What do these changes mean for Agreement State Programs?
Acceptable Training Program? IMC 1248 or SP (NRC/OAS Training Working Group Recommendations for Agreement State Training Programs) IMC 1248 or SP (NRC/OAS Training Working Group Recommendations for Agreement State Training Programs) IMPEP Procedures – SA103 “Technical Staffing and Training” IMPEP Procedures – SA103 “Technical Staffing and Training”
Documented Training Program Statement of Policy Statement of Policy Sample found in Appendix A of OAS training recommendations Sample found in Appendix A of OAS training recommendations Minimum Qualifications for staff training Minimum Qualifications for staff training Core, Specialized, Refresher Core, Specialized, Refresher Supervisory responsibility of ensuring policy is implemented – support of management Supervisory responsibility of ensuring policy is implemented – support of management
Minimum Training Categories Core training (all technical staff) Core training (all technical staff) Basic Health Physics Basic Health Physics Program Orientation Program Orientation State Regulations State Regulations Regulatory Guides, procedures, other Regulatory Guides, procedures, other Specialized training (according to your job) Specialized training (according to your job) Refresher/Continuing Education training Refresher/Continuing Education training
Basic Health Physics Radiation & radioactivity Radiation & radioactivity Biological effects Biological effects Types and uses of radiation sources Types and uses of radiation sources Instrumentation (survey, lab) Instrumentation (survey, lab) Surveys and monitoring Surveys and monitoring Personnel Monitoring Personnel Monitoring
Specialized Training Position Description Driven Position Description Driven Specific training in assignment area Specific training in assignment area Medical Use Medical Use Gauges Gauges Industrial Radiography Industrial Radiography Well Logging Well Logging Flexibility based on needs and staffing of state program Flexibility based on needs and staffing of state program
Refresher Training Peer or Cross Training – mentoring for new employees or just awareness Peer or Cross Training – mentoring for new employees or just awareness Manufacturer Training Manufacturer Training New devices New devices New methodologies New methodologies Professional meetings/journals Professional meetings/journals NRC courses – Special Topics NRC courses – Special Topics
NRC Training vs In-house Developed Costs Costs Availability Availability Travel Travel Time away from office/home Time away from office/home State imposed travel restrictions State imposed travel restrictions State specific needs and regulations, procedures & policies State specific needs and regulations, procedures & policies
Components of Florida’s Training Program NRC course attendance (when available) NRC course attendance (when available) In-house training modules developed In-house training modules developed Self-study reading material & powerpoint Self-study reading material & powerpoint Licensee observation Licensee observation Inspector or evaluator accompaniments Inspector or evaluator accompaniments Exam and/or supervisory audit Exam and/or supervisory audit Peer reviews Peer reviews
Example of State Developed Training
Documentation Qualification Journal Qualification Journal Supervisory Audits Supervisory Audits Certificates of completion Certificates of completion Job specific documentation Job specific documentation
SECTION B.1: Radioactive Material Inspection Training & Development Portable Gauges [3L(I) – P] Completion DateManager Review Complete “Portable Gauge Development Manual for BRC Inspectors” Accompany or participate in inspection Act as lead inspector during accompaniment Satisfactory audit by manager(1) Certified to BRC standards Medical Institution (5B) Completion DateManager Review Complete Diagnostic Nuclear Medicine and Radiopharmaceutical Therapy modules Review inspection history & procedures Accompany or participate in inspection Act as lead inspector during accompaniment Satisfactory audit by manager(1) Certified to BRC standards
Security Focus Heightened Awareness and Focus on Security Issues Heightened Awareness and Focus on Security Issues Pre-licensing or license delivery - opportunity to address security systems Pre-licensing or license delivery - opportunity to address security systems NRC “Increased Controls” course NRC “Increased Controls” course Additional security issues depending on type/category and use of material Additional security issues depending on type/category and use of material
Pre-license Visit 2.0SECURITY RELATED INFORMATION 2.0SECURITY RELATED INFORMATION 2.1Verify that the applicant’s proposed radioactive materials license name matches their business license. However, note that in some counties the regulating agency may require that the RML be obtained prior to issuance of the business license. 2.1Verify that the applicant’s proposed radioactive materials license name matches their business license. However, note that in some counties the regulating agency may require that the RML be obtained prior to issuance of the business license. 2.2A member of management or their designee must be present and the RSO’s presence is strongly encouraged. Request identification (driver’s license, picture I.D., green card, etc.) of applicant personnel present at pre- license visit. Verify their identity by name and picture/photo. 2.2A member of management or their designee must be present and the RSO’s presence is strongly encouraged. Request identification (driver’s license, picture I.D., green card, etc.) of applicant personnel present at pre- license visit. Verify their identity by name and picture/photo. 2.3Determine whether any of the applicant’s personnel have professional licenses or certifications. If so, verify that the names on these professional licenses or certifications match the names of individuals present at pre-license visit. 2.3Determine whether any of the applicant’s personnel have professional licenses or certifications. If so, verify that the names on these professional licenses or certifications match the names of individuals present at pre-license visit. 2.4Observe RAM storage areas. Ensure RAM storage areas are adequate to secure RAM from unauthorized access. 2.4Observe RAM storage areas. Ensure RAM storage areas are adequate to secure RAM from unauthorized access.
Summary NRC gives you guidance NRC gives you guidance Tailor it to the needs of your state – ensure flexibility Tailor it to the needs of your state – ensure flexibility Establish written training program Establish written training program Training policy statement (see example in Appendix A of OAS Document) Training policy statement (see example in Appendix A of OAS Document) Minimum Qualifications for staff training Minimum Qualifications for staff training Supervisory Responsibility Supervisory Responsibility Focus on Security Focus on Security
Applied Rad. Physics Course –Alpha Class Survey Technique Lab He’ll never find it… It’s in my pocket!
The UnKnown Physicist