NUREG-0731, Provides Info Re Experience W/Implementing NUREG-0731

Provides Info Re Experience W/Implementing NUREG-0731

ML20197F494
Person / Time
Site:	Comanche Peak
Issue date:	04/04/1981
From:	Dan Collins Office of Nuclear Reactor Regulation
To:	Office of Nuclear Reactor Regulation
Shared Package
ML20197F501	List: ML20197F503 ML20203N054 NUREG-0731, Summary of 860314 Meeting W/Util in Bethesda,Md Re Qualifications of Radiation Protection Manager as Compared to Qualifications Outlined in 1975 Rev 1 to Reg Guide 1.8, Personnel Selection & Training. Viewgraphs Encl
References
RTR-NUREG-0731, RTR-NUREG-731 NUDOCS 8104230371
Download: ML20197F494 (7)

Text

ENCLOSURE 4

' ,'jg '%g g UNITED STATES

' y, . g NUCLEAR REGULATORY COMMISSION 7, j WASHINGTON, D. C. 20555

,  % , ,,, , # APR 0 < 1981 MEMORANDUM FOR: Radiation Protection Section FROM: Doug Collins, Leader RPS

SUBJECT:

RADIATION PRGTECTION ORGANIZATION, STAFFING AND QUALIFICATION , ,

N e RPS has made several reviews of OLs using NUREG-0731 as criteria and this i memo is to provide you information on our experience with NUREG-0731 imple-

! mentation.

NUREG-0731 was issued as a draft in September9 l' 80 for' interim use in

evaluating near-term Ols per NUREG-0694. The salient radiation protection aspects of this NUREG and their application are listed below. l

1. Radiation' Protection Manager (RPM) Reporting

, a. Criteria Section II. A.1 of NUREG-0731 states that'"The functional areas of radiation protection, quality assurance, and training should assure independence from operating pressures" and that there be

" clear lines of authority to the Plant Manager." Figure 1 of NUREG-0731 shows a ' representative" plant organization with the RPM reporting directly to the Plant Mgr/ Asst. Plant Mgr and at the same level as the Operations Manager. In hddition, Regulatory Guide 8.8, Section C.1.b.(3), states: l The Radiation Protection Manager (RPM) ~(onsite) has a

- safety function and responsibility to both employees and management that can be best fulfilled if the individual is independent of station divi-sions, such as operations, maintenance, or  !

technical support, whose prime responsi- J bility is continuity or improvement of -

station operability. The RPM should have direct recourse to responsible management personnel in order to resolve ,

questions related to the conduct of the radiation protection program.

. ~ This section will be revised shortly to state that the Regulatory

}, . Guide 1.8 qualified RPM should have direct access to the Plant i' Manager in all radiation protection matters.

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Revision 3 of Regulatory Guide 133 (for Comment dated j l November 1980) states, with regard to " independence from operating pressures" and QA groups, that the NRC is i evaluating the effectiveness of an organizational structure in which the onsite QA group reports functionally to offsite QA management rather than to the Plant Manager. This is not the same meaning of

" independence from operating pressures" as applied to the .

RPM. Acceptable implementation for the RPM is discussed s bel ow.

b. Implementation c I

The two main goals with regard to the organizational structure are to give assurance that the radiation protection (RP) group is independent from operations  ;

and operational pressures and that the RPM has direct access to the Plant Manager in all RP matters. It is -

clearly unsatisfactory for the RPM to report to the Opera-tions or Maintenance Superintendent since this makes him j directly dependent on operational pressures. Although NUREG-0731 and Regulatory Guide 8.8 imply that the RPM should report directly to the Plant Manager, the Figure 1 i

is for a " representative" organization and Regulatory i

Guide 8.8 states that the RPM's responsibilities can be best fulfilled if he is independent of Technical Support dTTsion. This does not say that reporting to the Technical Support Manager is unacceptable; only that it is not the best organization. We have found acceptable a' system in I

which the RPM reports to the Technical Services Manager

~ ' with a commitment in the FSAR that the RPM has direct access to the Plant Manager for RP matters or that the RPM is a member of PORC. Each review should detennine if the proposed organizational structure does and will work (including access of the RPM to the Plant Manager) and if the functional orga nization that works is depicted by the FSAR and tech specs.

In instances where the organizational structure is questionable, P you should contact the Resident Inspector or assigned regional HP Inspector to get inpt.. In addition, if necessary, you should visit the site as part of your evaluation in order to interview the RPM. ,

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2. Radiation Protection Separate from Chemistry

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a. Criteria J Section II.A.1 of NUREG-0731 states that one characteristic that fonns the basis for a plant organization is that " distinct functional areas are separately supervised and/or managed."

Figure 1 of NUREG-0731 shows RP separate from Chemistry.

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Additionally, Standard Technical Specifications specify that radiation protection technicians meet ANSI 18.1 which requires in paragraph 4.5.2 that technicians in responsible positions shall have a minimum of two years of working experience in their speciality. Radiochemistry and Radiation Protection are listed as separate specialities in Section 4.4 of that ANSI standard.

NUREG-0654, in Table B-1 lists separately HP technicians .

and radiochemistry technicians. s

b. Implementation The bases for the separation of RP from Chemistry are (1) assurance that the RPM devotes sufficient attention to RP (and is not distracted from his responsibility to RP -

by Chemistry), and (2) assurance that technicians are not required to perform so many functions that they cannot main-tain specialized competence in dedicated functions. There are acceptable methods for achieving these goals other than total  ;

separation of RP from chemistry. We found acceptable organiza-  :

tions in which a Supervisor of Radiation Protection and Chemi.stry has two discrete functions (RP and Chem) reporting  ;

to him. In order to overcome the potential problem of dilu- l tion of Chem and RP Supervisor's management of and technical input into the RP program, a Regulatory Guide 1.8 qualified individual is put in charge of the RP group. Thus, the RP function has the benefit of the full-time direction of a Regulatory Guide 1.8 qualified individual. In these cases, the Chem and RP techs have been separate groups with separate duties and qualification standards. HP Appraisair have found plants where the cambination of RP and Chemistry duties have resulted in problems because of the inability of technicians to maintain competence in all areas; they have also found programs where the combination technician has worked. In plants where the groups are separate, a few very good technicians have been able to maintain qualification in both areas. It, therefore,is theoretically possible to' qualify a staff of techs in both specialities, but it would require 4 years experience total per ANSI 18.1 and would require a great expenditure of effort in training and qualifying the J

staff in both areas. One plant has a contractor evaluating the organization for potential solutions to the dt.al-technician qualification problem. '

3. Shift Staffing

a. Criteria NUREG-0654, Table B-1, specifies that there be an HP tr..;hnician on 4

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I APR 0 ' 13^1 each shift as a minimum. This on shift person must be a tech-nician qualified per ANSI 18.1, not "an individual qualified in RP procedures" as specified in Tech Specs of operating reac-tors in the past. A footnote to the table shows that two such

" individuals qualified in RP procedures" are required in addition to the technician.

Section II. A.d.(2) of NUREG-0731 states that a RP technician should be onsite at all times. - 1

b. Implementation Beyond this minimum, there must be sufficient staff to per-form the assigned RP functions. Those functions assigned RP vary from plant to plant. Many functions, such as TLD processing, bioassay, instrument calibration, environmental monitoring, etc. can be contracted out and therefore the in-house staff to perform RP functions is variable. HP Appraisals have found that some.of the better programs at one-unit stations have only 10-11 people on the entire RP staff. Other plants with substantially more personnel have had more significant findings.

4. Back-up to RPM

a. Criteria Section II.A.2 of NUREG-0731 states that there should be in-depth experience at the Radiation Protection Manager level.

, Section 4.4.4 of the December 1980 draft ANSI 3.1, which will be adopted by Regulatory Guide 1.8 spcifies that an individual who temporarily replaces the RPM should have a B.S. degree in science or engineering and 2 years experience, six months of which should be onsite.

b. Implementation It is our intent that the backup to the RPM be assigned to the site, but in certain circumstances he may be assigned at corporate with close ties to the site. For example, the corporation HP of a one unit utility located near (app. 30 miles) to the site might be acceptable as a back-up to the RPM if, during the RPM's absence he is assigned to the site.

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5. RPM Qualifications '

a. Criteria j Standard Technical Specifications specify that the RPM should

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. be qualified in accordance with Regulatory Guide 1.8, which o

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currently states:

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The Radiation Protection Manager (RPM) should be an experienced professional in applied radiation protection at nuclear facilities dealing with radiation protection problems and programs similar to those at nuclear power stations. .

The RPM should be familiar with the s design features and operations of nuclear power stations that affect the potential for exposures of persons to radiation. The RPM should have the technical competence to establish radiation protection programs and the supervisory capability to direct the work of professionals, technicians, and journeymen required to implement the radiat,1on protection programs.

The RPM should have a bachelor's degree or the equivalent in a science or engineering subject, including some fomal training in radiation protection. The RPM should have at least five years of professional experience in applied radiation protection. (A master's degree may be considered equi-valent to one year of professional experience, and a doctor's degree may be considered equivalent to two years of professional experience where course work related to radiation protection is in-volved.) At least three years of this professional experience should be in applied radiation protection work in a nuclear facility dealing with radio-logical problems similar to those encountered in nuclear power stations.

• preferably in an actual power station.

Equivalent, as used above for the B.S. degree, may be met by (a) 4 years of fomal schooling in science or engineering, (b) 4 years of applied radiation protection experience at a nuclear facility, (c) 4 years of operational or technical experience / training in nuclear power, or (d) any combination of the above totaling 4 years. With regard to other clart-J fications of the R.G.1.8 wording, see the attached EEB Branch Position dated March 2,1978. Note that with regard to the numbcr of refueling outages in the EEB position, the 6

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} NRC is adopting a new ANSI 3.1 which will require 6 months l l

onsite and one refueling outage. l s

b. Implementation l There should be a Regulatory Guide 1.8 qualified RPM assigned at the site. In some instances the individual assigned RPM l has strong management capability but does not have the radiation j j

protection technical experience of Regulatory Guide 1.8. - How . 1 i ever,we have found it acceptable for this individual to function s l as RPM when he is supported by an individual in the line organi- I I

j zation (e.g. HP Supervisor) who has the Regulatory Guide 1.8 education and technical experience. We have not found it accep-i table to have a Regulatory Guide 1.8 person not in line (e.g.

as a staff member of a rad engineering group).

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i j 6. Radiation Protection Technicians

- a. Criteria )

ANSI 18.1, Section 4.1, states that individuals must have the I training and experience to do the job. Section 4.5.2 states that technicians in responsible positions shall have a minimum j

of two years experience in their specialty and should have one ,

year of related technical training. In practice, the shall 2 years 1 applies, with training as part of the 2 years.

I ANSI 18.1, Section 5.1 and 5.3, specify training in general j tems. Section 5.5.1 specifies retraining in more specific

], tems.

Proposed Regulatory Guide 1.8 (RP 807-5, Sept.1980) on page 18 specifies a perfomance oriented training and qualification for .

t technicians.

b. Implementaton

- A " responsible" radiation protection technician is one who:

1. Reviews surveys perfo5ned by others; l

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2. Signs RWPs; i

3. Issues RWPs;

4. Independently perfoms surveys or evaluations used to pemit compliance with regulatory requirements.

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APP 0 / 1991 We have accepted an alternative to two yeasrs experience (the quality of which is not specified by ANSI). This alternative would consist of an NRC reviewed and approved training program with a 1 year experience requirement (the quality of which would be specified). Some licensees have contended that the retraining 11sted in Section 5.5.1 of AMSI 18.1 does not apply to radiation protection technicians. ,

This retraining does apply. N l

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' Douglas M. Collins, Leader Radiation Protection Section Radiological Assessment Branch Division of Systems Integration cc: W. Kreger D. Collins l

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