U.S. Nuclear Regulatory Commission

Qualification of Reactor HP Technician

HPPOS-022 PDR-9111210126

Title: 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

Applicability: Reactors