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:
Conduct special and routine radiation, contamination and airborne radioactivity surveys and evaluate the results.
Establish protective barriers and post appropriate radiological signs.
Establish means of limiting exposure rates and accumulated radiation doses, including the use of protective clothing and respiratory protection equipment.
Perform operability checks of radiation monitors and survey meters.
Recommend appropriate immediate actions in the event of a radiological problem and perform necessary activities until the arrival of health physics personnel.
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