Qualification of Reactor HP Technician
See the letter from R. C. DeYoung to J. A. Jones (Carolina Power and Light Company) dated December 1, 1981.
Sufficient time and breadth of experience are important for an HP Technician placed in a responsible position. The licensee used an HP Technician with only eleven months experience, most of which was observing personnel monitoring themselves for contamination, to control radiation exposures to workers during steam generator maintenance.
A radiation exposure to the head in excess of NRC limits was received by a worker during steam generator maintenance at a licensee facility. The exposure of the worker was controlled by chest-worn, self-reading pocket dosimeters, despite the fact that evaluation of working conditions had previously revealed the head would receive a higher exposure than the chest. Additionally, the use of an HP Technician (or so-called HP Tech) who did not meet the minimum experience level required by TS, appeared to be among the causes of the radiation exposure in excess of NRC limits.
Technical Specification 6.3.1 requires that each member of the facility staff shall meet or exceed ANSI N18.1-1971 with regard to the minimum qualifications for comparable positions. Paragraph 4.5.2 of this ANSI standard states, in part, that technicians in responsible positions shall have a minimum of two years of working experience.
Contrary to the above, the Reactor HP Tech only had eleven months of experience consisting primarily of observing other workers surveying themselves for contamination. This level of experience was far below that required for performing survey work during steam generator maintenance.
The overexposed worker was marking steam generator tubes, a high radiation exposure task requiring vigilance on the part of the HP Tech to carefully monitor and control radiation dose rates and total worker doses. If the HP Tech had been more vigilant and experienced, he most likely would have been aware of the need for monitoring the exposure to the worker's head and to control the four entries into the steam generator by the overexposed worker.
While the magnitude of the radiation dose received by the worker only slightly exceeded the regulatory limit in this instance, NRC was concerned that, notwithstanding the previous civil penalty for a similar problem, the licensee did not adequately evaluate radiological conditions, establish effective protection measures, and implement applicable plant procedures. These concerns were expressed in an enforcement conference held on September 16, 1981, at the Region II office. One of the issues discussed was the requirement for continuous HP coverage of steam generator maintenance work. During the enforcement conference, the Manager, Environmental and Radiation Control, denied the allegation of failure to provide continuous HP coverage of the steam generator tube marking operation.
NRC acknowledged the presence of an HP Tech, but more than mere presence was required during a high exposure task. Civil penalties in the cumulative sum of $85,000 were imposed for the three items in the Notice of Violation.
Regulatory references: ANSI N18.1-1971, Technical Specifications
Subject codes: 1.1, 1.2, 12.7