ML20036C108
| ML20036C108 | |
| Person / Time | |
|---|---|
| Issue date: | 08/01/1991 |
| From: | Glenn J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Ronald Bellamy NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20036C106 | List: |
| References | |
| HPPOS-276, NUDOCS 9306140078 | |
| Download: ML20036C108 (4) | |
Text
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o AD9 91 1991 MEMORANDUM FOR:
Ronald R. Bellamy, Chief Nuclear Materials Safety Branch Division of Radiation Safety and Safeguards, RI FROM:
John E. Glenn, Chief Medical, Academic, and Commercial Use Safety Branch Division of Industrial and Medical Nuclear Safety, NMSS
SUBJECT:
TECHNICAL ASSISTANCE REQUEST:
CONTINENTAL AIRLINES This refers to your technical assistance request (TAR) dated April 2,1991, concerning Continental Airlines' industrial radiography license. application.
In its application, Continental has proposed to designate individuals as radiographers who have completed only 360 hours0.00417 days <br />0.1 hours <br />5.952381e-4 weeks <br />1.3698e-4 months <br /> of on-the-job training (0JT) verses the 520 hours0.00602 days <br />0.144 hours <br />8.597884e-4 weeks <br />1.9786e-4 months <br /> normally expected of NRC licensees.
To support its position, Continental maintains that because it will use only one type of radiography device and because of the repetitive nature of its radiography operations, 360 hours0.00417 days <br />0.1 hours <br />5.952381e-4 weeks <br />1.3698e-4 months <br /> would be sufficient _to qualify an individual.
Continental also points out that 45 days (or 360 hours0.00417 days <br />0.1 hours <br />5.952381e-4 weeks <br />1.3698e-4 months <br />) is the amount of OJT
" agreed" to with the State of Texas under Continental's Texas license (in fact, Texas' regulations specifically require two months 0JT), and that Continental is also conducting similar radiography operations under California and Colorado licenses in those states.
We understand that Colorado's regulations currently impose a one month period for OJT which is based on a recent revision of the Conference of Radiation Control Program Director's " Suggested State Regulations." The State of California has informed us that they require Continental to provide for 520 hours0.00602 days <br />0.144 hours <br />8.597884e-4 weeks <br />1.9786e-4 months <br /> OJT.
NRC guidance in this area is that 520 hours0.00602 days <br />0.144 hours <br />8.597884e-4 weeks <br />1.9786e-4 months <br /> are normally required to qualify an individual as a radiographer. We do not believe that it is appropriate to waive this " requirement" based only on current job restrictions.
Therefore, we recomend that you inform Continental that the burden is on the applicant to demonstrate that 360 hours0.00417 days <br />0.1 hours <br />5.952381e-4 weeks <br />1.3698e-4 months <br /> will be adequate to fully qualify an individual as a radiographer.
Factors such as hardship (where an individual is only infrequently involved in radiographic operations and to obtain the 520 hours0.00602 days <br />0.144 hours <br />8.597884e-4 weeks <br />1.9786e-4 months <br /> will entail a time period significantly greater than three months),
number of procedures, and quality of supervision and testing should all be considered by the applicant.
l 9306140078 910801 7
PDR ORG NRRB
Mr. Ronald R. Bellamy MG0 t 1991 be granted, about 360 hours0.00417 days <br />0.1 hours <br />5.952381e-4 weeks <br />1.3698e-4 months <br /> not providing an in cant's request operational experience should Continental modify its operations sufficient individual left Continental and was authorized to con
, or if the operations for another licensee.
will prepare an individual for any and all non-destructivWe should situations or i
we have to assume that our radiograoperations the individual will enco are properly prepared technically, phy licensees will ensure that their emp
- Instead, Just for good business reasons, you would think that a company would want ensure that the individ job understand how to conduct that job to produce adequateuals it view of 0JT should not be related to conducting a specific typ radiographs.
NRC's technical aspects of non-destructive testing.
e of job or the the period of time NRC believes it takes for an individInstead, it should familiar and comfortable with the radiation safety portiual to become on of his/her duties.
If you have any questions, please contact me at FTS:
at FTS: 492-0634.
492-0645 or Bruce Carrico kW alan *4 Drs John E. Glenn, Chief Medical, Academic, and Comercial Use Safety Branch Division of Industrial and Medical Nuclear Safety, NMSS DISTRIBUTION Wegion IMAB-432 JEGlenn NRC File Center IMNS Central File RECunningham TAR r/f WECline, RII PCVacca JGreeves MShanbacky, RI JGrobe, RIII JBCarrico CHosey, RII JKinneman, RI RJPate, RV SLBaggett, IMAB GMMcCann, RIII PSwetland, RI EMcAlpine, RII MLamastra BRiedlin WFisher, RIY ABBeach, RIV RFonner,ger, RV OGC LWCamper, IMAB JRicci, AE0D/TTC VLMiller, GPA/SP LFranklin, RII IMAB r/f CCain, RIV JJohansen, RI JPiccone, IMAB NMSS r/f PRathbun 07/ /91 OFC: IMAB, r
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- IMAB B
NAME:JBCarrico:jbc :MLarrastra
>enn DATEhk)Yh9k f'f9i f)f91 6FFICIAL RECORD COPY IMAB432
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REQUEST FOR TECHNICAL ASSISTANCE
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/
OATE:
04/02/91 TO: John E. Glenn Chief, Medical, Academic, and Commercial Use Safety Branch, NM55 FROM:
orn,3s nellamu Chief, Nuclear Materials Safety and Safeguarcs Branch, Region v
LICENSEE:
enntinontal Airlines LICENSE NO.
flew Applicant Control No.
(enclosed) 01/11/91 and Letter dated 03/19/91 (enclosed) y Suggested change in licensing procedure (enclosed)
Other (see remarks)
Problem / Issue:
Please see attached.
Action Required: Please see attached.
Alternatives Considered:
n /a Recommended Alternative:
N/A i
Remarks:
Pipate see attached.
legional Reviewer: ft Tavlor deviewer Code:
v.7 Reviewer Phone No.: 346-5311 REV. 8/90
F proolem/ Issue: Licensee recuests that an Assistant Radiographer in training to Oe a radiographer be recuired to only have 360 hours0.00417 days <br />0.1 hours <br />5.952381e-4 weeks <br />1.3698e-4 months <br /> on-the-job instead of the recemmended 520 hours0.00602 days <br />0.144 hours <br />8.597884e-4 weeks <br />1.9786e-4 months <br />.
The licensee bases their recuest on the fact that they will be using only one type of radiography exposure device and performing one type of exposure.
Action Required:
To review licensee's recuest and verify the Region's position to recuire the recommended 520 hours0.00602 days <br />0.144 hours <br />8.597884e-4 weeks <br />1.9786e-4 months <br /> of on-the-job training for assistant radiographers to become radiographers.
Remarks:
The region believes that accepting the licensee's proposal will have far reaching effects.
1.
A radiographer trained under this criteria who leaves the company to go to another radiography company may not possess the same level of training as the radiograohers emoloyed at the new company.
Under current guidelines the licensee is only recuired to provide a small amount of license-specific training for individuals already designated as radiographers.
This raises the issue of allowing inconsistencies in the training programs for these licenses.
A decision will need to be made as to what will be the acceotable minimum amount of training and how to control the transferability of such limited scope training programs.
In addition, ASNT requires 520 hours0.00602 days <br />0.144 hours <br />8.597884e-4 weeks <br />1.9786e-4 months <br /> of on-the-job training for radiographer certification.
Limited scope training programs would further complicate the implementation of rulemaking to require ASNT certification.
2.
Unless a specialized, limited scope license is issued, the NRC will have little control over the type of radiography exposuras the licensee performs.
NRC has generally been making an effort to standardize license conditions rather than making them more license specific.
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