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