ML20126M390
| ML20126M390 | |
| Person / Time | |
|---|---|
| Issue date: | 06/11/1985 |
| From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Pate Z INSTITUTE OF NUCLEAR POWER OPERATIONS |
| Shared Package | |
| ML20126M395 | List: |
| References | |
| NUDOCS 8506200314 | |
| Download: ML20126M390 (15) | |
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4' JUN 111985 Mr. Zack T. Pate President,-Institute of Nuclear Power Operations 1100 Circle 75 Parkway Suite 1500 Atlanta, GA 30339
Dear Mr. Pate:
Enclosed are two copies of our revision of the Coordination Plan for NRC/INP0 Training _Related Activities (Appendix Four to the Memorandum of Agreement).
The change we propose to Attachment 1 substitutes "NRC-designated contractors" for National laboratories because we are currently using private sector contractors to assist us in the areas of examinations and training. These contractors would require access to the JTA data base.
INP0 would still have approval authority. has not been changed.
I have signed the revised copies.
If you agree with the revisions, please sign, date and return a copy.
Sincerely, (Signes William J.Direks William J. Dircks Executive Director for Operations
Enclosures:
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Mr. Zack T. Pate, President Institute of Nuclear Power Operations 1100 Circle 75 Parkway Suite 1500 Atlanta, GA 30339
Dear fir. Pate:
Enclosed are two copies of our revision of the Coordination Plan for NRC/INP0 Training-Related Activities (Appendix Four to the flemorandum of Agreenent).
Also enclosed is a mark-up of the version you sent to me on April 9,1985.
The change we propose to Attachment 1 substitutes "NRC-designated contractors" for National Laboratories since we are currently using private sector contractors to assist us in the areas of examinations and training.
These contracto s would require access to the JTA data base.
INP0 would still have approval authority.
In Attachment 2, we have made several changes which would
- allow NRC to select the INP0 documents to be reviewed
- allow NRC management the authority to determine the number of NRC employees needed to observe INP0 tean' visits
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- indicate that NRC will audit a sanple of\\ utility training programs to fulfill our responsibility to " independently evaluate applicants' and l
licensees' implementation of improvement programs."
We have also deleted parts of Sections 3.b. and 3.f.
ince they are not subject to agreement between NRC and INP0.
l I have signed the revised copies.
If you agree with the ret!sions, please sign, date and return a copy.
Sincerely, t
1 Willian J. Dircks l
Executive Director for Operations i
Enclosures:
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Mr. Zack T. Pate.gPresident Institute of Nuclea.r Power Operations 1100 Circle 75 Parkway Suite 1500 N
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Dear Mr. Pate:
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Enclosed are two copies of our revision of the Cpordination Plan.for NRC/INP0 Training-RelatedActivities(qppendixFourtotpeMemorandumofAgreement).
Also enclosed is a mark-up of the version you ent to me on April 9, 1985.
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The change we propose to Attachment I subst;itutes "NRC-designated contractors" for National Laboratories sipce we are currently using private sector contractors to assist us in\\the a eas of examinations and training.
These contractors would require access the JTA data base.
INP0 would still have approval authority.
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ents to be reviewed
- allow NRC to select the I
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- allow NRC management ttye authority to\\ determine the number of NRC employees needed to observe INP0 team v sits
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- indicate that NRC will audit a sample of utility training programs to fulfill our responsibility to "independentiy evaluate applicants' and x
licensees' implerpentation of improvement pro rams."
Wehavealsodeletedp/arts of Sections 3.b. and 3.f.
ince they are not subject to agreement /between NRC and INP0.
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I have signed thefrevised copies.
If you agree with th revisions, please sign, date and rpturn a copy.
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William J. Dircks Executive Director for Operations
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y Zack T. Pate, President Institute of Nuclear Power Operations 1100 Circle 75 Parkway Atlanta, GA 30239K
Dear Mr. Pate:
Enclosed are two copies 'of our revision of.t)1e Coordination Plan for NRC/INP0 Traininc-Related Activities (Appendix Four o the Memorandum of Agreement).
Also enclosed is a mark-upof the version ou sent to me on April 9, 1985.
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The change we propose to Attaghment I su stitutes "NRC-designated contractors" for National Laboratories ince we are currently using private sectorcontractorstoassistus\\intheareasofexaminationsandtraining.
These contractors would require acce to the JTA data base.
INP0 would still have approval authority.
In Attachment 2, we have made sev.
I changes which would
- allow NRC to select the P0 d cuments to be reviewed
- allow NRC management t e authori to determine the number of NRC employees needed to o serve INP0 am visits
- indicate that NRC w.11 audit a samp e of utility training programs to fulfill our respor ibility to "indep.ndently evaluate applicants' and licensees' impler ntation of improve n,t, programs. "
We have also deleted rts of Sections 3.b. artp 3.f. since they are not subject to agreement etween NRC and INP0.
I have signed the r vised copies.
If you agree ith the revisions, please sign, date and re rn a copy.
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William J. Dircks
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Executive Director for Operations
Enclosures:
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APPENDIX NUMBER FOUR C0 ORDINATION PLAN FOR NRC/INP0 TRAINING-RELATED ACTIVITIES
===1.
Background===
The purpose of this plan is to coordinate selected NRC and INPO activities related to nu ar power industry training.
It is also intended to provide a nr ism and a basis for information sharing and NRC recognition of INPi
'ts in this area.
There are several unde sumptions:
o INP0 and NRC shar of improving and maintaining the quality of nuclear utili' o
INP0 recognizes iulatory responsibilities.
O Coordination (
craining-related activities and sharing of ir increase overall effectiveness as well as lessen th
.d on the industry by duplication of activities.
2.
Overall Coordinatio In order to promote os I coordination of NRC and INP0 training-related activa ss, the following actions will be taken:
a.
NRC/INP0 Human Factors Coordination Meetings will continue to be held on approximately a quarterly basis with representatives from NRC's Division of Human Factors Safety (NRR), Human Factors Branch (RES-DF0), and INP0's Training and Education Division. At these meetings, ongoing projects and plans will be discussed. Oppor-tunities to contribute to each other's projects will be identified.
1 Written reports of progress and results will be exchanged.
b.
An INP0 observer will be invited to attend the programmatic review meeting of the Human Factors Review Group.
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NRC/ INFO Coordination Plan Appendix Four Page 2 J
c.
Coordination in specific areas is covered by attachments as follows:
(1) Job and Task Analysis - Attachment 1 (Revision 1)
(2) Accreditation of Training Programs - Attachment 2 I
i no WilliadqforDircks Zack T. Pate Executive Director for Operations President U.S. Nuclear Regulatory Commission Institute of Nuclear Power Operations Effective Date:
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NRC/INP0 Coordination Plan Appendix Four (Revision 2)
JOB AND TASK ANALYSIS Both NRC and INP0 analyze (and/or contract for the analysis of) nuclear power plant jobs and tasks for the purpose of defining training and qualification requirements, developing licensed operation examinations, improving operating procedures, recommending staffing levels, and evaluating control room human factors considerations.
It is recognized that the NRC, INP0, and nuclear utilities would benefit from coordination and sharing of data.
It is agreed that the following actions will be taken:
1.
The NRC and NRC contractors will collect job and task analysis data in such a manner that it can be incorporated into the INP0 computerized data base. NRC will provide this data to INP0 in machine readable form on tape.
2, INP0 will provide the NRC and, with INP0 approval on a limited, case-by-case basis, NRC-designated contractors with access to the job / task analysis data stored in the INP0 computer system.
INP0 approval for contractor access will be in writing from the Vice President and Director, Training and Education Division.
This will include data i
collected by the NRC and INPO. Access to this data will be via terminals located at the NRC and the NRC-designated contractor sites, but will be limited to " read only" access. TYMNET costs will be borne by NRC and its contractors will be limited to 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> per week during the time period 8:00 a.m. and 5:00 p.m. E.D.T. or E.S.T.
Outside of I
those hours it is not considered necessary to specify limits at the present time.
3.
NRC and INP0-approved NRC-designated contractors may use the INP0 l
job / task analysis for the following purposes:
a) evaluation of human engineering designs of new control rooms and retrofitting current control rooms b) identification of skill and knowledge requirements of plant personnel c) evaluation of operator qualification and plant personnel training requirements d) development of test questions for operator examinations e) evaluation of normal, off-nonnal, and emergency operating procedures f) assessment of job performance aids g) evaluation of internal communication methods and systems
NRC/INP0 Coordination Plan Appendix Four (Revision 2)
Page 2 4.
NRC will make available to INP0 the job / task analysis data tapes containing the results of the NRC control room crew task analysis performed in 1982-83, additional data which may be collected by the NRC for control room crew task analysis, and other data which may be col-lected for other crafts and technicians associated with nuclear plant maintenance and operation.
5.
Unless agreed otherwise, the data collected by INP0 and the data collected by the NRC will be kept separated.
Every effort will be made by both parties to protect the confidentiality of the data, the names of the nuclear power plants, and the personnel contributing to the data base, and to protect that information covered by the Privacy Act of 1974 (P.L.93-579).
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NRC/INP0' Coordination Plan Appendix Four ACCREDITATION OF TRAINING PROGRAMS
===1.
Background===
The purpose of this plan is to provide for coordination of selected INPO and NRC activities related to the implementation and accreditation of performance-based training programs.
This plan also provides for continued industry initiative with NRC monitoring in this area and serves as a basis for NRC recognition of INP0's efforts. This coordination plan is consistent with the Commission Policy Statement on Training and Qualification of Nuclear Power Plant Personnel.
There are several underlying assumptions, including the following:
INPO recognizes NRC's regulatory responsibility.
o NRC recognizes the industry's initiative and commitment to INP0 o
programs that promote high quality training through development of integrated training and qualification s accreditation of key training programs.ystems, ir.cluding NRC and INPO recognize the need for a period of orderly progress o
in training activities as utilities implement training improvements, including performance-based training programs and continued additions of training staff, facilities, and simulators.
NRC recognizes INPO accreditation and associated training o
evaluation activities (see also Appendix 2 " Coordination Plan for NRC/INPO Appraisal and Evaluation Activities") as an acceptable means of self-improvemeat in training. Such recognition encourages industry initiative and reduces duplicate program review and appraisal activities.
INP0 recognizes that the NRC requires access to selected INPO o
documents and information, as well as the opportunity to observe selected INPO activities related to training and accreditation, in order to ensure that the NRC meets its obligations to the public and the Congress.
2.
INP0 Activities This section outlines current and planned INPO activities related to training and qualification of nuclear power plant personnel and accreditation of performance-based training programs.
The INPO point of coordination for the implementation of this Attachment is the Vice President and Director, Training and Education Division.
NRC/INPO'Coordinaticn Plan Appendix Four Page 2 1
a.
INP0 will continue to manage the accreditation of utility training programs including:
o self-evaluations by member utilities, with assistance from the INPO staff; l
0 on-site evaluations of training and qualification programs by teams of INP0 and utility personnel; o
preparation of a report for each accreditation evaluation; o
follow-up on recommendations developed during the accreditation process, including follow-up as part of the regular plant evaluation program; o
awarding (or deferring) of accreditation by the Accrediting Board; o
submittal to INPO by member utilities of two-year interim status reports on accredited programs; and o
re-accreditation of utility training programs covered by INP0 accred!tation approximately every four years.
b.
INP0 will continue to conduct periodic performance-oriented evaluations of training and qualification programs as part of its regular plant evaluations.
c.
INPO will develop a Training System Development Manual and accreditation program description and accreditation criteria, and will provide copies of these documents to the NRC.
These documents will be made publicly available.
d.
INP0 will review and consider NRC reconsnendations regarding INP0-managed training-related programs, documents, and criteria.
e.
INP0 will provide periodic detailed briefings en accreditation to appropriate NRC management personnel, including review of the activities described in 2.a above and documentation of the status of industrywide progress toward accreditation.
f.
INP0 intends to brief the Commission periodically on program status.
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'itC/INPO'CoordinationPlan N
Appendix Four Pag 2 3 l
3.
NRC Activities This section outlines the NRC's continuing efforts to monitor'INP0 activities as part of NRC's assessment of the effectiveness of industry's training and qualification program improvements. The NRC point of coordination for implementation of this Attachment is the Director, Division of Human Factors Safety.
NRC will not issue documents that duplicate INP0 training a.
documents and will not refer to INP0 documents as a means of satisfying NRC requirements so as to avoid " codifying" or the appearance of " codifying" INP0 documents.
b.
NRC will assess the effectiveness of industry's training and qualification program improvements as follows:
o conduct operator licensing exams; o
conduct operator requalification exams, consistent with Comission policy; include a training sumary evaluation as part of each o
systematic assessment report of licensee performance (SALP);
monitor plant and industry trends and events involving o
personnel errors; continue evaluation of industrywide training and qualification o
program effectiveness; and conduct performance-oriented training inspections to assess o
the level of knowledge and qualifications of plant personnel.
NRC will monitor INPO activities in training and accreditation as c.
follows:
L o
receive periodic briefings and/or reports from INPO and review a sample of applicable INPO documents; o
recommend an individual who is not on the NRC staff to serve as a 4
member on each Accrediting Board with full voting privileges; have an NRC staff member attend and observe Accrediting Board o
meetings with the INPO staff and/or the utility representatives; 1
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NRC/INP0' Coordination Plan App:ndix Four Page 4 o
on request and with concurrence of the utility, have NRC employees observe INP0 accreditation team site visit ~s for the purpose of monitoring the effectiveness of the accreditation process. Since accreditation teams are relatively small in number, it is anticipated that NRC would typically send only one observer on any visit. However, in certain circumstances, it may be appropriate to send more than one.
INP0 will obtain the necessary concurrence from the host utility. While specifying a maximum number to be observed is not considered necessary by either party, it is anticipated that NRC employees would observe approximately 20 percent of INP0 accreditation team visits.
~
o accompany INPO on selected plant evaluations (see Appendix 2).
d.
NRC will provide INPO an opportunity to review and comment on NRC's performance-oriented inspection program, including applicable inspection guidelines.
NRC will review and consider INPO's consnents.
e.
NRC will coordinate any team inspections with INPO accreditat'on i
team visits and evaluations so as to minimize the impact on the utility involved. On request and with concurrence of the utility, an INPO employee may occassionally observe an NRC inspection in this area.
f.
Since INP0 has its own system for obtaining member corrective action, NRC's role in pursuing corrective action of INP0-identified training and qualification recomnendations will involve only significant safety problems for which NRC has no other reasonable alternative in meeting its legislated responsibilities. The NRC intends to exercise discretion in enforcement matters related to training as described in the Commission Policy Statement on Training and Qualification of Nuclear Power Plant Personnel.
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DUE: 04/25/85 EDO CONTROL: 000535 DOC DT: 04/09/85 ZACK T. PATE FINAL REPLY:
INPO hO-TO:
DIRCKS FOR SIGNATURE OF:
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