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HPPOS-276 PDR-9306140075

Technical Assistance Request, Continental Airlines, On-the-Job Training of Radiographers

See the memorandum from J. E. Glenn to R. R. Bellamy dated August 1, 1991 in response to a TAR from Region I. Continental Airlines proposed to designate individuals as radiographers who had completed only 360 hours of on-the-job training (OJT) verses the 520 hours normally expected of NRC licensees.

Continental maintained that because it would use only one type of radiography device and because of the repetitive nature of its radiography operations, 360 hours would be sufficient to qualify an individual. Continental also pointed out that only 45 days (or 360 hours) was the amount of OJT “agreed to with the state of Texas under Continental’s Texas license (in fact, Texas’ regulations specifically require two months OJT), and that Continental was also conducting similar radiography operations under California and Colorado licenses in those states. Colorado’s regulations imposed a one month period for OJT that was based on a revision of the Conference of Radiation Control Program Director’s “Suggested State Regulations.” The State of California as determined by NRC required Continental to provide for 520 hours OJT.

The NRC normally requires 520 hours to qualify an individual as a radiographer and felt it inappropriate to waive this “requirement” based only on current job restrictions. Therefore, the burden is on Continental Airlines (the applicant) to show that 360 hours will be adequate to fully qualify an individual as radiographer. Factors such as hardship (where an individual is only infrequently involved in radiographic operations and to obtain the 520 hours will entail a period significantly greater than three months), number of procedures, and the quality of supervision and testing should be considered by the applicant.

Regulatory references: 10 CFR 34.11, 10 CFR 34.31

Subject codes: 1.2, 11.1, 11.3

Applicability: Byproduct Materials