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
