U.S. Nuclear Regulatory Commission

Applicability of Generic Letter 82-12 to Radiation Protection Staff

HPPOS-173 PDR-9111210261

Title: 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:

1. 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.

2. 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

Applicability: Reactors