ML20244B150
| ML20244B150 | |
| Person / Time | |
|---|---|
| Issue date: | 08/26/1980 |
| From: | Morrison W NRC OFFICE OF STANDARDS DEVELOPMENT |
| To: | Bryan Leonard ACADEMY OF IRM (FORMERLY INSTITUTE FOR RESOURCE MANAG |
| References | |
| RTR-REGGD-01.008, RTR-REGGD-1.008, TASK-OS, TASK-RS-807-5 NUDOCS 8009250277 | |
| Download: ML20244B150 (2) | |
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- 26 500 Dr. Bobby E. Leonard, president Institute for Resource Management, Inc.
428 Fourth Street, Eastport Annapolis, Maryland 21403
Dear Dr. Leonard:
Your letter of June 12, 1980 to Mr. Richardson of the NRC staff requested a clarifi-cation of the experience requirements for qualification of individuals in accordance with the guidance in Regulatory Guide 1.8, " Personnel Selection and Training." You specifically requested information on calculation of manhours credit for application to years of experience with regard to health physics or radiation protection tech-i ni cians.
The NRC staff recognizes that contractor health physics technicians are utilized at many of the power reactor facilities and that considerable overtime is frequently assoi:iated with this work. In consideration of this situation, members of the staffs of the Office of Nuclear Reactor Regulation and the Office of Inspection and Enforce-ment developed guidance for the application of manhours to years of experience for use only in determining the qualification of contractor health physics technicians.
This guidance recommends that 2,000 or more working hours accumulated during a total period of not less than 40 weeks be acceptable as representing one year of experience.
The further breakdown to hours per week is not discussed nor is it appropriate to .
evaluate work on a week-by-week btsis. I'm not aware of any other guidance of this type that has been established for determining the qualifications of any other members ,
j of the plant staff.
The type of work performed by individuals is very important in determining whether f credit should be allowed towards meeting requirements for years of experience. l j
Obviously, if work experience is solely in a job of very limited scope, then it would not be acceptable for meeting the years of experience requirement. Further-more, work experience is only one of several criteria which must be met for qualifi-cation. Experience, education, training and demonstrated proficiency are all re-quirements for qualification.
Your letter also points out that the NRC Office of Inspection and Enforcement has l recently issued Circular 80-02 which provides for limitations on workinD hours of {
i 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> per week. The guidelines of Circular 80-02 are included to establish maximum allowable limits on working hours and that actual working hours under normal con .tions are expected to be less and not be continuously extended to the maximum allowable. This guidance is for an entirely different purpose than that r discussed above and as such is not contradictory.
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An opportunity for public input on this question will be afforded in the near future when Regulatory Guide 1.S is issued for public comment, at r$ich time the MRC will review comments received and changes in the guide may be made in this regard.
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W. M. Morrison, Assistant Director for General Engineering Standards Division of Engineering Standards Office of Standards Development
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