Applicability of Generic Letter 82-12 to Radiation Protection Staff
See the memorandum from L. J. Cunningham to W. D. Shafer dated April 1, 1988.
Generic Letter 82-12 (overtime) applies to Radiation Protection personnel assigned to emergency response duties as part of their job description or assigned to perform safety-related work (e.g., maintenance and calibration of monitors, etc.) and does not apply to simple survey support. HPPOS-024 and HPPOS-253 contain related topics.
A licensee had interpreted Generic Letter 82-12 and the Technical Specifications reflecting Generic Letter 82-12 to be applicable to radiation protection / chemistry technicians who were performing "safety-related" functions. Their definition of "safety-related" was similar to that referenced in Generic Letter 83-14 for maintenance workers.
The licensee had concluded that only one radiation protection / chemistry technician per shift was needed to perform the sole identified safety-related function and therefore applied the overtime restrictions of Generic Letter 82-12 to only one designated radiation protection / chemistry technician per shift.
As stated in the Commission's "Policy on Factors Causing Fatigue of Operating Personnel at Nuclear Reactors" (see HPPOS-024), licensees must "establish controls to prevent situations where fatigue could reduce the ability of operating personnel to keep the reactor in a safe condition." Health physics (and chemistry) personnel can be called upon to perform "safety-related" functions during routine and emergency conditions. It is vital that when personnel are called upon to perform these tasks, they are capable of performing the tasks in a safe, competent manner.
The guidance of Generic Letter 82-12 applies to all health physics / chemistry personnel who meet the following criteria:
- Personnel who are assigned certain emergency response duties including assignment to in-plant rescue teams, environmental monitoring and dose calculations, or who handle, process or provide data and input to emergency response decision makers.
- Personnel who are assigned to perform, or who could reasonably be expected to perform, safety-related work related to normal plant operations. Such work includes maintenance and calibration of effluent monitors, area radiation monitors, engineered safety feature systems, or any that are "safety-related" as this term is defined in 10 CFR 50.49 (b) (1), which is the definition provided in Generic Letter 83-14 clarification of Generic Letter 82-12.
A broader interpretation of safety-related work for purposes of Generic Letter 82-12 can not be supported. It is the NRR position that performing radiological surveys in support of maintenance work on a safety system does not meet the intent of the Commission Policy statement. Providing adequate HP job coverage is an important worker safety issue; however, such coverage does not stand the test of Generic Letter 83-14's narrow definition of "safety-related."
Regulatory references: Technical Specifications
Subject codes: 1.4, 1.5, 12.19