ML20203N682
| ML20203N682 | |
| Person / Time | |
|---|---|
| Issue date: | 12/20/1977 |
| From: | Liza Cunningham NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Fisher W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8610170139 | |
| Download: ML20203N682 (3) | |
Text
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UNITED STATES
[
NUCLEAR REGULATORY COMMisslON WASHINGTON D. C. 20555 DEC 1,81977 MEMORANDUM FOR:
W. L. Fisher, Acting thief, FFMS Branch, Region III FROM:
L. J. Cunningham, Acting Assistant Director, Division of FFMSI, IE:HQ
SUBJECT:
ENFORCEABILITY OF NRR LETTER TO LICENSEES--RE:
CRITERIA FOR " INDIVIDUALS QUALIFIED IN RADIATION PROTECTION PROCEDURES Your memo of November 30, 1977 expressed your doubts about the enforce-ability of the criteria contained in the NRR letter sent to all operating power reactor facilities.
Further, you asked for a determination whether a citation could be issued for failure to comply with any or all of the six criteria.
The following is the Division of FFMSI position regarding your questions:
1.
The " Criteria" are to be used as part of the determination of compliance with the technical specification which requires "at least one member of each operating shift crew shall be qualified to implement readiation protection procedures."
2.
Any citation must be against the technical specification, not the list of criteria.
The list of criteria may be referenced to detail the basis for the citation.
By copy of this memo, all Regions are being informed of the Division position on this subject.
F
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J. Cunningham Acting Assistant Director Division of Fuel Facilities and Materials Safety Inspection Office of Inspection and Enforcement
Enclosures:
Sample Letter Criteria cc:
L. Higginbotham P. Nelson J. Sutherland G. Brown H. Book CONTACT:
L. J. Cunningham 49-28188 97 220 l
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UNITE D 5f ATES NUCLEAR REGULATORY COMMisslON y
y WASHING TON, D. C. 20555 0
f SAMPLE LETTER fl Docket No. 50-Licensee,
Gentlemen:
RE:
As you may be aware, the provision for "an individual qualified in
. radiation protection procedures to be on site when fuel is in the reactor" has been a technical specification requirement for the majority of operating facilities for the past several years.
The intent of this requirement was to provide a minimum level of expertise in radiological protection at the operating shift crew level.
It was intended that these radiation protection personnel would perform routine radiation monitoring activities and thereby supplement a licensee efforts to maintain radiation exposure and release of radioactive effluents "as 1,ow as is reasonably achievable".
As a result of recent NRC staff discussions, we have formalized our position regardino the necessary activities " individuals qualified in radiation protection procedures" should be able to perform.
These activities and related clarifying information are presented for your information in the attached enclosure.
The OI8E Inspector assigned to your facility will be using this same criteria in determining whether your designated individuals meet these requirements.
We recommend you review the enclosed criteria promptly so that you may take any action necessary to meet the requirements.
In the event you desire further discussion of this matter, please contact us.
I Sincerely, l
. Chief Operating Reactors Branch #
Division of Operating Reactors
Enclosure:
Criteria for " Individuals Qualified in Radiation Protection Procedures" 1
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CRITERIA FOR " INDIVIDUALS.0UALIFIED IN' RADIATION PROTECTION PROCEDURES" i
An individual is considered to be qualified in radiation protection procedures when a licensee certifies that each designated individual 1
is capable of successfully accomplishing the following activities as required by federal regulations, license conditions, and facility procedures pertaining to radiation protection.
1.
Conduct special and routine radiation, contamination and airborne radioactivity surveys and evaluate the results.
2.
Establish protective barriers and post appropriate radiological signs.
3.
Establish means of limiting exposure rates and accumulated radiation doses, including the use of protective clothing and respiratory protection equipment.
4.
Perform operability checks of radiation monitors 'and survey meters.
5.
Recommend appropriate.immediate actions in the event.of. a radiological problem and perform necessary activities until the arrival of health physics personnel.
6.
Conduct other routine radiological duties (e.g., TS surveillance items) as may be required on backshifts or weekends.
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