United States Nuclear Regulatory Commission - Protecting People and the Environment

U.S. Nuclear Regulatory Commission

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

HPPOS-276 PDR-9306140075

Title: 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), amd 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


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

Page Last Reviewed/Updated Thursday, March 29, 2012