ML20197F503

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Discusses Licensee Dissatisfaction W/Nrc Position Re Qualifications of Onsite Radiation Protection Managers
ML20197F503
Person / Time
Site: Comanche Peak Luminant icon.png
Issue date: 03/02/1978
From: Grimes B
Office of Nuclear Reactor Regulation
To: Goller K
Office of Nuclear Reactor Regulation
Shared Package
ML20197F501 List:
References
RTR-REGGD-01.008, RTR-REGGD-1.008 NUDOCS 8104230375
Download: ML20197F503 (6)
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Text

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. - . -, ENCLOSURE 6 l

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~.,arl R. Eollar. .'. sin:. : Dir2ct:r f:r CFmtins FE.CPUiSt:N FOR:

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Brian K. Grices, Chief. Envirecmntal Enl::atica- 3

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Branch, DOR

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SUBJECT:

QUA1.IFICATIONS OF TEE OX5ITE RADIATION PROTEC .

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- Several licensees have requested exceptiens to the is:plementatien of j

- Regulatory Guide 1.8 in their response to letters sent to licensees (enclosure 1). Oconee, Three Nile Isla::d. Point Beach and Pilgrim have expressed dissatisfaction with NRC's position and are t.willing to ccomilt to requiring qualifications recces: Ended by Regulatory Guide 1.8 for future radiation protection sanagers. iEnclosure 2 is the En- ,

vironmental Evaluation Branch Position that considers the issues rais 16 the aforecantioned licensees.

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! Orignal Signed by n Brian K. Grimes

' Brian K. Grires, Chief Environurntal Evaluation Branch

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Division of Operating Reactors 35d

Enclosures:

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.- l* C. Eisenhut

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R. Vollmer

.- . 02 B/C ti. Kreger T. Murphy C. Trarrell

,' . G. Zwetzig J. Hannon . .

-. .- M. Fairtile -

"j. L. Barrett

- E. Adensam

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I R. Alexander- l

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Docket No. 50- * *

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7 We note that your facility technical specifications do not require tha j the individual performing the function of Radiation Protection Manegeri 4

(RPM) meet the minimur.1 qualification requirements of Regulatory Guide ;

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1.8, September 1975. As stated in this guide, it is the NRC, position i that if the RPM is reassigned or the incumbent replaced, the new RPM should have qualifications equivalent to those stated in this guide.

To implement this provision, we request that you determine if the' l

' individual performing the function of Radiation Protection Manager meets the minicum qualifications of Regulatory Guide 1.8, September 1975. In the event the RPM is so qualified, you should propose a 4

technical specification to be included in the Administrative Controls Sectica which states that "the RPM (or equivalent position title) shall nieet or exceed the qualifications of Regulatory Guide 1.8,

! September 1975".

j In the event you detemine that the present incumbent does not meet i-the minimum requirements of the guide, you should advise us of this fact and provide a written comnitment that the successor to the Q

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  • incumbent will be so qualified and that you will propose a technical specification to that effect at that time. .

The above action should be completerf wlthin 60 days of receipt of this

! l etter. In the event you should desire further discussion of this

~. j matter, please contact us.

Sincerely, .

- Of,-

,' Chief Operating Reactors Branch f

[,- Division of Operating Reactors

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- ENCLOSURE 2

! Qualificatior: of an onsite Radiation Protection Manager (RPM)

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F P.epistory Guide 8.3, Re/isica 2. Sc: tion 0.1.5.(3) s:stes that the l

. . P.adiation Trcta: tion Manager (onsite) should have qualifica:icns as O

presented in Regulatory Guide 1.8. Tne word "onsite" was purpose-

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,{ fully added to the section on " Personnel Qualification and Training" s

. of Regulatory Guide 8.8, Revision 1 so that the staff would have somh basis for confidence that well trained and experienced radiation pro-tection personnel (as described in Regulatory Guide 1.8) would be

, imediately available ,to, onsite personnel to ensure that their exposures under nomal and accident conditions were kept'"c.s low as reasonably

.f achievable"(ALARA). Although the qualifications of the RPM in Regula- i

$ tory Guide 1.8 does not attest to his competency or expertise, it does

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. k provide a basis for ass'uring that the individual assigned that job respon- l

sibility is a knowledgeable professional who can provide the supervision

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necessary to implement the program required for radiation protection. The h:

practical requirement for "onsite" RPM management is that radiation protec-

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, tion management, surveillance, and dose monitoring 1ay be maintained by J. q'ualified health physics personnel during day-to-day plant operations. The.

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i onsite Radiation Protection Manager is also supported by onsite plant man-

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agement.' Together they must have a day-to-day working relationship in orar l

to (1) implement the station Al. ARA' program effectively (2) resolve site

! specific questions relating to the ALARA program, (3) effectively handle

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-l emergency situations involving overexposed or contaminated site personnel, f and (4) provide expertise in decision-making with respect to accidents thit e

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cay have a potential for release of radioactive materials to the environ- I

, ra.r.t . The ensite RPM cust be ready to icediataly adviv.' plant ra .ag .2h O

en aach of the arc-ec.entiened items with lit:la or ca offsite intarac:icn The ensite R?". would also have a "feal" for difficult :paraticnal/::intsn-i

. ance problems of which an offsite person would have only secondhand know ;

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} 1 edge. Finally, Regulatory Guide 8.8 has recently been reviewed by indusi3 i j at which time no comment was made with respect to the "onsite" RPM meeting 4 the qualifications of Regulatory Guide 1.8. -

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  • . j Accordingly, we recomend that technical specification changes tilat would j ' allow the individual that meets the qualifications of Regulatory Guide 1.8 I

to perform the function of RPM while he is stationed "offsite" be disap-i proved.

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One licensee (Metropolstan Edison) requested that the qualifications of the.

RPM be divided by two individuals. The qualifications of the RPM as receml -

f mended by Regulatory Guide 1.8 considers both technical background (B.S. !

degree or equivalent) and professional experience in applied radiation protection. These qualifications were not intended to be shared by two l l.s people, one having the technical background and the other the professional experience, because each of these features complement the other. They allu an RPM to make independent technical and professional judgments in crder -

conduct and supervise the radiation protection program on a managerial levd

. 1 Having two separate people does not permit this type of operation. Considv-able decision-making effectiveness would be lost because of possible cormm-~ l

. l cation difficulties between two people trying to manage a ' single pr6 gram.

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W In sumary, the sum of two persons with 50% of the qualifications nj ,

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not equal one person with 100% of the qualifications. Consequen

n re:c.T. sad that technical specification chaage., which car.zit the c as tiens of the RPM to be divided between two individuals not; be a .

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Some comments have also been made by licensees with r

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i 3 ments of Regulatory Guide 4 1.8 that the radiation protection mana '

years of professional experience in applied radiation protection in to a college degree or equivalent.

One issue raised here is that indivicWS

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with these qualifications may not be available in future years. The basi s for recomending 5 years of professional . experience is lthat th -

' low an RPM candidate to experience many of the technical -

i minis'trative procedures associated with radiation protec

typical at LWR's.
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At least two years of this experience should.be in ap

! health physics work in a, nuclear facility implementing l o prog g

those required in an LWR station, but preferably in an

- LWR

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- . ' 3 ing this period, he should participate in at least twonc LWR r! '

t j major 'naintenance operation supervising the work of health y

cians required to implement the radiation protection program a I

1 ALARA program.

c I N Certain individuals (e.g., an individual with exceptional qualifications at a multi-unit statior) may achieve this experie ciated competence in a. shorter interval. t j In these exceptional cases, alter-native technical specifications may be approved on a case basis.; ~

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respec,t to th,e possib'lt.fut'ure Unavailability ol_trd'in5d e '

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. . i believe it would be inappropriate to base our qualification requirac.ents.

.- i on this potential problem. Assurance of an adequate pool of trained

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