ML20058L917
| ML20058L917 | |
| Person / Time | |
|---|---|
| Issue date: | 08/06/1990 |
| From: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| References | |
| TASK-RII, TASK-SE SECY-90-270, NUDOCS 9008090010 | |
| Download: ML20058L917 (3) | |
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August 6' 1990 SECY-90-270 (Informat. ion).
For:
The Commissioners From:
James ti. Teylor Executive Director for Operations
Subject:
RESPONSE TO U.S. APPEALS COU'T'S DECISION IN
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PUBLIC CITIZEN VS. NRC i
Purpose:
To inforn the Commission of the staff's plans for a rule i
addressing requirements for the training and qualification of nuclear power plant personnel.
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- Summary:
Based on the April 17, 1990, decision of the U. S. Court of Appetls for the District of Columbia Circuit, the staff is developing a required rule which is performance-based and ocn-prescriptive.
Background:
On Apri' 17, 1990, the U. S.-Court of Appeals for the District of Columb M Circuit concluded that the Commission had not complied w1'h Congressional' directive to create mandatory
'j requirements for the training and qualification of personnel
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at civilian i.uclear power plants.
The Office o, the General Counsel, at the direction of-the
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Commission', sought rehearing of the decision:by theifull Court i 1
On June 19, 1990, the rehearing was denied.
Discussion:
The staff.is in the process of developing a proposed rule' addressing requirements for the training and quali#ication 3
of nuclear power plant personnel. The proposed ruie*would 1
require each licensee to provide training to personnel using i
a performance-based systems approach to training (SAT). A i
performance-based training and qualification program seeks to improve the tasks and related knowledge and skills required f
1 CONTACT:
NOTE: TO BE MAPE PUBLICLY AVAILABLE IN Susen F. Shankman, NRR 10 WORKING DAYS FROM'THE DATE OF X21014 j.
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The Conmissior.s a i
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- fur competent job performance.
This is the system that the Commission endorsed in its Policy Statement on Training ~ and Qualification of Nuclear Power Plant Personnel.
in' its Policy Statement, the Comission-noted that it considers the following five elements as essential to acceptable performance-based training programs:
u (1)Systematicanalysesofthejobstobeperformed, i
(2) Learning objectives derived from the_ analyses which describe desired performance after training, (3)Trainingdesignedandimplementationbasedonthe learning objectives, (4) Evaluation of trainee mastery of the objectives during training, and (5) Evaluation and revision of the training based on the performance of trained personnel in the job-setting.
This approach yould describe essential elements of a-performance-based system.
Because licensees'moy need further details to. determine an. acceptable approach, such-detail would be provided in a regulatory guide.
A strong advantage of the systems approach'to training is that it is self-correcting. As workers and the job requirements change, the continuing reanalysis of job-performance--leads to program revisions to meet the needs of the site. ~Another adventage of:this appro, changing
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ach is that programs developed according tu the guidelines i
distributed under the INP0-managed training. accreditation-
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program are based on SAT. Therefore, this approach builds on a
the current industry initiatives. Th u e eiforts have been
-1 successful in it.iproving industry training programs as
-I reported to the Commission in SECYs'85-288,86-119, 87-121,88-351, 89-203 and 90-005.
In addition, the staff has-reviewed such programs.and has determined them to be effective. This approach also has the adhntage of providing flexibility while having a minimal effect on licensee and NRC stoff resources.
It should be noted tnet prior to development o'f the Policy-
.i Statement, the staff had developed a' SAT-based rule and supporting regulatory guide.
Further, the proposed rule and reguletory guide were compared by--the staff to the' INPO-proposed accreditation program objectives ano criteria.
Cased on this review, the staff determined that the INPO progrom content compared favorably and was consistent with n
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Thb Commissioners 3-the staff's intent for improved training. Thus, this rule would not necessitate the staff starting over and would' permit utilizing experience as a basis for updating the~
, previous staff rulemaking effort.-
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The. staff estimates that the rulemaking process would require approximately 2 full-time equivalent. staff years-3.
1 and that 1 year would be required to draft and publish a final rule.
Coordination The Office of the General Co'nsel has reviewed this paper and has no legal objection.
,/
mes M. T or.
xecutive irector for Operations
-DISTRIBUTION:
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GPA Regional Offices
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