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:
Four years of formal schooling in science or engineering.
Four years of applied radiation protection experience at a nuclear facility.
Four years of operation or technical experience / training in nuclear power.
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