United States Nuclear Regulatory Commission - Protecting People and the Environment

U.S. Nuclear Regulatory Commission

Qualification Requirements of Line Health Physics Supervisors

HPPOS-172 PDR-9111210259

Title: Qualification Requirements of Line Health Physics

Supervisors

See the memorandum from L. J. Cunningham to R. R. Bellamy

dated March 14, 1988, and the incoming request from R. R.

Bellamy dated March 2, 1988. A line Health Physics (HP)

supervisor according to ANSI N18.1-1971 must have four

years of craft or discipline experience. A line supervisor

with first line foremen / supervisors reporting to him and

having broad scope responsibilities falls under Section

4.3.2.

On November 30, 1987, Region I issued a licensee a Notice

of Violation (NOV) for assigning an individual to the

position of Radiological Operations Supervisor who did not

meet applicable TS qualification requirements for

supervisors. The individual possessed only eight months of

the required four years of directly applicable radiological

controls experience. The licensee responded to the

violation in a January 8, 1988 letter. The violation and

licensee responses are included as Attachment 1 and

Attachment 2 of this memorandum and provide other pertinent

information including applicable Technical Specifications

(TS), Radiation Protection Organization charts, and

applicable FSAR sections.

In his response, the licensee contended that the individual

assigned to this position need not be qualified as a

"supervisor" as defined in Section 4.3.2 of ANSI

N18.1-1971, and therefore, need not possess four years of

experience "in the craft or discipline he supervises" as

specified in Section 4.3.2. The licensee believed it

appropriate to qualify this individual as a "technical

manager" as defined in Section 4.2.4 of ANSI N18.1-1971.

Section 4.2.4 specifies that an individual should possess a

minimum of eight years in responsible positions of which

one year of this experience shall be nuclear power

experience. This section does not specify any experience

requirement in a particular craft or discipline.

The Radiological Operations Supervisor has program

responsibilities for infield radiological controls, ALARA,

and radwaste shipping. Because of the scope of

responsibilities of this individual, and the impact his

direction has on the health and safety of personnel, NRC

believes it appropriate that this individual be qualified

with the four year experience provision of Section 4.3.2 of

ANSI N18.1-1971. The licensee elected not to place an

individual in this position who was qualified to Section

4.3.2.

NRR believes an HP line supervisor should meet the Section

4.3.2 supervisor's experience requirement. Specifically,

in this case, the Radiological Operations Supervisor (ROS)

had two HP foremen and one HP reporting to him, and he was

also directly responsible for the infield implementation of

the site radwaste, classical HP job coverage / RWP program,

ALARA program, and job scheduling. Given this broad

spectrum and scope of operating activities and their direct

worker safety implications, the ROS (a line supervisor with

first line foreman / supervisors reporting to him)

unquestionably fell under Section 4.3.2. The ROS, thereby,

needs to have four years of "craft or discipline"

experience to be in full compliance with Technical

Specifications 6.3.

A word of caution is needed in the generic application of

this guidance. With the expansion of the HP staff in the

post-TMI period, many HP organizations have added staff HP

specialists who are assigned narrow, specific areas of

responsibility. For example, individuals may be assigned

as Respiratory Supervisor, Dosimetry Supervisor, etc. NRR

does not believe individuals filling these types of narrow

specialty positions with small support staffs should be

expected to meet the requirements specified for Section

4.3.2 supervisors.

NRR believes that the stated guidance is generally

consistent with past HQ and Regional actions in the plant

staff qualification area.

Regulatory references: ANSI N18.1-1971, Technical

Specifications

Subject codes: 1.1, 1.4, 1.5

Applicability: Reactors

Page Last Reviewed/Updated Thursday, March 29, 2012