Should documents related to training and qualification of personnel, including procedures and instructions, be included in the LSN?
A. Some training-related documents are required but many should be excluded from the LSN pursuant to the general exclusion criteria contained in 10 CFR 2.1005. Examples of excludable documents include those related to general employee training, and training in specific topical areas such as diversity, ethical standards-of-behavior, management techniques, information technology, and general and technical education. However, you should include personnel training and qualification records related to programs or processes determined to be important to safety or waste isolation. 10 CFR 63 Subpart H requires that operation of repository systems and components important to safety must be performed only by trained and certified personnel under the direct visual supervision of an individual with training and certification in the same operation. More broadly, DOE must establish a program for training, proficiency testing, certification, and requalification of operating and supervisory personnel.
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