See the memorandum from L. J. Cunningham to E. Greenman dated August 5, 1982. Technician experience is not equivalent to professional experience when evaluating the qualifications of a Radiation Protection Manager (RPM).
The RPM experience factors mentioned in Regulatory Guide 1.8, Rev. 1, were reviewed by IE. A licensee proposed to allow a one-for-one substitution of an incumbent technician’s experience for the Regulatory Guide’s stated “… at least 5 years of professional experience ….”
Consistent with the position of NRR’s Radiological Assessment Branch, IE agreed that technician experience was not equivalent to professional experience. NRR also agreed that exceptions may be granted under certain circumstances but such cases must be examined on a case-by-case basis.
Regulatory references: Regulatory Guide 1.8, Technical Specifications
Subject codes: 1.1
Applicability: Reactors