Question for DOE facilities

[Keith Welch <welch@CEBAF.GOV>]

This is a training-related question for DOE sites.  If you are not
intimately familiar with your site's (radworker) training policies, please
pass on the request to your training expert(s).  I'll post a summary of the
responses.

Here's some background:

I'm fleshing out our policy regarding acceptance of training qualifications
from other DOE facilities with the goal of establishing a written policy
statement contained in our radiation safety training manual.

I am periodically asked by members of our user community why we don't accept
another lab's training in place of our own, and from time to time we are
requested to send evidence of completion of radworker training to another
facility, for purposes of updating an individual's qualification based on
the training here.  It is apparent that some facilities will take credit for
another facility's training.  Our interpretation of 10CFR835 is that we can
only give credit on  "generic" material and must provide training on site
specific information.  Our training material is now 'segregated' into
generic and site specific topics.  We found it unwieldy to conduct "site
specifics" training, per se' so we have adopted a standard session which
allows people to do self study - thereby skipping over generic items if they
wish - then take a written test and perform a basic practical factors
exercise.  This method may be used for retraining or any "transfers" of
training.  In our view, the practical has to be considered part of site
specifics because it involves the facility's use of RWP's, specific work
practices, specific radiological conditions related to the facility, and
site specific examples of postings.  For us, the bottom line is this: Since
every DOE facility is not conforming lock, stock and barrel to the Radcon
manual, one cannot assume that all facilities use the same procedures,
policies, postings or definitions regarding radworder training.  Therefore,
the only thing one can consider generic is radiological fundamentals.  

If you're wondering "how different can it be?", here are a few examples of
site specific practices that are in full compliance with 10CFR835, but may
vary considerably from your site.  At our facility, we train most people to
a level we call Radworker I.  These workers can access areas up to and
including High Radiation Areas, and some Airborne Radioactivity Areas.  If
you go strictly by the RCM, only RW-II workers can enter these areas.  We
use something called a Radiologically Controlled Area (RCA) to define areas
where dosimetry and radworker training are required for unescorted access
(Not the same as a "Controlled Area" as defined in the reg).  The posting
and definition are probably somewhat unique to our site.  This area is
somewhat analogous to a RBA, but we don't routinely post RBA's.  The only
time we would use the RBA is to put a buffer around a contamination area
(and the whole shootin' match would be inside an RCA).  And the list goes on.  

Now for the questions:

1.  What type of facility are you?

2.  Does your site accept training qualifications from other sites in place
of your own qualification?

2a.     Is this a full or partial qualification?
2b.     Is it accross the board, or case basis?

3.  If you accept full qualification, how do you reconcile this with 835.902.

4.  If it is a partial qualification, do you have a "site-specifics"
training class to cover the rest, or do you make other allowances in the
process to make the training more streamlined?

5.  Have you identified - by objective, or topical area - what is considered
site specific and generic?  If so, is it explicitly identified either in the
context of the training or in a training management document?

6.  Has your policy (either to ignore other training, or to take whatever
level of credit) been specifically documented in your site's radcon manual
or other guidance documents? 

7.  What level of outside scrutiny has your policy been exposed to?  Have
you had to modify your policy based on audit findings or other review?

8.  Have you examined any other facility's training materials for
consistency with your own in an effort to develop an "equivalency agreement"
between sites that share many of the same users.
 

Please feel free to add any related information if it's pertinent to the
subject.  Thanks in advance for the help on this.
Keith Welch
Thomas Jefferson National Accelerator Facility
Newport News VA
welch@cebaf.gov