U.S. Nuclear Regulatory Commission

Clarification of Regulatory Guide 1.8 on Qualification of Radiation Protection Manager

HPPOS-020 PDR-9111210132

Title: Clarification of Regulatory Guide 1.8 on

Qualification of Radiation Protection Manager

See the letter from A. Schwencer to W. O. Parker, Jr.,

dated October 11, 1977, and the incoming request from W. O.

Parker, Jr. (Duke Power Company) dated May 13, 1977. The

NRC position is that ANSI N18.1-1971 does not provide

appropriate qualifications needed for the Radiation

Protection Manager whose responsibility is to manage an

onsite radiation protection program. A clarification is

provided for the equivalent of a bachelor's degree as used

in Regulatory Guide 1.8. HPPOS-018 and HPPOS-217 contain

related topics.

ANSI N18.1-1971 states that "the responsible person shall

have a minimum of five years experience in radiation

protection at a nuclear reactor facility. A minimum of two

years of this five years experience should be related

technical training. A maximum of four years of this five

years experience may be fulfilled by related technical

training or academic training."

Regulatory Guide (RG) 1.8 requires the RPM to have nine

years of training and experience (e.g., a bachelor's degree

plus an additional five years of experience, three of which

must be in radiation protection). The requirements for

Station Manager and Technical Services Superintendent,

established by ANSI N18.1-1971 and deemed acceptable by RG

1.8, are ten years and eight years of experience,

respectively, with a degree not being a requirement.

The requirement of a bachelor's degree is not considered to

be germane to the specific functions of the Radiation

Protection Manager (RPM). The only position at the station

that presently requires a degree is that of the Reactor

Engineer. The attributes of a good RPM are considered to

be gained almost exclusively by specialized on-the-job,

practical and supervisory experience rather than through

the broad generalized academic training received by a

person with a bachelor's degree.

RG 1.8 states that the RPM shall have a bachelor's degree

or equivalent in a science or engineering subject. To

provide clarification on this point, "equivalent" in the

content of RG 1.8 is defined as follows:

1. Four years of formal schooling in science or

engineering.

2. Four years of applied radiation protection

experience at a nuclear facility.

3. Four years of operation or technical

experience / training in nuclear power.

4. Any combination of the above totaling four years.

It should be noted that the above requirement is in

addition to the requirement for five years of professional

experience in applied radiation protection as specified in

RG 1.8.

Regulatory references: ANSI N18.1-1971, Regulatory Guide

1.8, Technical Specifications

Subject codes: 1.1

Applicability: Reactors