United States Nuclear Regulatory Commission - Protecting People and the Environment

U.S. Nuclear Regulatory Commission

Enforceability of NRR Letter Regarding "Individuals Qualified in Radiation Protection Procedures."

HPPOS-021 PDR-9111210121

Title: Enforceability of NRR Letter Regarding "Individuals

Qualified in Radiation Protection Procedures."

See the memorandum from L. J. Cunningham to W. L. Fisher

dated December 20, 1977. This memo provides a list of

criteria for "Individuals Qualified in Radiation Protection

Procedures." The criteria are to be used as part of a

determination of compliance with Technical Specifications

that require one member of each operating shift crew to be

so qualified. Citations for non-compliance should be

against Technical Specifications and not the list of

criteria.

Region III expressed doubts about the enforceability of the

criteria contained in an NRR letter sent to all operating

power reactor facilities and asked whether a citation could

be issued for failure to comply with any or all of the

criteria for certifying an individual as qualified in

radiation protection procedures.

The criteria for "Individuals Qualified in Radiation

Protection Procedures" are as follows:

1. Conduct special and routine radiation,

contamination and airborne radioactivity surveys and

evaluate the results.

2. Establish protective barriers and post appropriate

radiological signs.

3. Establish means of limiting exposure rates and

accumulated radiation doses, including the use of

protective clothing and respiratory protection equipment.

4. Perform operability checks of radiation monitors

and survey meters.

5. Recommend appropriate immediate actions in the

event of a radiological problem and perform necessary

activities until the arrival of health physics personnel.

6. Conduct other routine radiological duties (e.g., TS

surveillance items) as may be required on backshifts or

weekends.

NRR stated that the "Criteria" are to be used as part of

the determination of compliance with the Technical

Specifications requiring "at least one member of each

operating shift crew be qualified to implement radiation

protection procedures." Therefore, any citation must be

against the Technical Specifications and not the list of

criteria. However, the list of criteria may be referenced

to detail the basis for the citation.

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

1.8, Technical Specifications

Subject codes: 1.1, 12.7

Applicability: Reactors

Page Last Reviewed/Updated Thursday, March 29, 2012