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. JR 2 9 IW MEM3RANDU:4 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-TPAINING OF POWER REACTOR HEAL.TH PHYSICS TECHNICIANS
'This refers to the cemo to you, dated July 10, from J. Philip Stohr on the same subject.
k'e agree with Region II that there is a clear need to take action in this area.
Our relateswording in aquestion.
to this recent Order modifying the Oyster Creek license, copy attached, k'e suggest the following material, which builds on the ideas set forth in.the Region II memo... be incorporated into the Radiation Protection Plan or a Regula-tory Guide whi'ch could contain or refer to the suggested Power Reactor Health Physics Training Manual.
SUMMRY The radi.ation protection organization training and qualification program must be approved by NRC and must consist of the following elements:
- 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 l must be set aside and a documented. testing procedure must be used to i 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 exa11inations 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 8603280019 e60123 PDR FOIA ,
DEVINEB4-744 PDR
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Jar.es H. Sniezek 2 JUL 2 9 M
- 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 followirg 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 ac.d 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 " resp'onsible position" in ANSI-N18.1 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 tr.aterial 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.
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Ja.es H. Sniezek 3 JUL 2 91530 iPAINING AND RE-TRAINING The list of topics $n the enclosure to the Stohr Memo is excellent. I would suggest the addition of the following topics:
Radiation k'ork Permit Nuclear Power Plant System Fundamentals The topics; PWR/BWR Radiation Sources In-Plant and Power Reactor Rules of Thumb which 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 grasp 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 wirl 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 and 2) requalification training.
Successful completion of the training and re-training and associated examinations are necessary prerequisites for gaining and holdirig the position in questior,. ,
DEMONSTPATION OF UNDERSTANDING OF AND ABILITY TO PERFORM PROCEDURES 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 why the procedure exists and how the procedure accomplishes its purpose.
The foreman should then certify his findings by signature entries in the individ-ual'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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Jt es M. Sniezek 4 JUL 2 9 E2
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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 appoined it.
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Geo ge . mith, Chief Fue' F ilities and Materials Sa ety Branch
Enclosure:
As stated *
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FF&MS Branch Chiefs RII RIII -
RIY RV T. Murphy O
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UN11ED STATES OF AMERICA NUCLEAR REGULATORY C0:WISSION In the Matter of ' '
Docket No. 50-219 Jersey Central Power and Light Company (Oyster Creek Nuclear Generating Station, Unit No.1) ), .
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ORDER MODIFYING LICENSE
, EFFECTIVE IMMEDIATELY I
The Jersey Central Pcwer and Light Compan Operating License DPR-16 (the " license") y (the which " licensee")
authorizes is the operation holder of of the Oyster Creek Nuclear Generating Station at steady state reactor core pcwer 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 (BWR), 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 airborne radioactive material which resulted in intake by one of the workers of approxima,tely 29 percent of the maximum allowable quantity of cobalt 60. A second instance of the use of unqualified personnel was identified during a Health Physics Appraisal inspection conducted May 12-16, 1980. During this inspection, an uncualified contractor technician was observed to allow personnel 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. '
l As a result of the first instance, a letter dated April 2,1980. was sent to the Director, Region I, U.S.N.R.C.. In this letter, the licensee's Manager of Nuclear Generation addressed immediate corrective actions and, among other things, stated, 'l 4
"0yster Creek will use Radiation' Protection Technicians who meet or exceed ANSI N18.1-1971 in responsible positions. ~
Unqualified tr.chnicians acting in less responsible positions will be closely supervised. This Action will I be implemented April 7,1980."
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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 techn.icians in responsible positions who did not meet the requirements of ANSI N18.1-1971. The initial NRC review of resumes, observation of field perfor' mince 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 to have no
. prior applied nuclear power plant experience. By May 19, 1980, it was d'etermined through further licensee review that an additional 10 of the 28 contractor.
technicians did not meet the ANSI NI8.1 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 ever safety-related activities and the prcmpt resolution of identified problems, I have detennined that the public health, safety and interest require, effective irimediately, 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 Corrmission's regulations in 10 CFR Parts 2 and 50, license No. OPR-16 is modi-fied by the following addition 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 perform specified work. This certification must be based on an NRC approved, documented progr.am consisting of classroom training with appropriate examinations and documented positive findir.gs 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. , Washington, D.C. 20555.
by tha licensee or an interested person, the Co=nission will issue an OrderIf a hearing is r designating the time and place of hearing. Such a request for hearing SHALL NOT STAY THE IMEDIATE EFFECTIVENESS OF THIS ORDER.
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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 'this Order should be s5s'tained.
FOR THE NUCLEAR REGULATORY COMMISSION Victor Stello, Jr.
Ditector -
Office of Inspection and Enforcement Dated at Bethesda, Maryland this day of , 1980 -
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NUCLEAR REGULATORY COMMISSION *
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Docket Nos.: 50-275 00T 2 819B0 and 50-323 . ._.--
HEMORANDUM FOR: Robert L. Tedesco, Assistant Director ./
for Licenr3[.g, DL .
FROM: William E. Kreger, Assistant Director for Radiation Protection, DSI -
SUBJECT:
DIABLO CANYON - SUPPLEMENT TO SAFETY EVALUATION REPORT -
REQUESTS FOR ADDITIONAL INFORMATION PLANT NAME: Diablo Canyon Nuclear Power Station, Units 1 and 2 LICENSING STAGE: OL DOCKET NUMBERS: 50-27.5/323 MILESTONE NUMBER / BRANCH CODE: 40/33 RESPONSIBLE BRANCH: LB!3; B.C. Buckley, LPM DESCRIPTION OF RESPONSE: Supplement to SER/ Requests for Additional Information REVIEW STATUS: Continuing g- Enclosed is a supplement to the Diablo Canyon Safety Evaluation Report. This report sumarizes the status of the Three Mile Island Lessons Learned items -
\,, from NUREG-0578 which are reviewed by the Radiation Protection Section (RPS).
The RPS review encompasses: Item II.B.2(2.1.6.b) - access to areas not including vital equipment protection; Item II.B.3(2.1.B.a) - post-accident sampling ALARA considerations not including systems and procedures; Item II.F.l(2.1.8.b) - high range in-containment radiation monitors; Item III.D.3.3
-(2.1.8.c) - portable radioiodine air sampling and analysis; and Item I.B.l.2 from NUREGS-0660/0694 - radiation protection organization only.
Status of Review II.B.2 - Open - Response from applicant expected in November. SSER pending Q331.18 response.
II.F.1 -
Open - Additional information regarding in-situ calibration and calibration. frequency requested. SSER pending Q331.24 response.
III.D.3.3- Complete - Updated SSER attached.
I.B.l.2 -
Open - Additional information regarding RPT on each shift, total numbers of RPT's, and qualification of RPM backup requested. SSER-pending Q331.21, 22, 23 response.
II.B.3 -
Complete - SSER attached.
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Staff positions and requests for additional information are additionally included. This evaluation was perfomed by R. J. Serbu, RPS/RAB. -
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William E. Kreger', Assista Director for Radiation Protectio
- Division of Systems Integration
Enclosure:
As Stated ,
cc: w/ enclosure '
D. Ross -
F. Miraglia B Buckley Collins
. Serbu T. Murphy
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,) RADIATION PROTECTION SECTION/ RADIOLOGICAL. ASSESSMENT BRANCH 331.0 (471.0) ~RAB Q331.21 -
(I.B.1.2) You have previously committed to add sufficient qualified radiation (13.1.2) .orotection technicians to provide a radiation orotectinn technician for each shift in accordance with NUREG-0654 and NUprn_n731," Guidelines for Utility Management Structure and Technical Resources.* Describe --
how your radiation protection organization is staffed and structured to provide a qualified radiation protection technician on each shi'ft, with enough radiation protection technicians overall to assure adequate radiation protection coverage for normal operation, maintenance and outages, and emergency situations.
Q331.22 In lieu of providing separate chemistry and radiation protection (1.B.1.2) organizations and in order to grgylda a cualified backup for the (13.1.3) . radiation orotection manaaer function in accordance with the positions ,-
of Regulatore Guide 8.8, NUREG-0660, and NUREG-0731. " Guidelines for Utility Management structure ano lechnical Resources," provide a commitment so that the Senior Radiation Protection Engineer, or his replacement, is qualified in accordance with Regulatory Guide 1.8. ,
'331.23 Provide a description of how your radiation protection qualification 1 0.1.2) and retraining program for Radiation Protection Technicians meets 1) the criteria of ANSI 18.1.
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1 L31.24(RSP) It is our position (Letter. D.G. Eisenhut, September 5,1980) that
,ll.F.1) calibration of high range containment radiation monitors be performed
, -12.1.4 ' in-situ using calibrated radiation sources for all decade ranges-below 1R/hr. Calibration should be performed each refueling outage (e.g.every18 months).
(1) Provide a commitment for in-situ caliberation of the high range radiation monitors for decade ranges below lR/h'r, or describe an acceptable alternative, r (2) Provide a commitment to perform an in-situ calibration on the high
- range radiation monitors at each refueling outage.
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. _e 331.1 In accordance with the recommendations' of Regulatory Guide 1.8, the Assistant Superintendant. Engineer-Radiochemistry, does not qualify as a Radiation Protection Manager (RPM) since he does not presently .
have the three years of professional experience dealing with radiolo-gical problems in applied radiation protection encounted at an operating nuclear power station or equivalent. Therefore, please .
justify the selection df the individual delineated for this position based on, his training and experience as shown in section'13.l.3.2 and . .
specify, as required, how he will a'chieve the aforementioned experience, prior to the. plant being licensed, to qualify a's'the RPM. -
331.2 Based on information contained in the draft document " Criteria for
, Utility Management and Technical Competence" it is our position that the Radiation Protection Group be a separate organization from the Chemistry Group. Your station organization chart' (Figure 13.1-3) shows these groups combined. Additionally, in accordance with Regulatory Guide 8.8, it is our position that the Radiation Protection Manager
, (RPM) should have . access to the Assistant Plant Superintendent in radiation protection matters. In matters relating to radiological health and safety, the RPM has direct responsibility to both employees .
and management that can best be fulfilled if he is indepandent of station divisions, such as operations, maintenance or technical support, whose prime responsibility is continuity or improvement of station operability.
Your FSAR and proposed Technical Specifications should be revised to reflect how your planned radiation protection program reflects this Position.