ML20033C648
| ML20033C648 | |
| Person / Time | |
|---|---|
| Issue date: | 12/31/1980 |
| From: | NRC OFFICE OF INSPECTOR & AUDITOR (OIA) |
| To: | |
| Shared Package | |
| ML20033C638 | List: |
| References | |
| FOIA-81-338 NUDOCS 8112030548 | |
| Download: ML20033C648 (32) | |
Text
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Report to the Commission 1
Review of the Status of NRC's Training Program for Resident inspectors j
e U.S. Nuclear Regulatory Commission Office of inspector and Auditor December 1980 g %,,
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December 17, 1980 MEMORANDUM FOR:
Chairman Ahearne Commissioner Gilinsky Commissioner Hendrie Commissioner Bradford
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FROM:
Jcmes J. Cummings, Director p,,
g,'7 Office of Inspector and Auditor.
SUBJECT:
REVIEW 0F THE STATUS OF NRC'S TRAINING PRO AM FOR RESIDENT INSPECTORS This is the Office of Inspector and Auditor's (0IA) third report on the Nuclear Regulatory Commission's (NRC) resident inspection program for reactor sites.
Our previous reports dealt with the acceleration and overall implementation of the resident inspection program.
This report deals with the recruitment and training programs for resident inspectors, especially "new-hire" inspectors. We have described the training programs that are in place for. these individuals and the qualifications for newly hired resident inspectors. Our intent is to infonn the Commission concerning the NRC recruitment and training programs for resident inspectors, and to recommend actions we believe will enhance these efforts.
Our review was conducted during the period January through July 1980 at NRC Headquarters and Regions I, II, and III.
Discussions were held with regional directors, branch and section chiefs, and other Office of Inspection and Enforcement (IE) officials concerned with the hiring and training of resident inspectors.
We also reviewed documents and manuals at IE Headquarters and regional offices relating to the resident inspector -
training program. We did not attempt to evaluate the adequacy, quality, or the substance of the training courses being offered.
Inspector personnel files were reviewed to determine education levels and work experience.
SUMMARY
OF FINDINGS DIA found that NRC needs a more integrated training program designed for resident inspectors. While there is a training program in place for "new-hire" resident inspectors, more attention needs to be given to developing a uniform, comprehensive training program for resident inspectors.
Especially lacking is a training program to progress inspectors from the junior resident to the senior resident inspector level.
Contact:
H. Boulden, 0IA
[
R. Donovan, OIA 49-27051 i
i The Commission 2
IE requires all resident inspectors to complete the same core training courses administered _by IE Headquarters, which are required for region-based inspectors.
None of these courses have been designed specifically for resident inspectors.
Additional training provided at the regional level is non-unifonn and is not fomally structured to insure the achievement of the same minimunt level of training in all regions.
Also, a " qualified" resident inspector in one region may not necessarily be considered
" qualified" in another region because regional requirements differ.
Specifically, 0IA found that:
travel funds permitting, "new-hire" resident inspectors can be expected to complete a series of four IE Headquarters training courses during their first year of employment with the possible exception of the Simulator training course. The training courses required by IE Headquarters for "new-hire" resident inspectors are:
Course Title Length PWR or (BWR) Technology Course 4 weeks PWR or (BWR) Advanced Technology Course 9 days PWR or (BWR) Simulator Course 7 days Fundamentals of Inspection Course 5 days These courses provide a technical understanding of reactor design and system operation, but are not designed to make the "new-hire" a qualified resident inspector or to substitute for the "on-the-job
' training" (0JT) that the regions provide; more use should be made of credit by examination for the two reactor technology courses for "new-hire" inspectors to satisfy completion of the required IE Headquarters training courses.
This would help to reduce the demand for space in the training courses and also reduce the regional travel expenditures for attending IE training; NRC does not have a unifonn training program for training "new-hire" resident inspectors at the regional level; however, the
-regional offices have developed their own training manuals and ci $teria for certifying that "new-hires" have met all the requirements to become a qualified resident inspector. Different, but comparable, training programs in each region are such that a " qualified" resident inspector in one region may not necessarily be considered " qualified" in another region because of the different regional training require-ments.
We believe the resident training program should be an agency program that provides unifom training to all "new-hires";.
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Th2 Commission 3
NRC does not have a training progran designed for inspectors to progress from junior resident to the senior resident inspector level. While we recognize that all resident inspectors may not progress to the senior level, we believe that such advancement should be based on more than just time as a junior resident and should be part of an inspector's career development; and NRC has recruited and selected "new-hire" resident inspectors, who, for the most part, have had experience in the nuclear Navy and/or industry and have the technical education or experience which should enable them to become qualified resident inspectors. We believe the IE regional offices have done a reasonable job in obtaining new personnel in view of the competition for qualified and experienced engineers in the nuclear industry.
RECOMMENDATIONS The report makes three recommendations to resolve the problems noted in our review.
Specifically, 01A recommends that:
the IE Regional Directors require, when appropriate, that resident inspectors try to obtain credit by examination of IE Headquarters training courses (page 8 of the report);
the Director, IE, in cooperation with the regional offices, use the existing regional resident inspector training manuals to develop a single comprehensive manual for the resident inspector training program (page 14'of the report); and the Director, IE, develop a formal training program to train resident inspectors to become senior resident inspectors (page 16 of the rep' ort).
AGENCY COMMENTS In responding to our report, the Executive Director for Operations (EDO) generally agreed with our findings and recommendations.
His specific comments are included in the report following each of the recommendations.
The ED0's complete response is contained in Attachment III to the report.
Attachment:
Subject Report cc: W. Dircks, ED0 Heads of Offices Regional Directors 9
m
. Table of Contents i
TITLE PAGE INTRODUCTION 1
. SCOPE OF REVIEW l
BACKGROUND' 1
Career Management Branch 2
2-Training Requirements 3
FINDINGS IE HEACQUARTERS TRAINING COURSES 4
More Use Should Be Made of Credit by Examination 7
Savings of Travel Costs 7
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Conclus' ion 8
Recommendation.1 8
Agency Comment 8
REGIONAL LEVEL TRAINING PROGRAMS 8
Certification 9
Resident Inspector Training Manual 10 Inspector's Qualification Notebook 10 On-The-Job Training 11 Self-Study Quizzes 12 Regional Office Training Courses 13 Evaluation of Individual. Training 13 Conclusion 14
- Recommendation 2 14 Agency Comment 14 i
4
TABLE OF CONTENTS TITLE PAGE 9
TRAINING PROGRAM T0 PROGRESS TO SENIOR RESIDENT INSPECTOR IS NEEDED 14 Conclusion 16 Recommendation 3 16 Agency Comment 16
SUMMARY
.0F QUALIFICATIONS OF NEW-HIRE RESIDENT INSPECTORS 17-Nuclear Training and Experience 18 Conclusion 20 ATTACHMENT I Summary Checkoff List ATTACHMENT II Region-Based Training Topics ATTACHMENT III Memorandum from W. J. Dircks, EDO to James J. Cummings, dated 11/25/80 5
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INTRODUCTION This is 'the Office of Inspector and Auditor's (0IA) third report on the Nuclear Regulatory Commission's (NRC) resident inspection program for reactor sites.
Our previous reports dealt with the acceleration and overall implementation of the resident inspection program. This report deals with the training programs for resident inspectors, especially "new-hire" inspectors.
We have described the training programs that are in place for these individuals and the qualifications for newly hired resident inspectors.
Our intent is to inform the Commission concerning the NRC training programs for resident inspectors and to recommend actions we believe will enhance these efforts.
SCOPE OF REVIEW Our review was conducted during the period January through July 1980 at NRC Headquarters and Regions I, II, and III. Discussions were held with regional directors, branch and section chiefs, and other Office of Inspection and Enforcement (IE) officials concerned with the hiring and training of resident inspectors. We also reviewed documents and manuals at IE Headquarters and regional offices relating to the resident inspector training program. We did not attempt to ' evaluate the adequacy, quality, or the substance of the training courses being offered.
Inspector personnel files were reviewed to determine education levels and work experience.
BACKGROUND
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Since the deployment of the first resident inspectors to reactor sites in the summer of 1978, NRC's resident inspection program has expanded significantly.
Program implementation is continuing, with the objective of placing at least two resident inspectors at each operating reactor site as soon as practical, and also assigning resident inspectors at selected construction sites.
To accomplish this expanded goal, IE was granted an additional 98 new inspector positions for fiscal year (FY) 1980.
Recruitment of these new inspectors is substantially complete; however,some of the "new-hires" will not be coming on board until this year (FY1981).
Currently, "new-hires" are being assigned directly to the reactor sites.
This differs from the previous practice of hiring a new inspector into the regional office for a period of time before assignment to a reactor site. The increased hiring of new inspectors has created' the need for training a large number of people in a short time frame.
This task has fallen on both the Career Management Branch (CMB) in IE Headquarters and the five regional offices.
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2 Career Management Branch The CMB, a part of IE Headquarters, is responsible for providing technical training to IE personnel (and other NRC offices on a space-available basis). To date, IE is the only major NRC office to have its own internal training function. The CMB is a separate operation from the Management Development and Training Staff, under the Office of Administration, which provides training opportunities for the NRC as a whole.
The CMB, with a staff of 22 people, provides instruction concerning inspection-related activities (i.e., reactor operations, construction, health physics, and safeguards). The CMB staff of professional instructors teach courses in both ioiling water reactor (BWR) and pressurized water reactor (PWR) designs.
The CMB has recently moved its BWR and PWR Technology Training Sections to the new NRC Reactor Training Center in Chattanooga, Tennessee.
All training courses previously conducted at IE Headquarters will now be given in Chattanooga.
Training Requirements Training requirements for IE inspectors are outlined in IE Manual Chapter (MC) 0226. Appendix B of the chapter specifies the required training necessary for each inspection discipline.
The general training policy fomulated in MC 0226 is as follows:
The supplemental training specified in this Manual Chapter consists of those training activities identified as being necessary to assure inspectors:
1.
Know the IE Role and Mission, 2.
Understand the responsibilities and legal authority of an inspector, 3.
Are knowledgeable of inspection techniques and procedures and are capable of perfoming the inspection function, 4.
Have the type and level of technical knowledge needed to adequately perfom inspection activities, and 5.
Understand the inspection program.
MC 0226 requirements are important because inspection personnel must satisfy these training requirements in order to be considered qualified to perfom inspections. The IE Manual state's it is IE policy that:
In general, only those inspector personnel that have successfully completed the required supplemental training are to be' allowed to perfom inspections. However, when Regional management evaluates the background.and perfomance of an individual ' inspector and concludes that the inspector = has demonstrated his ability to perfom
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4 meaningful inspections, even though he has not completed the required supplemental training, the Regional Director, if he so documents his action, can authorize the individual to perfom inspections.
When this approach is used, the successful completion of the supplemental training is still required within the time limits specified in %
Appendix.
FINDINGS-In reviewing the training program for resident inspectors, OIA generally found the program to be somewhat unstructured and nonunifonn. Specifically we found that:
travel funds permitting, "new-hire" resident inspectors can be expected to complete a series of four IE Headquarters training courses during their first year of employment with the possible
. exception of the Simulator training course; the courses provid,e a technical understanding of reactor design and system operation, but are not designed to make the "new-hire" a qualified resident inspector or to substitute for the "on-the-job training" (0JT) that the regions provide; more use should be made of credit by. examination for the two reactor technology courses for "new-hire". inspectors to satisfy completion of the required IE Headquarters training courses.
This would help to reduce the demand for space in the training courses and also reduce tne regional travel expenditures for attending IE training; NRC does not havb a unifonn training program for training "new-s hire" resident inspectors at the regional level; however, the regional offices have developed their own training manuals and criteria for certifying that "new-hires" have met all the requirements to become a qualified resident inspector.
Different, but comparable, training programs in each region are such that a " qualified" resident inspector in one region may not necessarily be considered " qualified" in another region because of the different. regional training require-ments. We believe the resident training-program should be an agency ' program that provides uniform training to all "new-hires";
NRC does not have a specific training program designed for inspectors to progress from junior resident to the senior resident inspector level. While we recognize that all resident inspectors may not progress to the' senior level, we believe that such advancement should be based on more than just time as a junior resident and should-be part of an inspector's career development; and NRC has-recruited and selected "new-hire" resident inspectors, who, for the most part, have had experience in the nuclear Navy and/or
. industry and have the_ technical -education or experience which should enable them to become qualified resident inspectors. We' r
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4 believeL the IE. regional' offices have d'one 'a reasonable job.in obtaining new personnel in view of the competition for qualified.
and experienced engineers. in the nuclear industry.
I IE HEADQUARTERS TRAINING COURSES Our review disclosed that all "new-hire". resident inspectors will receiv'e a1 series:of four IE Headquarters training courses,-scheduled to be completed within their first year of hire.
These courses, delineated in IE MC 0226,~ are designed to provide the resident inspectors with a unifom base.of technical knowledge with which to perfom their onsite ins pection. activities.
. The training courses required by IE Headquarters for "new-hire" resident -
inspectors' are:
Course Title -
Length I'
PWR or (BWR) Technology Course 4 weeks PWR or (BWR) Advanced Technology Course 9 days PWR or. (BWR) Simulator Course 7 days Fundamentals of Inspection Course 5 days The Technology Course provides a general, overall knowledge of the various reactor systems and how they operate. The Advanced Technology Course builds upon prev.iously learned concepts and concentrates on reactor systems interrelationships, standard technical specifications, y
transient analysis, and facility computer operation. The Simulator Course provides the "new-hire" resident with an exposure to control. room -
instrumentation, evaluation of plant system alignments, emergency procedures',.
and surveillance procedures. The fourth course, Fundamentals of Inspection, provides the "new-hire" resident with basic background infomation-regarding the inspection function and the role of the NRC reactor inspector.
i Officials in CMB indicated that the technology courses are equivalent to
~
college-. evel-courses and are-designed to provide a technical understanding l
of the reactor, design and systems operation.
They stated.these-courses are not designed to make the "new-hirc" a qualified resident inspector
.or. to substitute for the "on-the-job training" (0JT) that the regional
-offices provide.
Regional officials we spoke with shared the same view, and the consensus was that the IE Headquarters training classes are beneficial, but do not:
train "new-hire" inspectors to be fully qualified resident inspectors.
5 Fr,r example, representative regional' comments.we-received were:
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-- ' 'For the academic type of course, we rely on IE Headquarters to -
provida that. That is what seven weeks of technology courses in
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Bethesda are for.
In reality, the only pure technical' training the inspectors receMie is at IE Headquarters.
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IE Headquarters training courses generally provide an adequate technical knowledge for the resident, but this has to be supplemented, e
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with resident onsite job experience.
Headouarters and regional training will get the "new-hire" inspector 'm to a functioning'
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junior resident level.
It was continually stressed in our discussions with IE officials that.a combination of both Headquarters and regional training was necessary to transform the "new-hire" into a functioning junior resident inspector.
The CMB has created a goal of getting the "new-hire" inspectors through the required IE Headquarters training courses within one year of hire.
To accomplish this goal, the following schedule of classes has been developed:
IE HEADQUARTERS TRAINING CLASSES FOR "NEW-HIRE" RESIDENT INSPECTORS Calendar Year 1980 Maximum Course Title-Dates Offered Class Size PWR Technology Course March; April; July; 18 people per class October BWR Technology Course March; April; September 18 people per class PWR Advanced Technology May; August; September; 12 people per class Course December BWR Advanced Technology May;' October; December 12 people per class Course PWR Simulator Course **
June *; July; September 6 people per class BWR Simulator Course **
June *; December
- 6 people per class Fundamentals of Inspection September; November No class size specified Course
- Note: Indicates two class sessions being held during the month.
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A CMB official' explained that their intentior. is-to have students progress from the Technology Course into the next scheduled Advanced Technology. Course and from there attend the next Simulator Course that is offered.
This~ official was confident that they would be able to meet s
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their goal of putting all the "new-hire" resident inspectors through
.th'ese courses by the.end of their first year with the NRC.
The officials indicated that with the current hiring freeze they do not anticipate a great influx of "new-hires" needing to be trained, thereby lightening o
the training load. CMB officials indicated that if a bottleneck occurs, it will probably be with the Simulator Courses.
This is because NRC-does not own its own reactor simulator, relying instead on the use of the TVA simulators located in Chattanooga, TN.
NRC's use of the simulators f
is dependent on the amount of _ time TVA makes available.
The current schedule c4lls for 2,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> of simulator time to be made available to
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the NRC this year.
As indicated by the above course schedule, class size decreases in each succeeding course level. The limited number of spaces available in the advanced courses also creates a bottleneck for the flow of inspectors.
Ct1B officials explained that because of the limited space.available for s'~
the Simulator Course, they have been decreasing the class size of the IE Technology Courses in order not to create a' large backlog of inspectors awaiting Simulator training.
We received differing opinions from regional officials regarding enrolling "new-hires" into Headquarters training cours.es.
One region indicated that there has been no trouble in enrolling "new-hire" inspectors and that they expected all their new inspectors currently on board to be i
through the required' training courses by July 1980.
However, other regions indicated that only some inspectors needing Headquarters training would be enrolled in all the required training courses because of a shortage of spaces available in training classes.
Another region indicated that they expected their "new-hire" inspectors would complete all their required training by March 1981, which appears to be just about within the one-year time frame.
Our examination of the IE training records maintained by CitB showed as of June 30, 1980, the following:
STATUS OF IE HQS.
REQUIRED TRAINING FOR RESIDENT INSPECTORS NUMBER OF RESIDENT INSPECTORS NUMBER OF IE H0S. TRAINING
-ENTERED ON DUTY:
COURSES COMPLETE 0*
TOTAL 4
3 2 1 0
.JAN. 1978 - DEC. 1979 25 19 2 4 JAN. 1980 - JUNE 1980 34 6 3 7 9 9
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- Refers to the courses discussed on.page 4s
We were infonned by regional officials that completion of the required four IE Headquarters training courses for the remaining six' inspectors i
who entered on duty prior to January 1980 had been scheduled for completion by September 30, 1980.
The CMB Chief IE, believes-that all required Headquarters training fo'r resident inspectors can be completed within 12 months of the date the individual' enters on duty.
More Use Should Be Made of Credit by Examination We were infonned that "new-hires" may bypass some of the required IE Headquarters training courser by successfully completing the written examinations for each of the technology courses.
However, the "new-1 hire" is still required to' attend and complete the Simulator and Fundamentals of Inspection Courses.
IE MC 0226 provides for inspectors being able to bypass required courses by examination:
It is not the intent of this program to require persons to participate in each of the defined supplemental training activities if they already possess the type and level of knowledge that can be acquired by completing the activity.
If employees, when hired, through previous work experience and training are deemed to possess the knowledge in question, they may successfully complete the standard examination (s) cove' ring the training activity and negate the regsirement to participate.
CMB officials explained that this involves taking an examination prepared by the CMB staff which 'wo'uld demonstrate knowledge obtained in the two Technology Courses. The Chief, CMB, indicated it is up to the regions to detennine which "new-hires" may have enough previous' experience and knowledge to bypass courses by examination.
A CMB official informed.us that credit by examination and/or experience has been used by four regions on at least 20 separate occasions.
During the period January through June 1980, three' regions took advantage of the credit by examination on four occasions.
Utilization of credit by examination for training courses would be helpful to the IE training; effort.
If "new-h e" inspectors can successfully complete the standard examination without attending the training courses, it would ease the workload,of the CMB in attempting to train all the "new-hire" inspectors.
It would also free-up needed class space for those inspectors awditing to' attend the course.
Savings of Travel Costs "
Another benefit of using -this ' procedure would be in the ' savings of per diem costs that are incurred to train the "new-hire" inspectors. When inspectors attend training courses at Chattanooga, they are allowed up to $35 per day in travel expenses.
For example, if an inspector did not have to attend the four-week Technology Course it would save the' NRC approximately $980* per inspector in per diem expenses (exclusive of any.
3
'zu cays x wb pe'r day = $980
8 transportationcosts).
If several inspectors could qualify to skip these courses, it would mean a considerable savings of travel funds.
Conclusion-Although some regional officials are not optimistic about the availability cf spaces in the IE Headquarters training courses to enable "new-hire" residents to complete all of the required courses within a year, we believe, with the exception of simulator courses, most "new-hires" will be able to complete all other courses within their first year of NRC employment. We also believe, that credit by examination should be used as much as possible to help in reducing the number of individuals enrolling in the training courses.
Recommendation 1 OIA recommends that, when appropriate, IE Regional Directors require resident inspectors to try to obtain credit by examination of IE Headquarters training courses.
If qualified "new-hires" can demonstr..:.e their knowledge without attending the required training courses, this wi'.1 lessen the training load and free-up nseded classroom space for other inspectors.
It will also provide a cost savings to the NRC in per diem expenses for those employees who need not be scnt to Chattanooga for training.
Agency Comment The EDO concurred in'our recommendation and specifically stated that:
The option for a "new-hire" to take a course examination in lieu of attending the full course, has been available since July 17, 1978, when IE Manual Chapter MC 0226, " Training and Orientation. Program,"
was issued for implementation. The decision on whether or not to take a course examination in lieu of attending.the course rests with the "neu-hire" inspector and his superviso,.
We support the
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advantages that this approach offers and intend to continue it.
REGIONAL LEVEL TRAINING PROGRAMS The second phase of training "new-hire" inspectors is provided at the regional office level. Our review disclosed that there is no uniform IE-training program to train "new-hire" inspectors at the regional level.
The regional offices have taken the initiative and developed their own training programs.
This has resulted in somewhat different, but comparable, training programs for "new-hires" in each region.
Although all regional offices have the same objective--to train "new-hires" to become resident inspectors--the methodology for accomplishing this is determined regionally, rather than on a ' programmatic. level (to provide uniformity and consistency).
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9 The regions hhve ' established criteria for certifying that a "new-hire _"
has saticfactorily completed all of his training requirements and has demonstrated that he has the knowledge and skills to be a qualified
-resident inspector.
In addition to IE Headquarters training courses, regional certification involves completion of the following:
Inspector's Qualification Notebook; On-the-Job training; Assist Inspection (0nsite and Offsite);
Self Study Quizzes; Regional Office Training Courses; and Progress Evaluations Certification Certification is the process by which the trainee is deemed to have met all of the prescribed training requirements and has demonstrated the knowledge an.d skills required of a resident inspector.
The period of time it takes to become certified varies depending on the individual's needs and capabilities and the availability of space in the IE technical training courses.
We have been infonned by regional officials that some trainees could be certified.within nine months of their employment if they were able to attend all the fonnal training courses in the proper sequence and without undue delays.
Regional officials believe that nearly all trainees should be ready for certification within a 12 to 18-month time period after they are hired.
However, we were informed that an inspector certified in one region may not necessarily be considered qualified in another' r'egion.
The procedures for obtaining certification varies somewhat from region to region.
In most cases, it is the Senior Resident Inspector (SRI) who initially detennines that an inspector trainee is ready and makes the recommendation for certification to the appropriate regional management official.
It ane region, certification is achieved by oral examination before a regional examining board, chaired by the branch chief.
According to these officials, the oral examination is comprehensive, and many of the questions are from the individual's " qualification notebook." The oral exam takes between three and four hours.
In another region, the recommendation for certification is made by the j
i section chief and the SRI.
An oral examination by a board of region-based inspectors and a section chief may be given as part of the evaluation l
process; however, the final determination for certification is made by l
the branch chief and regional director.
In the third region, the branch-chief is the management official who certifies that an inspector trainee is qualified to assume the duties and responsibilities of an NRC resident inspector.
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10 Resident Inspector Training Manual In order to achieve the tr.aining program objectives and to assure that each of the "new-hires" completes all the requirements necessary for
. certification, training manual / guides have been developed by each of the
. regional offices.
These manuals ~were developed to consolidate into one source all the certification requirements a "new-hire" must satisfactorily complete before becoming a qualified resident inspector. The essential parts of the manuals are a " qualification notebook," self-study quizzes on NRC rules and regulations, and requirements for on-the-job training.
Each major segment of the manual' has a checkoff list and signature block for the SRI to sign-off, attesting that the resident trainee completed the requirements for that section. A completed manual becomes the documented evidence that the "new-hire" has completed all the training requirements and is ready to be certified as a qualified resident inspector.
Attachment I is an example of a checkoff list which requires the SRI's-review and signature.
We were informed by one regional office that they developed the first draft of a training manual for resident inspectors and that it was sent to IE Headquarters and other regional' offices for review. However, the other regional offices developed their own version of a training manual instead of adopting the draft manual.
Our review of these manuals indicated that although there are similarities in the types of training, there are subtle differences in performing the training requirements for certification at each of the regions.
In addition, regional officials said it took considerable time and effort to develop their own manual.
Although the initiative of the regional offices is commendable, we believe IE Headquarters should have taken the lead and developed one uniform training manual to be used by all "new-hires" of the resident inspection program.
Inspector's Qualification Notebook This notebook is probably the most important record of the "new-hire's" training at the regional level.
It establishes the "new-hire's" 0JT program. The purpose of OJT is to provide the trainee with a thorough familiarization with the site-specific systems, procedures, and analyses.
This phase of the "new-hire's" training is coordinated and closely monitored by the senior resident inspector.
As noted above, each of the regions we visited have similarities in their training programs, but the format and substance of the " inspector's qualification notebook" is one area where va,riances exist.
Two regions have somewhat similar notebooks,
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11' while a third regions's notebook consists of eight comprehensive multipart questions that the "new-hire" must answer.
On-The-Job Tra'ning On-the-job training consists of:
(1) participation in inspections at the assigned site with regional personnel, (2) participation in inspections at other s_ites, and -(3) participation in inspection activities at the assigned site with the SRI.
Much of the DJT is an outgrowth of the
" inspector's qualification notebook" particularly as it relates to items such as the inspection program, facility procedures, : system walkdowns, and observatiens.
Assist Inspections Onsite - Each of the regional offices have a policy that inspector trainees will assist region-based specialists during their inspection-visits to their site.
It is expected that this effort will increase the trainee's knowledge of the assigned facility and of the inspection techniques of experienced inspectors.
It is also expected that the trainee will assist in several disciplines other than general plant operations and thereoy gain an appreciation for the various aspects of the IE inspection program.
Generally, the onsite. inspection assistance includes the areas of security, health [hysics, construction, quality assurance, core physics, as well as,.
attending. site entrance and exit interviews for the assist inspections the trainec participates in. As the trainee gains proficiency, he is assigned responsibility for the completion of inspection ' modules.
Assignment of the inspe: tion module is coordinated between the SRI and the visiting regional inspector.
There is no stated frequency for assisting region-based inspectors; however, regional management does expect the inspector trainee to participate as often as reasonably possible.
i Assist Inspections Offsite - As part of their traini,ng, "new-hires" are scheduled to participate in inspections at sites other than the one they are assigned to.
The purpose of this is to expose the trainee to other facilities and how they operate, and to other NRC inspectors and their inspection techniques.
Each of the regions we visited have established offsite inspections as one of the criteria for certification; however, the number and type of offsite inspections vary'among the regions.
'One region has an' unwritten policy that "new-hires" will participate in and accompany region-based ' inspectors for a one-week inspection every three months during their first year.
Although this is desirable, regional management recognizes that this is subject to the timing and availability of the inspectors and the 1.ndividual needs of the trainee.
Another region requires at least four assist inspections away from the home site during.the trainee's first year. The following criteria were -
-established in making offsite inspection assignments:
12 two inspections should be at a preoparational. site and two should.
be at an operating site; at least one ' inspection should be at an " identical" reactor site (same nuclear steam system supplier [NSSS]), if possible; at least one inspection should be at a boiling water reactor-(BWR)
(for a pressurized water reactor [PWR]-based resident trainee);
at least one inspection should be at a PWR (for a BWR-based resident trainee); and at least one inspection should involve the " Quarterly Review of Operations," Module 71710.
Another region requires that trainees participate in at least two offsite inspections during the first year. The regional policy is that the assist inspections should preferably be with the SRIs at plants of the same type and NSSS as the assigned site.
In addition, one of the inspections should be at a plant in a different stage--operation or construction--
than the assigned site.
Assist Senior Resident Inspector - Regional office management expects the trainee will receive a significant portion of his 0JT while accompanying the SRI on his daily activities.
This allows the SRI to directly observe the trainee's inspection technique as the trainee assumes responsibility for various inspection areas.
Some of the activities the trainee partic-ipatesin include:
conduct inspections with the SRI; attend licensee management meetings;.
verification of safety-related system lineups, observation of control room activity, observation of work on tests in progress, verification of technical specifications and procedures compliance; attend public hearings or meetings with the media; assist in inspection report processing and communications with the Regional Office; assist in the maintenance of computerized management infonnation
- systems, such as the' 0utstanding items File or Grey Book; and attend regional meetings of Resident Inspectors.
Self-Study Ouizzes
- The regional training programs include a voluminous series of self-study quizzes which are part of the resident inspector training manuals.
.These quizzes are designed to provide-infonnal instruction in several
~.j 13 areas particularly important to new NR'C employees.
The areas' include q
the Atomic Energy Act, Title 10 of the Code of Federal Regulations, the NRC Code of Conduct, and IE enforcement policy. The self-study activities are to be completed within the first two months of employment and are part of the "new-hire's" certification record.
A variance in -the self-study quizzes is that one region provides the material on the Code of-Conduct and IE enforcement policy in a region-
' based seminar rather than including it in their manual. Although the other regions cover about the same material, we believe the seminar method is probably a more effective method for teaching these subjects.
Regional Office Training Courses Each of the regional offices have established region-based training courses for."new-hires" to attend in the regional offices.
Attachment II is~ a partial listing of some of the topics covered in the region-based training programs for new resident inspectors.
The classes are usually for three to five days, and in some regions the training is provided in two sessions. The first session is given within the first three months of. employment.
The second session is given about six months later.
In addition, the regiona] offices also hold bimonthly training sessions for all resident inspectors, both seniors and "new-hires." These meetings serve a multiple purpose by providing the "new-hires" the opportunity to meet and exchange experiences with each other, as well as with the region-based inspectors,., The meetings also provide the "new-hires" with information on NRC, IE, and regional office policy and procedures concerning-the various activities of inspection and enforcement.
In comparing the topics covered in the region-based training with those in the " Fundamentals of Inspection" course at IE Headquarters, we found that there is some duplication.
However, we believe that some duplication is necessary to further expand on the details of certais topics.
In addition, the regions nay have differing regional policis and procedures on how to handle or respond to particular items which must be conveyed to new inspectors.
. Evaluation of Individual Training Resident inspector trainees are evaluated on their progress at three-month: intervals during their first year.
In two of the regions we visited, regional supervisors are responsible for performing the evaluations with the assistance of the SRI.
In another region the evaluation is
'done' by the SRI and 'is documented in a memo to regional management, usually the section chief. - Procedures in all regions require that unsatisfactory progress or performance by the trainee be corrected by remedial action and documented in the individual's training file.
Conclusion j
We believe the resident inspector training program should be an agency progra'n that provides unifonn training to all "new-hires." The programs in place have essentially been developed on a regional basis, although they are somewhat comparable.
'Each of the approaches used to guide the "new-hire" in learning the si_te
- sp'ecifics of his facility and infonning the "new-hire" how the NRC does
- its job in inspecting the facility have some merit.
However, 0IA believes there should be one standard trainlog program manual _ and one that adopts the best features of each of the regional programs.
Recommendation 2 IE Headquarters should assume responaibility for the resident inspection training program to ensure uniformity and consistency in the level and types of training that "new-hires" will receive in becoming qualified resident inspectors.
We recommend that the Director, IE, in cooperation with the regional offices, use the existing regional inspector training manuals to develop a single comprehensive training program and manual for resident inspectors.
Use of this training manual at the regional level should be mandatory.
IE's Career Management Branch should monitor resident inspectors' progress as an overview function.
Agency Comment The ED0 concurred in our recommendation and specifically stated that:
A task group will be established under our Training Branch to review the existing regional Training Manuals with the goal to develop a single comprehensive manual.
The task force will have a representa-tive from each regional office with the lead responsibility assigned to the Training Branch. The task force is to complete its effort by April 30, 1981.
TRAINING PROGRAM TO PROGRESS TO SENIOR RESIDENT INSPECTOR IS NEEDED NRC does not have a training program designed for inspectors to progress from junior resident to the senior resident inspector level. This same issue was addressed in 0IA's December 1979 report titled, " Review of the Continuing Implementation of NRC's Resident Inspection Program." While we do not infer that all resident inspectors will progress to the senior resident level, we do believe that advancement to the senior resident level should be part of an inspector's career development.
Appropriate training should assist resident inspectors who have an opportunity to i
i
. m m-m.
m
15 I
. advance in~ the IE management' organization.
Lack of a specific training program makes it difficult to determine whether an inspector has had all the training and experience or has the minimum qualifications necessary to be a senior resident-inspector. We do not believe that just a certain i
minimum period of-service as a junior resident necessarily qualifies a person to become a senior resident inspector.
Inspector training requirements are detailed in IE Manual Chapter 0226; Appendix B.
The MC indicates 'that after the initial training
-schedule is' completed, only refresher training is necessary.
The MC indicates that refresher training consists of either completing the BWR or PWR Refresher Courses.
The MC states:
d.
Refresher Training Inspectors are required to complete the first refresher training between 15 and 21 months after completion of their initial training and then every 15 to 21 months thereafter as long as they are assigned the above described inspection responsibilities.
This is the only training that-the IE Manual specifically delineates after the inspector has completed his/her initial training sequence (discussed in an earlier section).
However, the MC further states that resident inspectors assigned to PWR or BWR facilities are not required to attend the refresher training courses.
According to an IE official, resident inspectors are at the sites on a daily basis and are continuously monitoring -the licensee'.s activities, whereas region-based inspectors have less frequent contact and exposure to the operations at the sites.
The closest we came to finding an official training sequence was the initial policy regarding qualifications of senior resident inspectors.
The policy states that the senior resident:
must be at least at the GS-13 level; must have at least 18-24 months NRC experience; and must have at least six months experience as an NRC project inspector.
l We were not able to find any other additional training _ requirements to reach the senior resident inspector level.
hired directly to sites will not be able to obtain at least six months' experience as an NRC project inspector unless they perform the duties of the Senior Resident Inspector or are detailed to a project inspector position elsewhere.
e
- _ ~
16 Regional -officials we spoke with also indicated there is no specified training sequence for an-individual to progress from the junior resident to senior resident -level.
One regional official had the following comment concerning training for senior resident inspectors:
The seni' r. residents we currently have onsite have become o
qualified based on previous project inspector experience at the regional level.
There is a void in the training for senior residents as far as management and supervisory training are concerned, communication skills, etc. Also, there is no formal training between junior and senior resident inspector levels, other than that required by MC 0226.
Other canments we received included:
To progress from a junior to senior resident inspector I believe it takes a lot of OJT and working under.the direction of a good senior resident.
I would also like to see the,
junior resident get some management training, because upon becoming a senior resident inspector, he will_ supervise at least one junior inspector and a secretary.
With respect to training for senigr resident inspectors, each senior resident will receive some refresher training, but at this point I don't know how much that will be.
Conclusion While some thought has been given to the training of "new-hires," we found no action being taken with respect to the training to become a senior resident inspector. As the resident inspection program continues to expand, it would behoove _the NRC to have a formalized, specific training program for resident inspectors to progress from the junior resident to senior resident inspector level.
Recommendation 3 We recommend that the Director, IE, develop a formal program to train resident inspectors to become senior resident inspectors.
We believe the training program should take into account those skills and knowledge which are necessary for the senior resident inspector to perform his job.
. Agency Comment The ED0_ concurred in our recommendation and specifically stated that:
We consider career ladder development very important to the naintenance of a viable Resident Inspector Program.
The progression from the
_ position of Resident Inspector to Senior Resident inspector does not involve specific additional formal training, but rather 1
17 requires additional experience that can be obtained by on-the-job training as well as individual initiative.
Since there are no formal training requirements, we are stating the qualification requirements for the position of the Senior Resident Inspector in the IE Manual. By doing this, the Resident Inspector will be aware of those areas where special effort is required if he want to advance.
Position qualification requirements for Senior Resident Inspectors will be published in IE Manual Chapter MC 0227, " Inspector
-Qualification" by February 15, 1981.
SUMMARY
OF QUALIFICATIONS OF NEW-HIRE RESIDENT INSPECTORS In mid-1979, NRC initiated a mass recruitment progr' m to hire 98 new a
inspectors' to help support the resident inspection program.
To determine the type of individuals being hired, we reviewed the Standard Form 171 (SF 171) for 49 "new-hires" who had been selected and desi.gnated for.
particular sites as of April 30, 1980.
Some of the 49 "new-hires" who had accepted positions with the NRC had not yet reported for duty.
Table 1 shows the education level, nuclear Navy experience, and commercial nuclear industry experience, if any, for the 49 "new-hires":
TABLE 1
SUMMARY
OF "NEW-HIRE" INSPECTORS
'~
Total Number Hired M
College Education Engineering / Science 32 Other major 4
None 13?
r e
L 18 TABLE 1 (Continued)
SUMMARY
OF "NEW-HIRE"-INSPECTORS Total Nuclear Navy 12 Officer
- 18 Enlisted 19 None H
Commercial Nuclear Industry Nuclear Power Station 7
Naval Shipyards 16 Nuclear Related Contractors 10 2
Department of Energy 2
NRC Interns None 12_
$9
- Eight were graduated from the U.S. Naval Academy Nuclear Training and Experience Our analysis of the 49 "new-hires" showed that 30 of them had served in the nuclear Navy and had completed the Navy's nuclear power training Ten of the 49 were still on active duty at the time they courses.
applied for a position with the NRC.
Our analysis of the background experience of the other 39 "new-hires" who did not come to the NRC direct'iy from the nuclear Navy shows that:
seven had been employed at NRC-licensed nuclear power pla'nts and six of the seven had been licensed Senior Reactor Operators (SRO).
All seven individuals also had had nuclear Navy training and experience; sixteen were employed at the various naval shipyards on the east and west coasts.
Six were working as Shift Test Engineers and the others worked in associated areas such as. nuclear engineers, refueling engineers, and production control.
Fourteen had college degrees, of which eleven were in engineering.
Five of the sixteen have served in the U.S. Navy and had nuclear power training and experience; ten were employed by one of the various contractors in the nuclear industry, such as, Stone and Webster, General Electric Nuclear Energy Division, General Electric Knolls Atomic Power Laboratory, and Bechtel Power Corporation.
Nine had engineering degrees, and four had nuclear Navy training and experience; b
e
19
.two had worked for the Department of Energy (D0E) at one of DOE's
~
field facilities. One individual had nuclear Navy training and experience and the other had an' engineering degree; and of 'the remaining four "new-hires," two came from.the NRC intern program and the other two had been employed in non-nuclear related jobs. Three.had engineering degrees with two of the three having nuclear Navy training a'nd experience.
The one who had no degree did have nuclear Navy training and experience.
During the course of our review we found that one region had designated four *new-hires" as SRIs and that three of them would be assisted by three "new-hire" junior resident inspectors.
In discussing this with the Regional Director, we were informed that the "new-hire" SRIs would not be given' site responsibility until they had completed the required training and regional management had assured itself that the individuals could assume the duties and responsibilities of an SRI.
By memorandum
. dated March 6,1980, the Director, IE, informed all reg onal directors i
that he was re-emphasizing the requirement that:
I
...an inspector must possess a minimum of two years' experience in the NRC regulatory program before being relocated to a site as a senior resident inspector.
If there is a situation in which an inspector has achieved the required level of understanding in less than the two year standard, you may request an exception to this requirement.
In the interim, the regional management is assigning experienced region-based inspectors to the sites to assist the designated SRIs until such time as they can assume their duties independently.
Regional officials responsible for reviewing the qualifications of new applicants informed us that it is difficult for the NRC to compete for individuals having engineering degrees and several years' experience in the nuclear industry.-
Regional officials acknowledged that it would be desirable to hire individuals with these credentials, but in the absence of an engineering degree, the individual's experience in the nuclear industry is the most significant consideration for hiring an applicant.
In general, regional officials would rather hire an individual-with
" hands-on" experience and no college than an individual with an engineering degree and no~ experience.
Regional officials responsible for screening applications said the rate of applicants to qualified applicants 'was about five to one.
In addition, one region was particularly hard-pressed for qualified applicants because of their geographic location. We believe this is borne out in comparing the "new-hires" selected:
/
f
20 Total Region A 0ther Regions-
' Number Hired
-49 37%
63%
. College Education
-Engineering / Science
'32 -
28%
72%
Other Major 4
25%
75%
None 13 62%
38%
Nuclear Navy Officer 12 0%
100%
Enlisted 18 56%
44%
.None 19 42%
58%
OIA believes the above data indicates that employment with NRC in -this
- ographic ' area is not as attractive to applicants with the same education and nuclear experience as in other areas.
Employment with NRC may not be attractive to professional engineers in that geographic area, because NRC salaries, benefits, and career opportunities may not match those of the nuclear industry in that area.
Conclusion In view of the competition for qualified and experienced engineers in the nuclear industry; we believe the IE regional offices did a reasonable job in recruiting personnel for the resident inspection program.
6 e
APPENDIX D PART A.. SUM.AARY_ CHECK 0FF LIST This list is used to indicate completed portions of the Inspector Qualification Notebook.
While the signatures in Sections B-E of the Notebook are made by 4
the Trainee, the signatures in this section are to be made by the Senior Resident Inspector at the site or the Section Chief.
These signatures indicate a review of acceptable completed work and form the basis for part of the certification process.
INSTRUCTIONS (Part B)
Signature /Date 1.
The Inspection Progran 2.
Scheduling and Preparation of Inspections
/
3.
Scope of Inspections
/
4.
Entrance / Exit Interviews
/
5.
Conduct of Inspections / Accumulations of Data
/
6.
Post Inspection Activities of Inspectors
/
NONROUTINE INSPECTOR ACTIVITIES (Part C) 1.
Morning Reports
/
2.
Nonroutine Licensee Events
/
3.
Preliminary Notifications
/
Attachment I Page 1 of 3 o
'9 A.
SUMMARY
CHECK 0FF LIST Signature /Date 4.
Circulars / Bulletins /Information Notices
/
/
5.
Hearings 6.
Evaluation of Licensee Management Effectiveness
/
. 7.
Safety-Related. Matters Not Covered by Require-f ments or Commitments
_J
/
8.
Incident Response 9.
Allegations / Investigations
/
10.
Yellow Book / Grey Book
/.
11.
Independent Measurement Program
/
12.
Use of Consultants by NRC -
/
ONSITE NUCLEAR PLANT AND INSPECTION ORIENTATION (Part D) 1.
Assist Inspections
/
2.
Identification of Systems / Components
/
3.
Site Activities at Other Sites
/
\\
4.
Inspector Activities
/
5.
Observations of Site Activities
/
f t
l Attachment I f
Page 2 of 3 l
h
~~
A.
SUMMARY
CHECK 0FF LIST REACTOR PLANT (Part E)-
Signature /Date A
4 1.
Safety Analysis Reports / Standard Review Plan
~/
2.
Reactor Operating Organization / Safety Review
/
Committees
~
/
3.
Test Programs
/
4.
Structures, Containments, Etc.
/
S.
Reactor System 6.
Reactor Coolant System / Primary
/
Pressure Boundary 4
/
7.
Major Secondary Systems
/
4 8.
Engineered Safety Features
/
9.
Energency Power System 10.
Instrumentation and Controls
/
11.
Radioactive Waste Management System
/
/
12.
Site Emergencies s-I Attachment'I Page 3 of 3-1
i I
REGION-BASED TRAINING TOPICS The following subjects are examples of the ' topics covered by regional resident inspector training programs.
IE Enforcement
. t Inspection, Report Writing and Processing Bulletins, Circulars, and Notice System Allegations, Complaints, and Investigations Licensee Events Reports Emergency Preparedness Action Item Tracking Syster (AITS)
Daily Reports and Preliminary Notifications Review of Selected Regulatory Guides.
Application of 10 CFR 50 4
a 5
9 Attachment II
p gut en c ~ 'o UNITED STATES u
NUCLEAR REGULATORY COMMISSION
. [ j i,.
- ,E WASHINGTON, D. C. 20555 g{
N'
/
NOV 2 5 MO MEMORANDUM FOR:
James J. Cummings, Director Office of Inspector and Auditor FROM:
William.J. Dircks Executive Director for Operations
~
SUBJECT:
REVIEW 0F THE STATUS OF NRC'S TRAINING PROGRAM FOR RESIDENT INSPECTORS I agree generally with the recomendations of 01A's Draft Report, " Review of the Status of NRC's. Training Program for Resident Inspectors." My specific comments;on each of the three recommendations are as follows:
Recommendation #1:. Regional Directors require, when appropriate, that Resident Inspectors try to obtain credit by examina-tion of IE Headquarters training courses.
Concur:
The option for.a."new-hire" to take a course. examination.in lieu of attending the full course, has been available since July 17, 1978, when IE Manual Chapter MC 0226, " Training and Orientation Program," was issued for implementation. The decision on whether or not to take a course examination in lieu of attending.the course rests with.the."new-hire" inspector and his supervisor.
We support the advantages that this approach offers and intend to continue it.
Recommendation #2: The Director, IE, in cooperation with the regional offices, use the existing regional Resident Inspector Training Manuals to develop a single comprehensive.
manual for the Resident Inspector Training Program.
Concur:
A task group will be established under our Training Branch.to review the existing regional Training Manuals with the goal.to develop a l
single comprehensive manual.
The task force will.have a representa-I tive from each regional office.with the lead responsibility assigned to the Training Branch. The task force is to complete its efforts 1
by April 30, 1981.
l r
Attachment.III
,R
.=
q.
FH-P~
? James J.-Cummings, 01A -
-~ '
h2_.
g?[
t TheDirectr..IE,deYelopaformaltrainingprogramto-p-
~
o y~
Recommendation #3:
train Resident Inspectors to become Senior Resident.
Inspectors.
Concur:
Weconsidercareerladderdehelopmentveryi.mportanttothemaintenance of a viable Resident. Inspector Program.
tion of Resident Inspector to. Senior Resident Inspector.does not involve-4 specific additional formal. training, but rather requires additional experience that can.be obtained by on-the-job training as well as
=*
individual initiative.
we are stating the-qualification requirements for the position of the By doing this, the Resident Senior. Resident. Inspector in the IE Manual.
Inspector will be. aware of those areas where special effort is required Position qualification requirements for Senior if he wants to advance.
Residcnt Inspectors.will be published in IE Manual Chapter MC 0227
" Inspector Qualification".by February 15, 1981.
William.J. Dircks Executive Director for Operations 4
I 1
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