ML20207P447
| ML20207P447 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 01/07/1987 |
| From: | Lovett D, Murphy M, Stewart D TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20207P399 | List: |
| References | |
| 311.01-SQN, 311.01-SQN-R05, 311.01-SQN-R5, NUDOCS 8701160143 | |
| Download: ML20207P447 (12) | |
Text
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 311.01-SQN SPECIAL PROGRAM REVISION NUMBER: 5 REPORT TYPE: Sequoyah Nuclear Plant Element TITLE: Health Physics Staff Training REASON FOR REVISION:
Revision 1-To incorporate SRP conunents Revision 2 To incorporate TAS conunents Revision 3 To incorporate Sequoyah Corrective Action Plan (CAID 31101-SQN-01)
Revision 4 To incorporate SRP conunents Revision 5 To incorporate SRP conunents PREPARATION PREPARED BY:
/// [I Dave Lovett
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Subcategory: Health Physics Element: Health Physics Staff Trainin, Report Number: 311.01 SQN Revision 5 XX-85-024-001 XX-85-102-009 XX-85-102-012 i
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HEALTH PHYSICS STAFF TRAINING This report evaluates three concerns identified to Quality Technology Company (QTC) regarding Health Physics (HP)-technician training and awareness of protective clothing requirements.
II.
SPECIFIC EVALUATION METHODOLOGY Three concerns were included in this Element Evaluation Report Concern XX-85-024-001 Health Physics personnel are not aware of protective. equipment Sequoyah:
Example: HP at entrance to radiation required for work area.
area informed craft that particulate masks were not required.
While working, HP told craft-to stop work and leave area because they did not have particulate masks. This happened in 1983 and 1984. Nuclear Power Concern units 1 and 2.
Concern XX-85-102-009 The perrenent plant Health Physics people are poorly Browns Ferry:
trained. CI does not feel the present HP staff has an adequate knowledge of working in radiated areas.
Concern XX-85-102-012 The permanent plant Health Physics people are poorly trained.
Sequoyah:
CI does not feel the present HP staff has an adequate knowledge of working in radiated areas.
The concern XX-85-102-009 is a specific concern for Browns Ferry (BFN)
Concern but has generic' applicability to Sequoyah Nuclear Plant (SQN).
XX-85-102-012 is a specific concern written to SQN. Concerns XX-85-102-009 and'XX-85-102-012 are the exact same concern affecting SQN.
was investigated by Nuclear Safety Review Staff (NSRS)
XX-85-102-012 under report I-85-734-SQN.
(Reference 11) Therefore, this evaluation of the concerns, XX-85-102-009 and XX-85-102-012, focused on determining the adequacy of the NSRS report.
Concern XX-85-024-001 is a specific concern evaluated for the SQN site.
I The concern as written references a specific incident where the concerned Individual questioned HP awareness of protective equipment requirements.
However, due to the timeframe involved and lack of specifics regarding the incident, the concern was evaluated from a general programmatic l
standpoint within the following areas:
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Training of Health Physics Technicians in establishing protective 1.
clothing requirements J
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Health Physics Technician stop work authority
- 3.- Health Physics Technician error 4.
Rstab11shing and Revising RWP requirements
'A review of regulatory requirements.. procedural requirements, and past
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~ Items reviewed are listed in the report and in the audits was done.
reference section of this report.
Interviews with cognizant personnel were also conducted to address the above listed areas. In addition, slallar concerns having already been investigated were reviewed for applicability to this concern.
III. FINDINGS Concerns XX-85-102-009 and XX-85-102-012 were evaluated by validating the-results of NSRS Report I-85-734-SQN.
This was done by reviewing in detail references 9 and 13 and other support documentation of the report, and interviewing a cognizant Health Physics Training individual at the Power Operations Training Center (POTC).
The results of the evaluation by area are as follows:
1.
Training of Health Physics Technicians A review of Nuclear Regulatory Commission (NRC). Institute of l
Nuclear Power Operations (INPO) accreditation, and Quality Auditing Branch (QAB) audits for the HP training section was done with no i-pertinent concerns, violations, or deviations found.
An interview with an individual in HP Training was conducted to determine if the identified areas for improvement of NSRS Report I-85-734-SQN were implemented. These items are as follows:
(1) airborne radionuclide origin and behavior; (2) maximum Permissible Concentrations (MPCs); (3) familiarity with 10 CFR 20; (4) appilcation of radiation limits to real life situations; and (5) operational theory of instrumentation. According to the interview, items 1, 3, and 5 of the NSRS report were either revised in training documents HPT-LP14 Revision 0. HPT 002.013 Revision 2, and HPT 002L.002, Revision 2, respectively, or were being further stressed in classroom lectures.
Item 2 is emphasized in HPT-LP16.
Item 4 is emphasized in all four of these training formats.
J Based upon the review of 1985 HP technician feedback, questionnaires, l
and interview with the above individual, the HP staff has an ongoing These program to identify deficiencies in the training program.
When a questionnaires are reviewed by HP Training to find trends.
trend tcward a deficiency is identified, then a review of the particular training format is performed and lesson plans revised as necessary.
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Rsvisica 5 ided As' outlined in SQN ASIL-3, the HP Technician Training is_div The classroom phase into classroom phase and in-plant phase. introduces the tech to Regulatory Guides, 10 CFR 20, and other disciplines as necessary h in-plant provide'the technician with the background to complete t e
~ phase.
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The in-plant phase of the Technician Training Program is des gne i
f HP to ensure that the trainee is competent in the applicat ons oDuring in real life circumstances.
technician is observed and evaluated by' ANSI-qualified Ireference 17) Senior HP technicians and the HP supervisor of This phase of the technicians' training d
in-plant training. includes oral examinations which must be successf for advancement to the senior technician level.
d A review of the 1985 SQN supervisor feedback questionnaire anin-p
. response revealed several deficiencies in theThese deficiencies identified were noted by the SQN supervisors.
nel were west.
It areas where a majority of newly assigned person i lly further identified the in-plant phase of training as potent aThe ii deficient in those areas.not address the in-plant phase or the impact to requirements based on the deficiencies noted.
t phase According to the interview with HP Training, the in-plan d nt gives the technician the opportunity to develop in i
requirements as well as general HP practices.
i-An interview was conducted with eight randomly sele l HP technicians on shift and was composed of SE-4 and SE-5 leve.
technicians.
Two of the technicians were onsite as SE-4stim technicians.
during the 1983-1984 in question.
h icians The interview was directed towards determining if these tec n they are were aware of protective clothing requirements and howEvery technician l
established in a given real-life scenario. interviewed d d
professional opinion in determining clothing /respiratoryEach technic requirements in a given situation.
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guidelines established for protective equipment requ remen s HPSIL-3 RCI-14, Revision 5. Attachment 3, and SQN Each technician also stressed that these outlined in SQN tive Appendix 1, Revision 11. recommendations are designed to help
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irator l
clothing and equipment but that protective clot uch as type of work to be performed, radiation levels, t
In contamination levels, and air quality taken into accoun.
3 Work addition each trchnician draws upon previous i
ts.
repetitious, in determining protectivo equipment requ remen l
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Rsvisicn 5 As a result of the interviews, it was determined.that HP technicians are aware of protective clothing / equipment l
requirements, and of how they are established and documented It was also found that they demonstrated good judgment on RWPs.
and an ability to make decisions within the bounds of Federal and e
plant requirements.
Health Physics Technician Stop Work Authority 2.
The following documents allow HP personnel to issue a stop work order when, in the judgment of the HP representative, such an action is prudent to protect craft workers from unnecessary or SQN RCI-1 Section VII, dangerous exposure conditions:
RCI-4 Section VI-A, Revision 20; and HPSIL-3 Revision 29; SQN Section III-E, Revision 11.
which sets guidelines by which respirators should NUREG 0041, 2.1.4 be utilized, states " Personnel who are responsible for
..and maintaining respiratory protection programs establishing.
must exercise sound judgment by providing and using engineering controls, where feasible, and by avoiding unwarranted use of Section 2.1.1, states that "when such controls are respirators."
not feasible or cannot be applied, the use of respiratory protective devices may be appropriate."
The above supportive documents allow HP discretion in the assignment of particulate masks and other protective clothing as well as giving the HP personnel the authority, based upon their judgment and training background, to alter those requirements in a conservative direction and to stop work when, in the opinion of the HP, the health and safety of the craft workers will be compromloed.
3.
Health Physics Technician Error interviews were conducted with HP supervisory Three (3) personnel to determine what, if any, corrective action mechanism According to the interviews, exists in regard to technician error.
judgment made in establishing protective clothing requirements or enforcing work practices that are in a conservative manner are Other errors that might result in supported through HP management.
violation of radiological control instructions result in the generation of a Radiological Incident Report (RIR) being written A review of RIRs for the period against the technician involved.
of 1983 and 1984 failed to reveal any situation where a technician was disciplined for failing to follow good radiological practices.
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Revision 5 l
4.
Ratab11shing and revising Radiological Work Permit (RWP) j requirements Prior to craft entry into an RWP area, HP personnel are responsible.
for surveying the work area and establishing the protective clothing j
and equipment requirements. According to SQN RCI-14,Section IV 88, i
Revision 5, the' individual performing the survey (radiation, contamination, airborne) is responsible for ensuring that the RWP is updated with the appropriate information. Also, as stated in RCI-14 IV B.12, Revision 5. " changes in protective clothing requirements... may be necessary because of changing work conditions."
Specific responsibilities of the work supervisor, HP representative, and the individual employee are outlined in sections VI A, B, and R of RCI-14, Revision 5.
As stated in section VI E.1 and E.5. of RCI-14, it is the employee's responsibility to " read and adhere to all requirements of the RWP
. associated with the area entered and the work performed."
Since specific details of the concern were not available, it cannot be determined whether the HP technicians or the craft workers involved failed to adhere to the requirements of RCI-14, section 4
VI-A, VI-B, and VI-R.
Several RIRs investigated during this timeframe did provide' documentation of failure to follow RWP i
instructions by various crafts. None of the RIRs could, however, be tied directly to the concern.
The information provided by employee concern XX-85-024-001 was not specific enough to allow a direct investigation. However, several scenarios were evaluated to ascertain whether the concern was valid and whether deficiencies in regulatory or procedural noncompliance existed. These are as follows:
1.
Are HP personnel fully knowledgeable of protective clothing requirements? Interviews with 11 HP personnel, both supervisory reviews of past audits of HP training, and regulatory and site procedurer (reference 1 through 10) indicate that HP personnel are aware of basic requirements for protective clothing.
I 2.
Wac the HP who stopped the crafts from working justified?
Ac peding to SQN procedures, the technician was justified in stopping work when in his judgment it was necessary for It is j
protecting the health and safety of the craft workers.
possible that, although none of the work that the crafts were l
performing required respirators or masks, some concurrent work i
in the same area may have had the RWP requirement for respiratory protection and the proximity of this other work was close enough that, in the HP's judgment, a valid radiological concern existed.
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Were both HP's involved in'the incident at fault due to insufficient knowledge of the work in the area? There is not
-enough information available to make an adequate determination of'this circumstance. However, none of the RIRs investigated during the 1983 and 1984 timeframe revealed a situation where HP's failed to follow good radiological practices.
L 4.
Were respiratory requirements specified on the kWP and, if so, did the craft workers read and sign the RWPt Due to the lack of specifics surrounding this incident, this scenario could not be substantiated. However, a review of RIRs for this period revealed in 16 of 62 cases that failure to follow instructions on the RWP was the cause of RIR being generated.
If the HP.who told the crafts people'that respirators or masks were not required violated the requirements of the RWP, an RIR should have been written against the siolation. None was found.
4 5.
Was the concern-a result of poor communication between HP's and the crafts? All of the personnel interviewed stated that-communication between HP and other departments and crafts has been a problem but that it has shown improvement in recent years.
Conclusions XX-85-102-009 and XX-85-102-012 The evaluation and review of NSRS Repcet I-85-734-SQN confirmed the conclusions of the NSRS report. Suppoeted by documentation, i.e.,
INPO accreditations and various audit materials, no major programmatic deficiencies were found. Resolution of the items identified in the NSRS l
report have been addressed and where appropriate have resulted in i
revisions to the POIC basic phase training format. There were however, some minor defielencies identified in the area of response to supervisor feedback questionnaire. The evaluator agrees with and supports the NSRS conclusions that the concerns XX-85-102-012 and XX-85-102-009, j-j as stated, are not substantiated.
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V R;visicn 5 XX-85-024-001 Based upon the results of this evaluation of concern XX-85-024-001 and the questions formatted and resolved, it was determined that the concern is not substantiated and no corrective action is needed.
IV.
ROOT CAUSE No root cause was determined since none of the concerns were valid.
V.
GENERIC APPLICABILITY The findings of this report regarding the basic phase of Health Physics Technician training are considered generic to all TVA sites as the training is conducted at the POTC alone.
The findings regarding the site specific training are generic as each I
site's program differs. Therefore, further evaluation of these concerns IRS should be conducted at each site.
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R:visien 5 VI.
REFERENCES 1.
SQN RCI-1, Revision 29 2.
SQN RCI-4, Revision 20 3.
SQN RCI-11, Revision 5 4.
SQN RCI-14 Revision 5~
5.
SQN HPSIL-3, Revision 11 6.
SQN HPSIL-31. Revision 0 7.
SQN ASIL-3, Revision 10 8.
SQN HPSIL-5, Revision 19 9.
SQN FSAR Section 12.3 " Health Physics Program" 10.
SQN HPSIL-7, Revision 12 11.
NSRS Report Number I-85-734-SQN " Training of Health Physics Technicians," March 11, 1986.
12.
Letter to Hugh Parris from E. P. Wilkinson, INPO, January 13, 1984 (RIMS A02 840116 016) 13.
Memorandum to N. E. Scott from C. C. Mason, " Health Physics Technician (HPT) and Radiochemical Laboratory Analyst (RLA)
Training Program Evaluation" (RIMS L53 830621 954) 14.
Lotter to H. G. Parris from David M. Vere 111, USNRC, " Reports 50-327/84-34 and 50-328/84-34," (RIMS A02 841130 005/L44 841208 020) 15.
Memorandum to H. L. Abercrombie from K. H. Whitt, " Nuclear Safety Review Staff Investigation Report Transmittal" (MATS 8280) 16.
SQN Tech Spec units 1 and 2 17.
NUREG 0041 19.
TVA Area Program Manual 0301.06 20.
Radiological Incident Reports 83-28 83-29 84-06 84-07 84-08 84-09 84-31 84-32 84-33 21.
Sequoyah Nuclear Plant - Office of Quality Assurance Audit Report CH-400-14
" Health Physics Training and Staff Qualifications" (RIMS S53 840926 936) d Page 8 'of 10
I Revision 5 22.
Memorandum to H. L. Abercrombie from G. W. Killian, " Evaluation of Corrective Action Response - Deviation Report CH-400-14-02"
-(RIMS L17 841003 802)
'23.
Memorandum to H. L. Abercrombie from G. W. Killian, " Evaluation of Corrective Action Response - Deviation Report CH-400-14-03" (RIMS L17 841030 802) 24.
Memorandum to H. L. Abercrombie from G. W. K1111ar., "Sequoyah Nuclear Plant - Office of Quality Assurance Audit Report CH-400-14 Health Physics Training and Staff Qualifications" (RIMS L17 850104 801) 25.
Memorandum to G. W. Killian from John Hutton,-" Division of Quality Assurance Audit Report CH-400-14. Health Physics Training and Staff Qualifications" (RIMS L47 850117 806)
- 26. -Memorandum to G. W. Killian from H. L. Abercrombie, "Sequoyah Nuclear Plant - Offico of Quality Assurance Audit Report CH-400-14
- Health Physics Training and Staff Qualifications" (RIMS S53 850206 923) 27.
Memorandum to H. L. Abercrombie from G. W. Killian, " Evaluation of Corrective Action Response to Deviation Report CH-400-14-01" (RIMS L17 850228 800) 28.
Memorandum to G. W. Killian from J. W. Hutton, " Division of Quality Assurance Audit Report CH-400 Health Physics Training and Staff Qualifications" (RIMS L44 850327 801) 29.
Memorandum to J. Hutton from G. W. Killian, " Evaluation of Corrective Action Taken - Deviation Report Closure" (RIMS L17 850530 806) 30.
Memorandum to H. L. Abercrombie from G. W. Killian, " Evaluation of Corrective Action Taken - Deviation Report CH-400-14-01" (RIMS L17 850807 800) r 31.
Memorandum to J. Hutton from G. W. Killian, " Evaluation of Corrective Action Taken - Deviation Report Closure" f
(RIMS L17 850816 802) 32.
Memorandum to G. W. Killian from H. L. Abercromble "SQN-DQA Audit Report CH-400 Health Physics Training and Staff Qualifications" (RIMS S$3 850828 928) 33.
Memorandum to H. L. Abercrombie from G. W. Killian, " Evaluation of Correctivo Action Response - Deviation Report CH-400-14-01" (RIMS L17 850920 802) i
.34.
Letter to J. A. Coffey from G. W. Killian, " Division of Quality Assurance Audit Report CH-400 Health Physics Training and Staff Qualifications," dated August 24, 1984 (RIMS L17 840905 803)
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Memorandum to Those listed from G. W. Killian, " Transmittal of QAB 35.
Audit Report Q55-A-85-0012" (RIMS L17 850905 800) 36.
Regulatory Guide 8.15-October 1976 37.
Regulatory Guide 8.8, Revision 3-1978 38.
10 CFR 20, " Code of Federal Regulations" 39.
TVA Program Manual - 0202.12, Revision 2-March 10, 1986 TVA HPT002L.002 " Radiation Monitoring Equipment," Revision 2 41.
June 9, 1986 TVA HPT002.013 " Sources of Radiation and Contamination: Controlle 42.
Zones and Limits," Revision 2, June 11, 1986 TVA HPT-LP14, Revision 0, July 21, 1983, " Radiation, Contamination, 43.
and Airborne Survey Techniques and Evaluations" TVA HPT-LP16 " Respiratory Equipment and Protective Clothing" 44.
Health Physics Retraining Program Evaluations Periodic Evaluation 45.
Questionnaires for 1985, CHPST-51L-T-6, Revision 1 November 11, 1983 i
VII. IMMEDIATE OR LONG-TERM CORRECTIVE ACTIONS l
CATD 31101-SQN-01 was issued to resolve deficiencies in the response to supervisor feedback questionnaire.
The Sequoyah Corrective Action Plan in response to the CATD states:
1 No further action required based upon recent revisions to applicable instructions as follows: Health Physics Training (Non GET) Procedure 0202.12 R2, 3/86; Division of Nuclear Training Standard Practice TCT 12 10/86; C, HP and Safety Training Section Instruction Letter T6, R2, 3/86.
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