ML20204E714

Forwards Suppl Input to SER Summarizing Status of TMI Lessons Learned Items Which Includes Site & Corporate Visit on 810120 & 21

ML20204E714
Person / Time
Site:	Diablo Canyon
Issue date:	02/17/1981
From:	Kreger W Office of Nuclear Reactor Regulation
To:	Tedesco R Office of Nuclear Reactor Regulation
Shared Package
ML20204E477	List: ML20204E471 ML20204E714 ML20206A861
References
FOIA-84-21, RTR-NUREG-0578, RTR-NUREG-0660, RTR-NUREG-0694, RTR-NUREG-0737, RTR-NUREG-578, RTR-NUREG-660, RTR-NUREG-694, RTR-NUREG-737, TASK-1.B.1.2, TASK-2.B.2, TASK-2.B.3, TASK-2.F.1, TASK-3.D.3.3, TASK-TM NUDOCS 8103090250
Download: ML20204E714 (12)

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,,0 4 Docket $os.: 50-775 FEB 171981 d ana 50-323 RESIONVist REGl0Nylag W I MEMORANDUM TOR: Robert L. Tedesco. Assistant Director i

for Licensing, DL g FROM: William E. Kreger, Assistant Director -

for Radtation Protection, DSI *

SUBJECT:

$1ABLO CANYON # SUPPLEMENT TO SAFETY EVALUATION REPORT l x . i PLANT HAME: Diablo Canyon Nuclear Power Station Units 1 and 2 i LICFNSING STAGE: OL .

DOCKET NUMBERS: 50-275/323 1 Mll ESTUNE NUX8ER/ BRANCH CODE: 40/33 RESPONSIBLE BRANCit: LBf3; 8. C. Buckley, l.PM '

DESCRIPTION OF RESPONSE: Supplement to SER  ;

REVIFW STATUS: Continuing Enclosed is a suppl . ent to the Diablo Canyon safety Evaluation Report. There are no open ite.?.s for Fuel Loading. This report suenarizes the status of the ,

Three Mile Island Lessons Learned items from NUREGS-0578/0737 which are reviewed by the Radiation Protection Section (RPS) and includes results from the site and corporate visit on January 70 & 21,' 1981. The RPS review encompasses:

Item II.B.2(2.1.6.b) - access to areas, not including vital equipment protection; Its II.B.3(2.1.8.a) - post-accident sampling ALARA considerations, not including systems and procedures; Item II.F.l(2.1.8 b - high range in-containment ractation monitors; Item III.D 3.3(2.1.8.c))- portable radioiodine air .

sampling and analysis; and Item I.B.I.2 from NUREGS-0660/0694 - radiation protection organization only.

Status of Review -

11.8.2 -

Open for full power - Response from aDplicant expected in feDruary.

• Final SSER subject to Formal submittal.PG&E has draft document completed. Explanation attached.

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II . T.1 - Complete for fuel Loading. Closed for full power subject to receipt of additional commitments regarding in-situ calibration and '

ralibration frequency requested. SSER attached.

111.D.3.3 - Satisfactory / Complete for FL/FP - Updated SSER attached to Cctober 28, 1980 letter. }-

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1 s ,i l i I . 8.1. 2 - Satisfactory /Completc for FL/FP - subject to receipt of written comi tments. SSER attached.

11 B.3 - Satisfactory /C'omplete for FL - SSER attached to October 28. . l 1980 letter.

This evaluation was performed._by R. J. serbu. RPS. RAB.

William E. Kreger, Assist t Director for Radiation Protection Division of Systems Integration Fnclosure:

As Stated cc: w/ enclosure D. Ross F. Miraglia

.r B/ Buckley

' O. Collins  :

"T. Murphy R. Serbu i

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iii, APPLICANT'S FILINGS . .

tiy letter dated 9/3/80, PG&E has subaitted commitments and docurr.entation of actions to be taken at Diablo Canyon to implement short term lessons learned in accordance with NUREGS-0660/0694. Through interviews conducted during ,

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an on-site visit at Diablo Canyon on 1/20/81, and. at PG&E Corporate Head- I quarters on 1/21/81. .PG&E provided additional positions and made commit-ments to implement short term lessons learned in accordance with NUREGS- '

j 0660/0694.

. iv. STATUS REPORT -

c O .. l Discussion and Status i The Radiation Protection Organization .(Chemistry and Radiation Protection)'

at Diablo Canyon has been evaluated in accordance with NUREG-0578/0660/0694,

, and the organization is acceptable in structure and functions for. both fuel j loading and full power operations, j

I In the Diablo Canyon Chemistry and Radiation Protection (C&RP) Organization, the Supervisor (equivalent to Radiation Protection Manager) reports to a high level plant pusition - the Plant Superintendent, along with operations, j

g m'aintenance, technical, and clerical organizations. This places the radiation ,

protection function on the same level as the operations functions, and provides  ;

i independonce from operating pressures. Additionally, the C&RP Supervisor has ,'

direct access to the Plant Manager on any matters, including radiation

protection problems or support, and to the Corporate staff, particularly in i 4

the radiation protection area, at all times. The support and interaction i between the C&RP Supervisor, the Plant Superintendent, the Plant Manager, and the Corporate groups is strongly evidenced by the extensive programmatic, conceptual, and financial support given to the radiation protection program. l Examples of such support and interaction are the procurement of equipinent such g as a whnle body counter and separate multichannel analyzer for radiochemistry i and radiation protection functions; prompt evaluation of the refueling transfer i

tube path and the installation of shielding; analysis and shielding of a j potential exposure source from in core detectors; thorough analyses of tential E j post-accident conditions and im'lementation p of ALARA-oriented modificat ons, E suc as at the primary system sampling facility. The C&RC Supervisor is also l i .

a r.cmber of the Plant Staff Review Committee, providing a high level of inter-action and review for the radiation protection function. In addition to the j functional interaction and access to upper management and corporate support j which exists for the C8RP Supervisor, PGSE has committed to formalize this 5 policy in the FSAR.

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The Diabic Canyon C&RP organization has sufficient depth to provide backup 1 to the CARP Supervisor. The incumbent C&RP Supervisor meets the requirements of Regulatory Guide 1.8, vnd his designated backup the Senior Chemistry J Tnd Radiation Protection Engineer, also meets the requirements. PG&E has comitted that any replacements for the designated CARP Supervisor backup also will meet Regulatory Guide 1.8, assuring that both chemistry and radiation protection funrJ; ions will have adequate technical and management  !

expertise to cope with all conditions. *

!l While the radiation proteption' functions and chemistry functions are -

consolidated in the same crganization, personnel assigned to perform and mar. age these functions have the necessary training and experiente to satis- j factorily perform both furctions and ' provide the essential support and  ;

quality control functions. Additionally, retraining qualification, and retraining programs which will provide standarization and improvement of CRPT skill levels and cr. hance both the quality control and support l functions, are being developed.

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s sufficient radiation protcetion technicians have bcen hired. trained. and j '

qualified to provide an Ah5I 18.1 qualified C&RP Technician on cach shift, g and sufficient numbers of qualified C&RP Technicians will be available to ,

pro.ide support during normal operations, outages, and TMI-type accidents, 'f

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s, The facility planning and scheduling groups have adequate means to allot radiation protection support as necessary.

Special Problems

')1, Fortions of this SSER are subject to receipt of written commitments (FSAR) from PG&E as follows: e q

j (1) The designated backup to the C&RP Supervisor will meet Regulatory '

Guide 1.8. 7 t

(R) The :ature of the-direct access / support between the Plant Manager. g Corporate groups anc the C&RP Supervisor will be stated.

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_P20XCIED END DATE i I

Completc with above commitments submitted-expected 2/28/81.

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By letters dated 2/29/80. 3/17/80, 3/31/80. 4/9/80, and 4/11/80, PG&E has submitted commitments and documentation of actions to be taken at Diablo Canyon by PG&E to implement short term lesson learned items in NUREG-0578/

0737.

iv . STATUS REPORT _

Discussion and Status .

We expect to receive a final version of their shieldits review is 2/81. The shielding analysis and equipment evaluation have been completed and are pending corpora.te approval. Shielding modifications for vital area access were observed to already be under way at Diablo Canyon.

Special Problems Submittal of the shielding review document should be accomplished at least four months before full power to meet our NUREG-0737 position,

v. FROJECTED END DATE February,1981. -  ;

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By letters dated 2/29/80, 3/17/80, 3/31/80, 4/9/80. 4/11/80, and 9/22/80.

PG&E has subnitted commitments and' documentation of actions to be taken at Diablo Canyon by PG&E to implement short term lesson learned items in j NUREGS-0578/0737. - 1 iv. STATUS REPORT Discussion and Status Diablo Canyon will have two high ranghcontainment radiation monitors insta11ed' PG&E has committed to have them installed in accordance with the imp}ementation l dates of NUREG-0737. The instruments will measure the range 1 to 10 R/hr.  !

with the capability to measure 60 Key photons. Separate power supplies from i separate vital buses will be provided, along with control room readout and recording capability on the Post Accident Monitoring Panel. Location in-containment is such that there are no in-containment shielding interferences or potential "hotspots" to interfere with representative readings. The seismic and environmental qualifications will comply with Regulatory Guides 1.89 and 1.100. Automatic functional checks will be performed every 2S minutes by the system. The comitments for Diablo Canyon meet our positions in NUREGS-0578/

C564/0690/0737 and are acceptable for Fuel Loading. A review of the equipment installation and operation will be performed during a routine inspection. -

Special Problems The monitor descriptions is acceptable for full power subject to receipt of a written comitments regaroing calf oration using sources and calibration frecuency.

. v. PROJECTED END DATE february,1981.

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%  % g HP TECHNICIAN QUALIFICATIONS Cz3M M J Criteria .

The criteria for selection of HP technicians is specified in ANSI N18.1-197!,

which is referenced by Regulatory Guide 1.8, Rev. 1-R. Section 4.5.2 of th.-

ANSI states: .

Technic'ians in r'esponsible positions shall have a minimum of two years of working experience in their specialty.

These personnel should have a minimum of one year of related technical training in addition to their experience.

joy tlie Jpurposetof ' inspection, a t.echnician .in a resporysible position .

-14pid be an individual who

1. Reviews surveys performed by others ,

2. Signs radiation work permits (RWPs) '

3. Issues RWPs Independent 1y performs surveys or evaluations

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used to permit compliance with regulatory

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One year of experience is 2000 or more working hours accumulated during

. a total period of not less than 40 weeks of assignments at nuclear -

power plants.

Inspection Item

' 1 For those facilities vliose technical specifications require that HP te'chnici. ins meet..or exceed the minimurri qualifications of ANSI N.18.1-1971, examine records of training and experience for HP techn'icians added to the organization within the

'last yea r.- Discuss the content of the records of training and experience with the HP technicians to determine if the records are correct and accurately reflect the actual scope and content of training and the scope of experience.

. For those facilities whose technical specifications do not require the HP technicians sicet or exceed the minimum qualifications of ANSI N18.1-1971 perform the above for all HP technicians. .

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HECENED

. , . t (& Hi1C An Electrician or Instrument Repairman other than one at Diablo Canyon Power Apprentice ControlPlant who is Technician the successful classification at Diablo bidder Canyon on Mdd a vacancy i gg $ alt will be placed at the wage rate step applicable at the end of 24-sonths, and such employee vill not have subsequent bids on Control Technician i vacancies considered under Subsection 205.7(b) until he has acciuaEGIONVg'e 1 24-months' classification seniority as an Apprentice Control Technician. l In addition, he vill not be considered.for automatic progression to 1 i Unassigned Control Technician under the provisions of the Master i

Apprenticeship Agreement until he has accrued 30-months' classification

seniority as au Apprentice Control Technician.

An Electrician or Instrument Repairman headquartered at Diablo Canyon Power Plant who is the successful bidder on a vacancy in the Apprentice Control Technician classification, will retain his current rate i of pay and be placed at the 24-month step, and will not have subsequent bids on Control Technician vacancies considered under Subsection 205.7(b) until be has accrued 24-month's classification seniority as an Apprentice Control Technician. In addition, he vill not be considered for automatic progression to Unassigned Control Technician under the provisions of the Master Apprenticeship Agreement until he has accrued 30-months seniority as an Apprentice Control Technician.

To enter the Apprentice Control Technician classification, an

( employee vill be required to pass a written examination based upon the j first two years of apprenticeship in either the Apprentice Electrician or

Apprentice Instrument Repairman classification depending upon the line of

, progression that the candidate is in. If he is in neither of these lines of progressien, he may have the choice of the two examinations, but will be given only one.

I 2357 CHEMICAL AND RADIATION PROTECTION TECHNICIAN (2358 Trv. Chemical and Radiation Protection Technician) .

A shift employee who, without direct supervision, performs contamination and radiation level surveys, including routine isotopic i

analysis to assist in assuring that the limits contained in the company's radiation control standards are not exceeded, and maintains survey and other appropriate records in support of the plant and environmental monitoring programs; instructs employees and others in proper radiation protection procedures; performs and advises other employees in the decontamination of spaces and equipment and the handling,, packaging, storing, and shipping of  ;

solid radioactive vastes and other radioactive material; assures that portable radiation detection and personnel radiation protection equipment are in satisfactory, operable condition; makes routine calibration checks of portable and counting room radiation detection equipment. In addition,

. he may be required to collect and analyze radioactive and nonradioactive samples in accordance with standard procedures and make recommendations to the appropriate supervisor based on the results of such analyses; maintain the appropriate records of analyses performed; advise other employees in operating i

chemical process equipment and vaste disposal facilities. He may be required to assist plant engineers in writing procedures for calibrations, maintenance, i

testing, and other activities in his area of responsibility.

i Exhibit VI-B l Page 55 Revised January 20, 1983 h f) f %.)

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l His background of education, training, and experience must be

! #sueb as to qualify him to perform these duties with okill and efficiency  ;

and meet the current NRC qualification require =ents for," Health Physics Technician" to which Company is committed. May be required to make independent determinations of appropriate postings of raidiological conditions once the employee meets the NRC requirements. To qualify for entrance into this classification, so employee must pass a written examination._

Next Lover Classification Same or Higher Classifications 1503 Environmental Protection 1505 Radiation & Process Monitor (H3PP)

Monitor (GPP) 1506 Trv. Radiation & Process Monitor (H3PP) 2357 Chemical & Radiation Protection Technician 2358 Trv. Chemical & Radiation Protection Techaician (DCPP) 2095 INSTRUMENT REPAIRMAN (2099 Traveling Instrument Repe.irman) (DCPP)

An employee who is a journeyman and is engaged in installing, maintaining, and calibrating all types of automatic control and recording equipment, instruments, gauges, and their component. parts. His duties require the use of machine tools, hand and bench tools, and various types of test equip =ent. In addition, he may be required to assist in taking readings during plant tests, tabulating and charting tes: and performance data. His background of apprenticeship and experience must be such as to

. qualify him to perform these duties with skill and efficiency.

Next Lower Classification Sane or Higher Classifications 2091 Appr. Instru. Repair =an 2090(2093) Instru. Rapairman & (Un.)

2095(2096) Instru. Repairman & (Un.)(DCPP) 2097(2094) Trv. Instru. Repairman & (Un.)

2099(2092) Trv. Instru. Repairman & (Un.)(DCPP) 2380(2381) Control Technician & (Un.)(DCPP) 2382(2399) Trv. Control Tech. & (Un.)(DCPP) 2385 Shift Control Tech. (DCPP) 2396(2394) Trv. Control Tech. & (Un.)

2397(2383) Control Technician & (Un.)

2398 Appr. Control Tech. (Top Rate) 2398 Appr. Control Tech. (DCPP)

(Top Rate)

Exhibit VI-B Page 56 Revised January 20, 1983

macr - an ALLEGATIEN DATA F3RM u.s. NuctEAR nEcutAToRY COMMISS'ON IIIEl Instruction. on tevers. s+oe RECEIVING OFFICE Docket Number (if applicable)

1. Fs cility(les) Involved: (Namel

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gerenc wen. GENEfuC) n, .a w 1 or o o a , c Do,dIa t% ly c> ., Q oro o o1 .t ]

2. Functional Areals) Involved:

Iche:k soproon.te boxtest i _ operations onsite health and safety

_ construction _ offsite health and safety

_ safeguards emergency preparedness

_ other tspecity 3.

Description:

lHlf I lP lEI411 lo lNINIC lLI l/YIol Ti l 5II414l/. I l[lol l IMnbill 121/l A!I Aalt Inlalal lelaloIt-InlMal lel IPln Ir>lEl/71 ITi / l /- EJ rt A clsinirlM /lul l#lM ol I I INlo INI> I ri olntt l lM o Tl lJIEl/Ylfl/171/ IVlfl l l l

4. Source "of Allegation: - ~

(Check .ppe,oprete box) _ contractor employee _ security guard

_ licensee employee news media

. _ NRC employee private citizen

_ , organization tspecity) other tspecify) $ ~ l t_ t ht) Lt. & m r0 l07 e 2.

MM DD YY

5. Da.te Allegation Received:

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6. Name of individual Receiving Allegation:

trirsi swa initi.i. .no i.. n.m.) .N 4 &# -

7. Office: "

ACTION OFFICE

8. Action Office Contaet: tri, two in;ii.i. .no i.. n.m.i M NNJ b

9. FTS Telephone Number: g g 7 7 7

10. Status: T' Open,if followup actions are pending or in progress icheck one) -

__ Closed, if followup actions are completed MM DD YY

11. Date Closed:

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,12. Remarks.

stirmt to 50 ch r.cters) I6 IE lEl l / lA)IS l/ lElc l 71/ lo I4)l lA' lEl/ Iole l T} l l l l/ h 15 l01-1217l rl/Isl31-1511l lPlelelAlslalelelM 191 1 12.1 Man-hours /Date o,,;,, y,,, ,.,,,,, p p

13. Allegation Number: 4 '

SPhtC e / > 'o,, UNITED STt.TE!'

NUCLEAR REGULATORY COMMISCICt.

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DHE0 {B]gggo: 45 MEMORANDUM FOR: William Fisher, Chief, Section B, Engineering and Technical Support BranEfh0i b g -

FROM: F. A. Wenslawski, Chief Radiological Safety Branch, Region V

SUBJECT:

REQUEST FOR GUIDANCE ON REQUIRED EXPERIENCE FOR CHEMISTRY AND RADIATION PROTECTION TECHNICIANS A number of facilities have a Technical Specification 6.3.1 which states in part "Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions...." ANSI N18.1-1971 Section 4.5.2 states " Technicians in responsible positions shall have a minimum of two years of working experience in their specialty." Some facilities, such as Diablo Canyon, have a unit staff position of Chemistry and Radiation Protection Technician. Chemistry and Radiation Protection are usually considered to be separate specialties, as is the case in section 4.4 of ANSI N18.1-1971 or section 3.2.4 of the revisions to this standard (ANS-3.1-1978 and 1981). Doug Collins in 1981 suggested that if a facility has a combine position then four years of experience, two in each specialty, would be required to meet the standard (see enclosure 1). It is our understanding, however, tL'at NRR has not established a firm position on this issue. We believe this issue has generic implications and want to be sure that we are not backfitting a new interpretation of the existing requirement.

We therefore specifically request guidance on:

A. Can we enforce a position that for technicians in responsible positions two years experience in each specialty, Chemistry and Radiation Protection, are required to meet the Technical Specification? )

B. For Radiation Protection technicians in responsible positions does preoperational experience count on a one for one basis to fulfill the ANSI N18.1-1971 experience requirement?  !

/s F. A. Wenslawski, Chief Radiological Safety Branch, RV

Enclosure:

As stated cc: M. Shanbaky, RI D. Collins, RII R. Greger, RIII B. Murray, RIV F. Congel, NRR l l

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I'.EMORANDI.ti FOR: Radiation Protection Section E .i;;; ,,.. ,

FROM: s Doug Collins, Leader RPS

SUBJECT:

RADIATION PROTECTION ORGANIZATION, STAFFING AND QUALIFICATION ,

RPS has made several reviews of Ols using NUREG-0731 as criteria and this memo is to provide you information on our experience with NUREG-0731 imple-mentation.

HUREG-0731 was issued as a draft in September 1980 for' interim use in evaluating near-term Ols per NUREG-0694. The salient radiation protection aspects of this NUREG and their application are listed below.

RPH

1. Radiation Protection Manager (RRPG Reporting

a. Criteria Section II. A.1 of NUREG-0731 states that "The functional areas of radiation protection, quality assurance, and training should assure independence from operating pressures" and that there be

" clear lines of authority to the Plant Manager." Figure 1 of NUREG-0731 shows a " representative" plant organization with the RPM reporting directly to the Plant Mgr/ Asst. Plant Mgr and at the same level as the Operations Manager. In addition, Regulatory Guide 8.8, Section C.1.b.(3), states:

The Radiation Protection Manager (RPM) (onsite) has a safety function and responsibility to both empicyees and management that can be best fulfilled if the individual is independent of station divi-sions, such as operations, maintenance, or technical support, whose prime responsi-bility is continuity or improvement of station operability. The RPM should have direct reccurse to responsible management personnel in order to resolve questions related to the conduct of the radiation protection program.

This section will be revised short.ly to st' ate that the Regulatory Guide 1.8 qualified RPM should have direct access to the Plant Manager in all radiation protection matters.

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Revision 3 of Regulatory Guide 1.33 (for Comment dated November 1980) states, with regard to " independence fran operating pressures" and QA groups, that the NRC is evaluating the effectiveness of an organizational

, structure in which the onsite QA group reports functionally to offsite QA management rather than to the Plant Manager. This is not the same meaning of

" independence from operating pressures" as applied to the .

RPM. Acceptable implementation for the RPM is discussea bel ow,

b. Implementation v

- The two main goals with regard to the organizational structure are to give assurance that the radiation

, protection (RP) group is independent from operations and operational pressures and that the RPM has direct access to the Plant Manager in all RP matters. It is clearly unsatisfactory for the RPM to report to the Opera-tions or Maintenance Superintendent since this makes him directly dependent on operational pressures. Although NUREG-0731 and Regulatory Guide 8.8 imply that the RPM should regort directly to the Plant Manager, the Figure 1 is for a representative" org'anization and Regulatory Guide 8.8 states that the RPM's responsibilities can be best fulfilled if he is independent of Technical Support HiFision. This does not say that reporting to the Technical ,

j Support Manager is unacceptable; only that it is not the ,

j best organization. We have found acceptable a system in j which the RPM reports to the Technical Services Manager l with a commitment in the FSAR that the RPM has direct access to the Plant Manager for RP matters or that the RPM is a member of PORC. Each review should detennine i_f the proposed 4

organizational structure does and will wort (including access of the RPM to the Plant Manager) and if the functional orga nization that works is depicted by the FSAR and tech specs.

In instances where the organizational structure is questionable,

. you should contact the Resident Inspector or assigned regional HP Inspector to get input. In addition, if necessary, you should visit the site as part of your evaluation in order to interview the RPM. l

2. Radiation Protection Separate from Chemistry l l

a. Criteria '

Section II.A.1 of NUREG-0731 states that one characteristic that fonns the basis for a plant organization is that " distinct functional areas are separately supervised and/or managed."

Figure 1 of NUREG-0731 shows RP separate from Chemistry.

APR 0 / 1""

Additionally, Standard Technical Specifications specify that  ;

radiation protection technicians meet ANSI 18.1 which requires f

in paragraph 4.5.2 that techniciant in responsible oositions J shall have a minimum of two years of wortina experience in their speciality. Radiochemistry and Radiation Frotection are listed as separate specialities in V( i Section 4.4 'of that ANSI standard.

i NUREG-0654, in Table B-1 lists ,eparately HP technicians .

and radiochemistry technicians.

b. Implementation The bases for the separation of RP from Chemistry are (1) assurance that the RPM devotes sufficient attention '

to RP (and is not distracted from his responsibility to RP by Chemistry), and (2) assurance that technicians are not i

required to perform so many functions that they cannot main-tain specialized competence in dedicated functions. There are  :

acceptable methods for achieving these goals other than total separation of RP from chemistry. We found acceptable organiza- 1

tions in which a Supervisor of Radiation Protection and l

. Chemistry has two discrete functions (RP and Chem) reporting j to him. In order to overcome the potential problem of dilu- l tion of Chem and RP Supervisor' management of and technical input into the RP program, a Rd.latory Guide 1.8 qualified individual is put in charge of the RP group. Thus, the RP function has the benefit of the full-time direction of a

! Regulatory Guide 1.8 qualified individual. In these cases, the Chem and RP techs have been separate groups with

• separate duties and qualification standards. HP Appraisals have found plants where the combination of RP and Chemistry duties have resulted in pr@lems because of the inability of technicians to maintain competence in all areas; they have also found programs where the combination technician has worked. In plants where the groups are separate, a few very good technicians have been able to maintain qualification in both areas. It. therefore.is theoretically possible to

. ,gualify a staff ~of techs in both specialities, but it would_.- '

k require 9 yt:ars experience total per ANSI 18.1 and would require a great expenditure of ef fort in training and qualifying the v i staff in both areas. One plant has a contractor evaluating the organization for potential solutions to the dual-technician qualification problem.

3. Shift Staffing

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a. Criteria NUREG-0654, Table B-1, specifies that there be an HP technician on i

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each shift as a minimum. This on shift person must be a tech-

, nician qualified per ANSI 18.1, not "an individual qualified in RPinprocedures" tors the past. as specified in Tech Specs of operating reac-A footnote to the table shows that two such

" individuals qualified in RP procedures" are required in addition to the technician.

Section II. A.d.(2) of NUREG-0731 states that a RP technician should be onsite at all times. .

, b. _ Implementation Beyond this minimum, there must be sufficient staff to per-

, form the assigned RP functions. Those functions assigned RP  !

vary from plant to plant. Many functions, such as TLD i processing, bicassay, instrument calibration, environmental

, monitoring, etc. can be contracted out and therefore the in-house staff to perfonn RP functions is. Variable. HP Appraisals have found that some of the better programs at one-unit staff.

stations have only 10-11 people on the entire RP Other plants with substantially more personnel have had more significant findings.

4. Back-up to RPM

a. Criteria

~

Section II.A.2 of NUREG-0731 states that there should be in-depth experience at the Radiation Protection Manager level.

Section 4.4.4 of the December 1980 draft ANSI 3.1, which will be adopted by Regulatory Guide 1.8 specifies that an individual who temporarily replaces the RPM should have a B.S. degree in science or engineering and 2 years experience, six months of which should be onsite.

b. Implementation It is our intent that the backup to the RPM be assigned to the site, but in certain circumstances he may be assigned at corporate with close ties to the site. For example, the corporation ,

HP of a one unit utility located near (app. 30 miles) to .

the site might be acceptable as a back-up to the RPM if, during the RPM's absence he is assigned to the site. -

5. RPM Qualifications t l

, a. Criteria Standard Technical Specifications specify that the RPM should be qualified in accordance with Regulatory Guide 1.8, which

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.e currently states:

The Radiation Protection Manager (RPM) should be

! an experienced professional in applied radiation protection at nuclear facilities dealing with

- radiation protection problems and programs similar to those at nuclear power stations. .

The RPM should be familiar with the I design features and operations of nuclear l power stations that affect the potential for exposures of persons to radiation. The RPM should have the technical competence to establish radiation protection programs and the supenrisory capability to direct the wort of professionals, technicians, and journeymen required to implement the i radiation protection programs. ,

4 The RPM should have a bachelor's degree or the equivalent in a science or engineering subject, including some fonnal training in radiation protection. The RPM should have at least five years of professional experience in applied radiation protection. (A master's degree may be considered equi-valent to one year of professional 1

> experience, and a doctor's degree my

- be considered equivalent to two years of professional experience where course work related to radiation protection is in-volved.) At least three years of this professional experience should be in applied radiation protection work in j

' a nuclear facility dealing with radio-logical problems similar to those encountered in nuclear power stations, preferably in an actual power station.

Equivalent, as used above for the B.S. degree, may be met by (a) 4 years of formal schooling in science or engineering, (b) 4 years of applied radiation protection experience at a nuclear facility, (c) 4 years of operational or technical i experience / training in nuclear power, or (d) any combination of the above totaling 4 years. With regard to other clari-l.

fications of the R.G.1.8 wording, see the attached EEB

'

• Branch Position dated March 2,1978. Note that with regard to the number of refueling outages in the EEB position, the i

APR 0.* 1. 091 NRC is adopting a new ANSI 3.1 which will require 6 months onsite and one refueling outage.

b. Implementation There should be a Regulatory Guide 1.8 qualified RPM assigned at the site. In some instances the individual assigned PfM has strong management capability but does not have the radiation protection technical experience of Regulatory Guide 1.8. How .

ever,we have found it acceptable for this individual to function as RPM when he is supported by an individual in the line organi-zation (e.g. HP Supervisor) who has the Regulatory Guide 1.8 education and technical experience. We have not found it accep-table to have a Regulatory Guide 1.8 person not in line (e.g.

as a staff member of a rad engineering group).

6. Radiation Protection Technicians

a. Criteria ,

ANSI 18.1, Section 4.1, states that individuals must have the training and experience to do the job. Section 4.5.2 states ,

that technicians in responsible positions shall have a minimum of two years experience in their specialty and should have one year of related technical training. In practice, the shall 2 years I applies, with training as part of the 2 years.

ANSI 18.1, Section 5.1 and 5.3, specify training in general tems. Section 5.5.1 specifies retraining in more specific tems.

Proposed Regulatory Guide 1.8 (RP 807-5, Sept.1980) on page 18 specifies a perfomance oriented training and qualification for technicians.

b. Implementaton A " responsible" radiation protection technician is one who:

1. Reviews surveys perfomed by others;

2. Signs RWPs;

3. Issues RWPs;

4. Independently performs surveys or evaluations used to pemit compliance with regulatory requirements.

APP. nt 1?y 1

i We wave accepted an alternative to two yeasts experience (thed quality of which is not specified by ANSI). This al+~ rrnative would consist of an NRC reviewed and approved ,

trg.r.-ning program with a 1 year experience requirement (the  !

quar.i-ity of which would be specified). Some licensees have I

comnded that the retraining listed in Section 5.5.1 of ANE 18.1 does not apply to radiation protection tecnnicians.

This . retraining does apply. ,

1 h"Pjbd k' Douglas M. Collins, Leader Radiation Protection Section Radiological Assessment. Branch Division of Systems Integration cc: W. Kreger D. Collins l

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. JUL 2 91930 MEM3PANDUM FOR: James H. Sniezek, Director, Division of Fuel Facilities and Materials Safety Inspection .

FROM: George H. Smith, Chief, FF&MS Branch, RI- .

SUBJECT:

REOUIREMENTS'FOR TRAINING, QUALIFICATION, AND RE-TRAINING OF POWER REACTOR HEALTH PHYSICS TECHNICIANS This refers to the memo to you, dated July 10, from J. Philip Stohr on the same

~

subject.

We agree with Region II that there is a clear need to take action in this area.

1 Our wording in a recent Order modifying the Oyster Creek license, copy attached.

i relates to this question.

We succest the following material, which builds on the ideas set forth in the

~

Regioi1 II mema,.be incorporated into the Radiation Protection Plan or a Regula-tory Guide which could contain or refer to the suggested Power Reactor Health Physics Training Manual. ,

SUKGRY

't The radiation protection organization training and qualification program must be -

approved by HRC and must consist of the following elements- l

1. A set of position descriptions which serve as the focal point and link through which defined authorities and responsibilities are tied to defined training and qualifications.

2. A documented program of classroom training and re-training to be done in accord with a prescribed set of topics. A spe'cified amount of time must be set aside and a documented. testing procedure must be used to verify that the trainee has grasped the key points and enough of the related material to be able to perform satisfactorily. Successful completion of this training and re-training and associated examinations must be accomplished in order to become and remain qualified for the position held.

3. A documented program for supervisor examination and verification that the individual understands and can successfully carry out each pro-

cedure associated with the position for which he is a candidate.

CONTACT: P. J. Knapp ,

) FTS 4S8-1291 N O D 00l9 i N m 1(@ i l

Janes H..Sniezek 2.

, JUL 29 MO o 4. A documented method through which the Radiation Protection Manager makes a formal determination that an individual has all of the necessary qualifications and training ^and is appointed to a position.

These areas are expanded on in the following paragraphs.

POSITION DESCRIPTIONS .

Positions in the radiation protection organization, including technician positions, should be designated. For each position there should be; a) a statement of the responsibilities and authorities of the position and b) a statement of the training and other qualifications which an individual must have in order to be appointed to the position.

Item five in the Stohr Memo speaks to such a position. This item could be expanded to read; The phrase " responsible position" in ANSI-NI8.1 should be defined in general terms as a position carrying such responsibilities and authorities that the actions of an individual holding it can have a direct affect on the radiological health and safety of plant personnel and the general public or on compliance with technical specifications which control the release of radioactive material to the environment. A list of specific examples of authorities and responsibilities should be published. This list should include:

1) Approving Radiation Work Permits.

2) Approving Effluent Release Permits.

3) Conducting radiation surveys upon which worker protection is based.

4) Providing personal radiation protection coverage to workers conducting jobs involving substantial radiation hazards.

QUALIFICATIONS FOR ENTRY .

There should be some minimum qualifications for entry to each position. For example a high school diploma with successful completion of Algebra 1 Algebra

2. Trigonometry and one year of science courses or equivalent practical experience should be required for entry to a Junior Technican position. All of the above plus one year of experience in the health physics department at a nuclear power plant or a plant with radiation protection problems of the same type and magnitude should be required for entry to a technician position.

James H. Sniezek 3

, JUL 2 915H

• TPJsINING AND RE-TRAINING The list of topics $n the enclosure to the Stohr Memo is excelle7t. I would suggest the addition of the following topics:

Radiation Work Permit l'uclear Power Plant System Fundamentals l

The topics; PWR/BWR Radiation Sources In-Plant and Power Reactor Rules of Thumb ,

>:hich are presently listed as appendices should be moved to the preceding list

of Training Manual Topics.

Each topic should be represented by a precis or course outline which presents sufficient detail to permit an independent determination that the subject is adequately covered. The key concepts (those without which the trainee cannot perform adequate work) under each topic must be identified.

Examinations must be developed and maintained on file which verify the trainee's crasp of each topic. In addition to obtaining a passing grade on an examination, the trainee must successfully answer questions on the examination which demon-strates that he has grasped every key concept.

The licensee's program must specify the topics which will be taught and tested for both initial cualification and re-training. As suggested in paragraph 4 of

. the Stohr Memo, the licensee's program should specify the number of hours which will be allotted to; 1) initial qualification training ano 2) requalification training.

Successful completion of the training and re-training and associated examinations are necessary prerequisites for gaining and holding the position in question.

DEM0"STPATION OF UNDERSTANDING OF AND ABILITY TO PERFORM PROCEDURES I

The ability to perform the actual procedures which make up the bulk of the health physics duties, particularly at the technician level, is a major qualification for gaining and holding an appointment to a described position.

The individual's foreman should be required to observe him to perform each pro-cedure successfully and should verify that the individual understands the reasons v;hy the procedure exists and how the procedure accomplishes its purpose.

The foreman should then certify his findings by signature entries in the individ-tal's record. In addition, a formal method for assuring that each individual fully understands and can implement each procedure change must be utilized.

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The program should identify procedures for whic.h re-certification is necessary as part of the annual re-training. ..

FORMAL DETERMINATION OF ELIGIBILITY AND APPOINTMENT The Radiation Protection Manager must verify from the individual's record that; a) he has the necessary qualifications for entry, b) he has successfully completed the classroom training and has passed the required examinations and c) he has successfully demonstrated to the responsible foremen that he understands and can successfully implement every procedure for which he will be responsible. The Radiation Protection Manager should take whatever additional steps he feels are necessary to assure himself that the individual is qualified. Finally, the Radiation Protection Manager should certify in writing that the individual is eligible for the designated position and has been appoin 'ed it.

( / -

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Geo ge . .,mith, Chief Fue' F ilities and Materials Sa ety Branch

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Enclosure:

As stated

. cc:

FF&MS Branch Chiefs RII RIII RIY RV T. Murphy

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UNITED STATES OF AMERICA l NUCLEAR REGULATORY COMISSION j In the Matter of '

Docket No. 50-219 Jersey Central Power and Light Company (Oyster Creek Nuclear Generating )) -

l Station, Unit No.1) l i

ORDER MODIFYING LICENSE  !

EFFECTIVE IMMEDIATELY 3

1 I

The Jersey Central Pcwer and Light Compan Operating License DPR-16 (the " license") whichy authorizes (the " licensee") is the operation of the holder of Oyster Creek Nuclear Generating Station at steady state reactor core power  ;

levels not in excess of 1930 megawatts thermal (rated power). The license was -

issued on April 9,1969. The facility consists of a boiling water moderated and cooled reactor (SWR), located at the licensee's site in Ocean County, New Jersey, nine miles south of Toms River, New Jersey.

II During an inspection conducted March 18 and 19,1980 it was determined that one of the major factors contributing to an incident involving a breakdown in radia-

- tion protection controls was the use of an unqualified technician to provide radiation protection coverage during the servicing of a heavily contaminated reactor control rod blade handling tool. The incident involved exposure to 4

airborne radioactive material which resulted in intake by one of the workers of approximately 29 percent of the maximum allowable quantity of cobalt 60. A second instance of the use of unqualified personnel was identified during a j Health Physics Appraisal inspection conducted May 12-16, 1980. During this inspection, an uncualified contractor technician was observed to allow personnel i

to exit a work are'a, used for repair of heavily contaminated control rod drive mechanisms, without performing whole body frisking. This individual was deter-mined to be at times directly responsible for the health and safety of the workers rebuilding the control rod drive mechanisms.

• As a result of the first instance, a letter dated April 2,1980, was sent to the Director, Region 1, U.S.N.R.C. . In this letter, the licensee's Manager of i

Nuclear Generation addressed immediate corrective actions and, among other l

j things, stated, "0yster Creek will use Radiation Protection Technicians who caet or exceed ANSI N18.1-1971 in responsible positions. Unqualified t'echnicians acting in less responsible positions will be closely supervised. This Action will be implemented April 7,1980."

O I .

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2

'As a result of the second instance and as a result of the normal inspection review process, it was determined on May 16, 1980 that the licensee was utilizing contractor supplied radiation protection technicians in responsible positions who did not meet the requirements of ANSI N18.1-1971. The initial NRC review of resumes, observation of field perform ~ ince and questioning indicated 4 of 28 contractor technicians designated by the licensee as meeting ANSI N18.1-1971 requirements did not meet these requirements. Of the 4 and including the latter individual discussed above, 2 contractor technicians were determined i.o have no prior applied nuclear power plant experience. By May 19, 1980, it was determined through further licensee review that an additional 10 of the 28 contractor technicians did not meet the ANSI N18.1 requirements.

The findings of the appraisal suggest that the licensee has not adopted appro-

~ priate controls to assure the utilization of only qualified technicians in activities important to the protection of workers.

In view of the significance to safety in assuring the establishment and imple-mentation of appropriate management controls over safety-related activities and the prompt resolution of identified problems, I have determined that the public health, safety and interest require, effective imediately, modification of License No. DPR-16 as stated in Part III of this Order.

III Accordingly, pursuant to t'he Atomic Energy Act of 1954, as amended, and the Comission's regulations in 10 CFR Parts 2 and 50, license No. DPR-16 is modi-fied by the follcwing addii. ion to Technical Specification 6.3, Facility Staff Qualifications:

6.3.2 Each member of the radiation protection organization for which there is a comparable position described in ANSI N18.1-1971 shall meet or exceed the minimum qualifications specified therein or, in the case of technicians, shall have at least one year's continuous experience in applied radiation protection work in a nuclear. facility dealing with radiological problems similar to those encountered in nuclear power stations, preferably in an actual nuclear power station, and shall have been certified by the Supervisor, Radiation Protection, as qualified to perfonn specified work. This certificatior must be based on an NRC approved, documented program consisting of classroom training with appropriate examinations and documented positive findings by responsible supervision that the individual has demonstrated his ability to perform each specified procedure and function with an understanding of its basis and purpose. However, the Supervisor, Radiation Protection, shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975.

IV The licensee, or any other person who has an interest affected by this Order, may, within twenty-five days of the date of this Order, request a hearing. A request for a hearing shall be addressed to the Director, Office of Inspection and Enforcement, U.S.N.R.C. , k'ashington, D.C. 20555. If a hearing is requested by the licensee or an interested person, the Commission will issue an Order designating the time and place of hearing. Such a request for hearing SHAl.L NOT STAY THE UNEDIATE EFFECTIVENESS OF THIS ORDER.

3 -

V b

In the event the licensee or any other interested person requests a hearing as provided above and a hearing is held, the issues to be considered at such a hearing shall be:

(1) whether the facts set forth in Part II of this Order are correct; and, (2) whether'thisOrdershouldbesUs'tained.

FOR THE NUCLEAR REGULATORY COMMISSION Victor Stello, Jr.

Director -

Office of Inspection and Enforcement Dated at Bethesda, Maryland this day of , 1980 ~

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