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
