Applicability of Generic Letter 82-12 to Radiation Protection Staff

HPPOS-173 PDR-9111210261

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