ML20135C218
| ML20135C218 | |
| Person / Time | |
|---|---|
| Issue date: | 11/22/1996 |
| From: | Bangart R NRC OFFICE OF STATE PROGRAMS (OSP) |
| To: | Orctiger T ILLINOIS, STATE OF |
| References | |
| NUDOCS 9612060228 | |
| Download: ML20135C218 (4) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION 3
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WAsHINoToN, D.C. 20066-0001 November 22, 1996 1
4 Mr. Thomas W. Ortciger, Director lilinois Department of Nuclear Safety 1035 Outer Park Drive Springfield, IL 62704
Dear Mr. Ortciger:
i This letter is in response to your letter dated September 12,1996. We recognize your decision to not send anyone to NRC training courses during fiscal year 1997 and that you 4
will reevaluate your position when the results of the rebaselining study become available.
Your letter presented severalissues which you will be following closely. We have addressed these issues with our current ;.osition.
1.
How will the new training policies affect IMPEP reviews? NRC cannot claim that Agreement State staff must attend NRC training courses to ensure adequacy when in fact, a program may demonstrate that it is " adequate" without attending the NRC
" core" training. How will equivalent training recommendations be handled?
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Response: The IMPEP process is based on performance. We expect a State program
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to have a process for the training and qualification of its staff. Such a process can include NRC courses, other courses, on-the-job training, and confirmation by the Program Director that the individual meets the State's qualification requirements based on the individuals education, training, and experience, if questions arise during the evaluation of a program, the IMPEP team will evaluate that aspect of the program in greater detail, in this case the training of the staff. The IMPEP team would look for evidence that the staff are qualified in the areas in which they are working. If an individual has attended an NRC, or alternative, course, but does not demonstrate an understanding through performance, the team may recommend additional training or an evaluation of training program effectiveness.
The overall goal for the training requirements is to have adequately qualified staff performing independent work. The NRC has evaluated its training needs and documented them in inspection Manual Chapter 1246 for the radioactive materials regulatory program. The NRC/OAS training working group has begun the process of development of guidance for the Agreement States in the area of training including alternatives to the NRC courses. They will outline the essential elements that must be addressed for an individual to be qualified in a given subject area. This guidance is scheduled to be completed by late spring 1997. We appreciate the participation of your staff in this effort.
2.
The course costs listed on the attachment to SP-96-089 appear to be based on the g\\
capacity number of students attending a specific course. When courses do not fill g 4 g nup, would remaining slots be offered to Agreement States free of charge, or would 06004g' g gga GON 9612060228 961122
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they remain empty? In essence, the NRC licensees would continue paying for training slots that are not used. We doubt that NRC licensees would agree that this is an " equitable" way to spend their money.
Response: The cost pcr student was calculated by dividing the contractor cost by the number of students allowed in the class (as specified in the contract). There is a minimum size to hold a class. After this number has been met the course will be held. Slots not filled would be available for attendance by Agreement State staff at no charge. Such slots, however, would only be available after all NRC and A greement States staff paying tuition costs were allocated in the course.
In establishing contracts for training courses, NRC purchases an entire course. The I
cost for a course is dominated by the instructor and facility costs which are approximately 85% of the total coat for a course. The additional costs, such as manuals, vary with the number in the class, but are about 15% of the cost. Leaving spaces empty in an NRC training course may not be efficient but it could still be j
" equitable" for NRC licensees. They would only be paying for the training of NRC personnel.
i We also are looking forward to the Commission's final decision on the rebaselining study.
If you have any questions on our responses to your concerns, please call me at 301-415-3340 or Dennis Sollenberger at 301-415-2819.
Sincerely, j
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Office of State Programs
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they remain empty? In essence, the NRC licensees would continue paying for't' raining slots that are not used. We doubt that NRC licensees would agree that this is an~" equitable" way to spend their money.
y Response: The cost per student was calculated by dividing ihe contractor cost by the number of students allowed in the class (as specified in the contract). There is a f
minimum size to hold a class. After this number has been met the course will be I
held. Slots not filled would be available for attendarice by Agreement State staff at 3
no charge. Such slots, however, would only be available after all NRC and Agreement States staff paying tuition costs were allocated in the course.
In establishing contracts for training courses, NRC purchases an entire course. The I'
cost for a course is dominated by the instructor and facility costs which are l
approximately 85% of the total cost for a course. The additional costs, such as manuals, vary with the number in the class, but are 'about 15% of the cost. Leaving spaces empty in an NRC training course may not be efficient but it could still be j
" equitable" for NRC licensees. They would only be paying for the training of NRC personnel.
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We also are looking forward to the Commission's final decision on the rebaselining study.
If you have any questions on our responses to your concerns, please call me at j_
301-415 3340 or Dennis Sollenberger at 301-415-2819.
l Sincerely,
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OriginalSigned By RICHARD L BANGART i
j Richard L. Bangart, Director l
Office of State Programs i
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lilinois File DOCUMENT NAME: G:\\ortciger.dms To receive a copy of this document, indicate in the box: "C",= Copy without attachment / enclosure "E" = Copy withJtti chment/ enclosure "N" = No copy '
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DATE 11/19/96 11'/3)96 s
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TASK # - 6S231 DATE- 09/16/96 MAIL CTRL. - 1996 j
TASK STARTED - 09/16/96 TASK DUE - 10/J (/96 TASK COMPLETED -
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g, TASK DESCRIPTION - 9/12/96 LTR RE TRAINING COSTS LIST AND REQUEST FOR
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September 12,1996 9
U.S. Nuclear Regulatory Commission Document Control Desk Pl-37 Washington, D.C. 20555 Attn: Richard L. Bangart, Director, OSP Re: Training Course List and Request for Interest in Attending (SP-96-089) i
Dear Mr. Bangart:
In response to the above-identified Agreement States letter, the Illinois Department of Nuclear Safety (Department) is hereby notifying you that we do not intend to send anyone to NRC training courses during FY 97. We will reevaluate our position on participation at NRC training courses when the results of the rebaselining study become available.
While arriving at this decision, we became aware of certain inconsistencies in interpretation or implementation of your current policies. We will be watching the following issues very closely:
1.
How will the new training policies affect IMPEP reviews? NRC cannot claim that Agreement State staff must attend NRC training courses to ensure adequacy when in fact, a program may demonstrate that it is " adequate" without attending the NRC " core" training. How will equivalent training recommendations be handled?
2.
The course costs listed on the attachment to SP-96-089 appear to be based on the capacity number of students attending a specific course. When courses do not fill up, would remaining slots be offered to Agreement States free of charge, or would they remain empty? In essence, the NRC licensees would continue paying for training slots that are not used. We doubt that NRC licensees would agree that this is an " equitable" way to spend their money.
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e Mr. Richard Bangart Page 2 We sincerely hope that as a result of the rebaselining study, the Commission will change its policy of not funding training and other assistance for Agreement States. We are looking forward to seeing preliminary results of the rebaselining study, and trust it will reflect a true partnership with the Agreement States. If you have any questions regarding these comments, do not hesitate to call me or Kathy Allen at (217) 785-9931.
Sincerely,
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N Thomas W. Ortciger Director TWO:kaa cc:
All Agreement States Chairman Jackson Jim Lynch, State Agreements Officer
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