U.S. Nuclear Regulatory Commission
Clarification of Regulatory Guide 1.8 on Qualification of Radiation Protection Manager
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
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
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
Regulatory references: ANSI N18.1-1971, Regulatory Guide
1.8, Technical Specifications
Subject codes: 1.1