reg. Guide documents.



Regards,


Sandy Perle
Supervisor Health Physics
Florida Power and Light Company
Nuclear Division

(407) 694-4219 Office
(407) 694-3706 Fax

sandy_perle@email.fpl.com