ML20198N939

Informs Commission of Staff Plan for Improving Effectiveness of NRC Training Program

ML20198N939
Person / Time
Issue date:	12/18/1998
From:	Travers W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:
References
SECY-98-291, SECY-98-291-01, SECY-98-291-1, SECY-98-291-R, NUDOCS 9901060255
Download: ML20198N939 (20)

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o j acoooooooaaaoooooooooos-POLICY ISSUE December 18.1998 SECY-98-291 FOR: The Commissioners FROM: William D. Travers Executive Director for Operations

SUBJECT:

PLAN FOR IMPROVING THE EFFECTIVENESS OF NRC'S TRAINING PROGRAMS PURPOSE:

To inform the Commission _ of the staff's plan for improving the effectiveness of NRC's training programs.

SACKGROUND: .

1 During the past few years the staff has undertaken a number of actions to identify, define, and resolve issues related to management nd implementation of agency training activities. In response to an Executive Director for Operations (EDO) request that the technical training staff provide recommendations for better integration of regulatory knowledge, skills, and abilities (KSAs) into the technical training and qualification program to improve the regulatory skills of the staff, a staff paper titled " Regulatory Skills Training Integration Plan" was completed in February 1998. It included a number of recommendations intended to improve the quality and consistency of reactor operations inspector regulatory training. Similar improvements were recommended for other inspector disciplines and reactor program staff. l Job task analyses (JTAs) for positions in the Regional Divisions of Reactor Projects and the Nuclear Reactor Regulation (NRR) Divisions of Reactor Projects were completed in August 1997 and July 1998, respectively.

Contact:

Paul E. Bird, HR Of /[

(301) 415-7516 Kenneth A. Rag!in, AEOD/TTD (423) 855-6500 OGOM'l fa#$ 54/ l 9901060255 981218 . I DR 9s 29 PDR VO M' b/ '

In March 1998, the EDO requested that the Office of Human Resources (HR) devise a means for planning, prioritizing, and scheduling all agency training. A prototype of an automated integrated calendar for scheduling training, which can be accessed by all employees on the NRC Internal Home Page, was developed.

In April 1998, the Executive Council designated a team of senior managers and subject matter experts from the Offices of NRR, Nuclear Material Safety and Safeguards (NMSS), Nuclear Regulatory Research (RES), and Region ll, led by Jack W. Roe, NRR, to review the agency's training activities in order to identify ways to improve the effectiveness and efficiency of the agency's training function in preparing NRC employees to perform their duties. The team presented their preliminary findings and recommendations to the Executive Council in August 1998, and delivered a written report in September 1998. This report is provided as an appendix to this paper.

DISCUSSION:

In its final report issued in September 1998, the Training Review Group proposed a number of recommendations. The group's specific recommendations and the staff's plan for improving the effectiveness of agency training activities are provided below. The attachment provides a list of the major staff actions discussed in this paper and associated milestones. As indicated in the

, responses to the specific recommendations and in the listing of major staff actions, the staff intends to prioritize training and development resources as necessary to address systematically the highest priority agency training needs. This includes optimizing the opportunities for improving the regulatory culture and regulatory skills of the staff consistent with established programmatic guidance. Additionally, the staff plans to establish an infrastructure through the Executive Resources Board to provide a forum for agency-wide discussion and coordination of training and development activities.

Recommendation 1: Combine existing providers of formal training into a single organization, reporting to a single Deputy EDO, with the responsibility and authority to effectively manage the agency's training function.

Many managers interviewed by the Training Review Group stated that there should be a single group to manage, oversee, and coordinate Agency training activities. Those interviewed recommended that the responsibility for Agency training should be at a level with adequate decision making and budgeting authority to ensure that training contributes appropriately to the accomplishment of the Agency's mission and goals.

The Technical Training Division (TTD) of the Office for Analysis and Evaluation of Operational Data (AEOD) and the Human Resources Development staff of the Office of Human Resources (HR) will be combined in the Office of Human Resources. Since training and development are integral parts of human resources management, placing the new, consolidated organization in HR under the Deputy Executive Director for Management Services is a logical choice. The rationale for consolidating the training function within HR is further developed and discussed in SECY-98-228, " Proposed Streamlining and Consolidation of AEOD Functions and Responsibilities."

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Efficiency and effectiveness will be enhanced by placing all trLining and development activities l in one organization under one Deputy Executive Director. This organization will have responsibility and authority for management, coordination, oversight, program planning and budgeting, performance measurement, approval, scheduling, and implementation of all agency training and development activities.

t Recommendation 2: Integrate the budget for all training-related activities to ensure that the Agency can monitor, prioritize, and control the use of training funds to develop and maintain staff competencies.

, it is important that the Commission and agency senior management have accurate and reliable training and development cost data and can consider these costs systematically during budget reviews. The Training Review Group report articulates the difficulty the team encountered with quantifying agency costs for training and development activities. Under the current structure, separate budgets and operating plans for training and development managed by HR and technical training managed by AEOD are prepared and presented to senior management.

Additional training and development costs incurred by the agency by other offices and regions  !

which sponsor training as well as the costs (FTE and $) to attend training are not factored into either of these two budgets. A consolidated training organization will enable necessary cooperation with program offices and regions and will facilitate the capture of information pertaining to agency costs for training activities.

As agency resources decline, careful monitoring and prioritizing of training funds are essential.

Consolidation of training and development activities will enhance management's ability to weigh priorities judiciously so that the training and development activities that are most important for accomplishing the agency's mission and performance goals are supported. The consolidated training organization will be responsible for development and implementation of policy and process changes required to ensure effective and efficient management, coordination, and oversight of agency training and development. Additionally, the infrastructure established through the Executive Resources Board will provide a forum for agency-wide discussion, coordination, and prioritization of training and development activities.

Reactor technical training, raaterials technical training, and professional training and development will be managed and controlled as one integrated training program. The Agency's training budget will reflect this integration. Planned accomplishments and milestones will be structured according to the phases of the systems approach to training (needs analysis, design and development, implementation, and evaluation). Over time, training activities not currently under the purview of AEOD/TTD or HR will be identified, included in the planning framework, and evaluated for consolidation in HR's operating plan.

Recommendation 3: Improve the processes used to approve, develop, and implement training ensuring: the use of a standard, systematic approach to determine what training is needed as well as to determine the appropriate training audh.%c; the use of objective criteria to obtain approval for making training a requirement; and the involvement of agency training professionals to guide key phases of training development and evaluation.

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i i This recommendation is consistent with requirements imposed on NRC licensees.10 CFR 50.120, " Training and qualification of nuclear power plant personnel," requires licensees to l establish, implement, and maintain a training program derived from a systems approach to I training.10 CFR 55.4, " Definitions," states: " Systems approach to training means a training  !

program that includes the following five elements: (1) systematic analysis of the jobs to be  !

performed; (2) learning objectives derived from the analysis which describe desired i performance after training; (3) training design and implementation based on the learning  !

objectives; (4) evaluation of trainee mastery of the objectives during training; (5) evaluation and l revision of the training based on the performance of trained personnelin the job setting."

The systems approach to training is a comprehensive, standard multi-phase program that includes training needs analysis, training program design and development, implementation of 1 training, and program evaluation. A more detailed description of each of these elements follows. j The training needs analysis phase consists of identification of training needs and of knowledge, skills, and abilities (KSAs) and competencies needed forjob performance. The purpose of the design phase is to convert the competencies and/or KSAs that were selected for training during the analysis phase into training objectives, and to sequence these training objectives into a training plan for initial and continuing training. The purpose of the development phase is to produce the materials (such as course manuals, graphics, lesson plans, examinations, etc.)

needed for implementation of the training program. This includes development of new materials, as well as maintenance and upgrade of existing course materials. Training implementation is the conduct of training using the materials and lesson plans developed during earlier phases.

This includes maintaining a qualified instruction staff and adequate training facilities and equipment. The purpose of the evaluation phase is to determine the effectiveness, efficiency, and impact of the training program and to identify whether and where revisions or improvements to the training are needed to maintain or improve the quality of job performance. This includes collecting and evaluating written feedback from students at course completion and, for selected <

l courses, from students after working for a time in their assigned job functions, from the line management of students regarding the effectiveness and relevancy of the technical training curriculum as evidenced by employee performance, providing project management and technical oversight of contractors for contracted courses to ensure contractor courses are evaluated and improvements made in accordance with contract requirements, and conducting post-course reviews to evaluate feedback with course instructors.

Both HR and AEOD currently provide training using the principles of the systems approach to training. Examples of agency training success stories include the modifications to the PRA curriculum during FY 1996 and FY 1997 and development and implementation of the Field Techniques and Regulatory Processes course. These instances were successful primarily because the training needs were defined and training requirements established systematically.

Closely coordinated efforts between the agency's subject matter experts and training professionals resulted in defining the audience and appropriate leaming objectives, design, development, and validation of the training materials, and implementation of the courses including involvement of instructors and program office subject matter experts during course J I

delivery. These instances will be used as benchmarks for defining and documenting an agency process for practical usage of the principles of the systems approach to training for all training and development activities provided by contractors and agency staff. HR will serve as consultants to Offices on using this sys: ems approach to training.

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l Recommendation 4: Review, evaluate, and formalize staff training activities, including those proposed in the " Regulatory Skills Training Integration Plan," using a standard, systematic approach to the training process to ensure acquisition and maintenance of regulatory, technical, professional, and management skills, as appropriate, for job positions and functions in support of the Agency mission and goals.

The consolidated training organization, in conjunction with line managers, will be responsible for systematically and methodically reviewing the knowledge, skills, and abilities needed for effective job performance, and formalizing staff qualification and training requirements, as appropriate. In August 1997 and July 1998, Job task analyses (JTAs) were completed for

Regional and NRR Divisions of Reactor Projects positions, respectively. Staffis currently in the process of reviewing the JTA contractor training recommendations and JTA results and formulating actions to address the recommendations. The JTA contractor's recommendations generally follow the standard systems approach to training methodology and, therefore, the majority of the recommendations are valid and are being considered for implementation by the staff. For example, the JTA results confirmed a training gap (i.e., inadequacy in or lack of skills) associated with tasks and KSAs related to regulatory processes, procedures, and skills.

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An integrated assessment of training needs for reactor projects staff is in progress and includes j JTA insights as well as insights from other pertinent inputs including the Training Review Group Report, the Regulatory Skills Training Integration Plan, and regulatory process changes l currently being designed in accordance with the EDO's tasking memo. Once resulting revisions I to the training and qualification programs are completed for reactor projects staff, training requirements for other regional inspector positions, NMSS positions, and other agency technical and non-technical staff positions will be examined. The staff does not currently plan to perform any further formal JTAs. However, the data from the NRR JTAs can and will be extrapolated for application to other agency technical positions. In addition, as the core competencies / skills assessment information is collected, it will also serve as a foundation on which to build appropriate training programs and requirements for agency staff positions. A balanced approach between regulatory, technical, and professional training will continue to be sought, and is especially important at this time as the NRC strives to change its corporate culture and define  !

its appropriate regulatory role in a changing political environment.

Recommendation 5: Use Agency training professionals to revise Management Directive 10.77 " Employee Development and Training" to delineate and require a standard, systematic approach to the training process for need determination, approval, development, implementation, and evaluation of all agency training activities.

Management Directive 10.77, " Employee Development and Training," currently delineates the agency's policy, organizational responsibilities and delegations of authority, and processes for providing, approving, and attending NRC sponsored training and development activities. The management directive is currently silent regarding any specific processes required for needs analysis, approval, development, prioritization, implementation, or evaluation of training activities. The management directive will be revised to delineate required implementation of the 4

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standard systems approach to the training process for needs analysis, approval, development, implementstion, and evaluation of ali agency training activities, Changes would be discussed with management and bargaining unit representatives, as appropriate. The revised management directive will incorporate applicable material from existing TTD Policy Document 2,

" Technical Training Program," which requires that technical training courses developed for the NRC by the TTD staff or contractors be developed and maintained using the systems approach to training principles and describes the process currently used to develop and maintain technical training courses.

In addition, the revised management directive will include the following specific elements:

1. New organizational responsibilities and delegations of authority for the consolidated i training organization within the Office of Human Resources.

2. A process for planning, approving, and scheduling all training and development activities through the training organization.

3. A process for identifying new training needs and formally communicating them to the training organization.

4. A precess for determining the most effective and efficient method to develop and deliver tha training.

5. A process for reviewing and approving training and development activities.

6. A process for prioritizing and scheduling new train;ng activities.

7. A process for incorporating new training activities into the appropriate qualification, training, and development programs.

8. A process for developing, implementing, managing, and overseeing staff qualification and development programs.

9. Methods for evaluation and performance measurement of training and development activities.

Recommendation 6: Consolidate Agency training resources in the Washington area.

A decision to move the Technical Training Center facility to the Washington area must be done deliberately and only after taking into consideration a number of factors. Such a move would have to be planned wellin advance and carefully sequenced. There are programmatic, financial, infrastructure, timing, and staffing considerations which must be carefully evaluated.

The Office of the Chief Financial Officer has developed a Statement of Work to examine costs, and the Office of Administration is looking at the space requirements and space availability for relocating the Technical Training Center at headquarters. HR will examine programmatic, timing, and staffing issues.

Recommendation 7: Reduce the number of simulators to i BWR and 1 PWR.

The Training Review Group obtained opinions from senior managers on their perceptions regarding-the need for vendor-specific simulator training. These senior managers felt that NRC could provide adequate inspector training using 1 GWR and 1 PWR simulator. Simulator training is an integral part of providing both reactor technology and regulatory skills training within the inspector qualification and training programs. Vendor-specific simulator training is a highly effective method for developing and maintaining skills related to performance-based 4

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_7 regulatory safety assessment of control room configuration, vendor-specific design and operation, integrated systems operation for all plant modes, plant transient and accident response, and application of emergency procedures and severe accident guidelines necessary I to support inspecticn, licensing, assessment and enforcement decisions.

The programmatic need for vendor-specific simulator training will be determined within the centext of thts integrated assessment of training needs discussed previously for Recommendation 4. Based on the results of the integrated assessment, actions will be developed to ensure that appropriate trainin0 is implemented to provide the technical and regulatory foundation necesury for reactor projects staff to effectively and efficiently execute their tasks in support of NRC mission, policy, and goals. The issues of cost-benefit of multiple i simulators and location of simulators will be considered in the cost and space requirements study to address Recommendation 6. A decision to dispose of two additional simulators should be made deliberately given the replacemeni costs of $10-14M per simulator.

RESOURCES:

The actions to address Recommendations 1 through 5 will be accomplished with existing agency resources. Evaluation and development of resulting action plans to sddress Recommendations 6 and 7 will be accomplished with existing resources.

QOORDINATION:

The Office of the General Counsel has reviewed this Commission paper for legal implications and has no legal objection.

l The Office of the Chief Financial Officer has reviewed this Commission paper for resource implications and has no objections to its content.

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William D. Travers.

Executive Director for Operations

Attachment:

As stated DISTRIBUTION:

l Conunissione rs CIO OGC CFO OCAA EDO OIG REGIONS OPA SECY OCA ACRS ACNW i

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4 Table of Agency Training Action itemr4 No. Action item Assigned Date Due 1 Establish consolidated training organization. DEDM 1/99 2 Develop actions to address contractor training HR/NRR 1/99 recommendations resulting from JTAs for Regional and IMR DRP positions.

3 Establish infrastructure through ERB for discussion HR 5/99 and coordination of training activities 4 Develop action plan and milestones for HR 6/99 development of qualification and training program med}fications resulting from NRR JTAs.

5 Identify support offices and support office activities HR 6/99 necessary to support and manage agency training activities.

6 Coordinate with support offices to add training HR/ FY 1999 support activities to office operating and Program Third performance plans. Managers Quarterly Update 7 Develop consolidated agency training and HR FY 1999 development operating and performance plan. Third Quarterly Update 8 Revise Management Directive 10.77 to include the HR 9/99 process for identification, development, implementation, management and oversight of training activities.

9 Revise Management Directive 10.77 to include HR 9/99 guidance for inclusion of staff development and training planned accomplishments and performance measures in office operating and performance plans.

10 Provide staff recommendation on consolidating HR 9/99 agency training resources in DC area based on evaluation of programmatic, financial, infrastructure, timing, and staffing considerations.

11 Provide staff recommendation on the appropriate HR 9/99 number and types of simulators based on an integrated assessment of training needs.

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y S UNITED STATES

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j NUCLEAR REGULATORY COMMISSION -

WASHINGTON. D.C. 3056H001 -

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e 1998 OCT -1 Ptisk*pidaber 29, 1998 I' MEMORANDUM TO: L. Joseph Callan, Chair l u. Executi Council d

FROM: J t W. Roe, Acting Director lyhlon of Reactor Program Management

! Office of Nuclear Reactor Regulation -

SUBJECT:

TRAINING ACTIVITIES l

. The Executive Council assigned a team the task of reviewing the agency's training activities.

The team is comprised of individuals not directly involved with the agency's training function. .

The team consists of Masy Ann Ashley from NRR; Susan Shankman, Cynthia Jones, and _

Pat Rathbun from NMSS; Kitty Thompson from RES; and Caudie Julian from Ril.

The team's review of the train!ng activities was aimed at identifying ways to improve both the I effectiveness and efficiency of the agency's overall training function in preparing the NRC staff - l to perform their duties. Attached is the teams report. 1 ce; . J. Funches; CFO )

' A. Galente, CIO I P. Norry, DEDM H. Thompson, DEDR J

W.' Travers, DEDE '

P. Rabideau, CFO F. Goldberg,,0C10 J. Silber, OCM/SAJ l K. Cyr, OGC J. Blaha, OEDO i

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REPORT OF THE TRAINING REVIEW GROUP September 1998 i

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TABLE OF CONTENTS Executive Summary , page 3 Scope Assessment Areas page 4 Team Membership page.4 Methods issues Development page 5 Survey Development page 5 Sample Selection page 5 Observations and Findings Tasking Area 1 page 6 Tasking Area 2 - page 7 Tasking Area 3 page 9 Tasking Area 4 page 11 Recommendation Summary page 13 Attachment 1 - Training Review Group Tasking Memo i Attachment 2. FY 1997 Estimated Agency Cor,ts.for Leaming Activities ,

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EXECUTIVE

SUMMARY

The Training Review Group (TRG) effort involved a rev:ew of various aspects of the NRC's overall management of the training function. The team, consisting of representatives from the major offices, reviewed the management of Agency training adivities to identify ways to improve both the effectiveness and efficiency of the Agency's overall training function. To that end, review strategies included gathering cost data from Agency Mining providers as well as end users of the training programs.

Key areas for review as directed by the EDO tasking memo were: 1) assessment of the adequacy of planning to ensure that training is preparing the staff to meet projected future Agency needs; 2) determination of the total costs associated with providing and attending training; 3) assessment of the processes used to establish training programs and training requirements; and 4) assessment of the processes, policies, and organizations used to ensure training effectiveness and efficiency.

. The team developed potentialissues for review based on personal experiences and suggestions from a cross-section of co-workers. A written survey was used to collect opinions on a broad overview r;f iss'.*es and to focus subsequent interview questions.

The Training Review Group concluded that the following recommendations should be considered to improve the effectiveness and efficiency of the Agency's management of the training function.

1. Combine existing providers of formal training into a single organization, reporting to a single Deputy EDO, with the responsibility and authority to effectively manage the Agency's training function.

l 2. Integrate the budget for all training-related activities to ensure that the Agency can monitor, l prioritize, and control the use of training funds to develop and maintain staff competencies.

3. Improve the processes used to approve, develop, and implement training ensuring: the use of a standardized, systematic approach to determine what training is needed as well as to determine the appropriate training audience: the use of objective criteria to obtain approval for making training a requirement; EM tm involvement of Agency training professionals to guide key phases of training cevelopment and evaluation.

4. Review, evaluate, and formalite staff training activities, including those proposed in the

' Regulatory Skills Training Integration Plan," using a standardized, systematic approach to the training process to ensure acquisition and maintenance of regulatory, technical,

., professional, and managemsnt. skills, as appropriate, for job positions and functions in support of the Agency mission and goals.

5. Use Agency training professionals to revise Management Directive 10.77

• Employee Development and Training" to delineate and require a standard, systematic approach to the training process for need determination, approval, development, implementation, and evaluation of all Agency training activities.

6. Consolidate Agency training resources in the Washington area.

. 7. Reduce the number of simulators to 1 BWR and 1 PWR.

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SCOPE The scope of the review was established based on items identified in an EDO tasking memo dated '

March 17,1998. Key areas were: assessment of the adequacy of planning to ensure that training is preparing the staff to meet projected future Agency needs; determination of the total costs associated with providing and attending training; assessment of the processes used to establish training programs and training requirements; and assessment of the process for evaluating training effectiveness.

Team members were selected from five different offices and several organizationallevels. The overall team was constructed to be generally representative of the Agency staff as a whole.

Several of the members of the group have had training-related job assignments, although none have any current association with Agency training providers. The team was headed by Jack Roe, NRR. The team was composed of Mary Ann Ashley, NRR; Susan Shankman, Cynthia Jones and Pat Rathbun, NMSS; Catherine Thompson, RES; and Caudie Julian, Region 11.

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- METHODS l

Several methods were identified for data and information collection. Limited distribution surveys j

' and interviews were selected given the charter and the time limitations. A written survey was used  ;

l to collect opinions on a broad overview of issues. The survey development process began with the team identifying potential issues for review based on personal experience and suggestions from a cross-section of coworkert. Survey questions were then generated from team-identified l training issues. A number of issues were identified but each was determined to be related to at ,

least one of four characteristics that were considered by the team to be integral for effective j management of the Agency training function.

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, The four characteristics identified by the team were:

. There should be integrated management of the Agency training function;.

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. The Agency's overall training budget should be managed to ensure tne effectiveness and efficiency of various Agency learning activities and to focus resources on the achievement of Agency goals; e Training should be focused on developing and maintaining skills specifically related to supporting the Agency's mission;

- The transfer of leaming from training to job performance should be monitored and evaluated formally and on a regular basis and the evaluation information used to modify training requirements to maintain a focus on ensuring long term Agency success.

i The population to be surveyed and interviewed was selected using a sample approach. Previous Agency experience with the National Performance Review - Phase 2 indicated that surveying and interviewing the directors of major Agency offices and Regional Administrators together with their resource or program support manager would provide a sufficiently large and diverse sample. The Office Directors of NRR,' NMSS, AEOD, HR, OGC, and ADM as well as all four Regional

' Administrators were surveyed and interviewed for this project. In addition, insights from various members of the Executive Council were obtained during preliminary briefings on the team's approach and findings. These insights have been included in this report as appropriate.

Surveys were sent to regional administrators, office directors and the training directors at the Technical Training Center and the Professional Development Center as well as representative members of thetechnical staff. A total of 17 responses were received. Written responses were then used to verify the applicability of the integral characteristics developed by the team and to shape questions for individual interviews. A total of 12 interviews, involving 20 people, were conducted.

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OBSERVATIONS AND FINDINGS Tasking Area 1: Assessment of the adequacy of planning to ensure that training is preparing the staff to meet projected future Agency needs.

Related Characteristic: There should be integrated management of the training function.

While many of the individuals interviewed or surveyed were aware of the TTD and PDC as being the Agen 'y's formal training providers and knew who the managers of those organizations are, there was uncertainty in who or how overall Agency training decisions were made. Many of the managers noted that there does not seem to be a central focus for management of the overall training function. Two important areas for improvement were noted by managers. The first was j the need for more efficient management of the training function. The second was the need for l clearer lines of communication to ensure that the staff has input into training decisions.

While integrated management of the training function was seen as desirable, the managers cautioned that doing so should not reduce the Agency's ability to provide training tailored to specific needs nor should it result in a single Agency group making training related decisions

.without appropriate input from the line organizations. However, many managers felt that there should be a single group to manage, oversee, and coordinate Agency training activities. Those '

interviewed recommended that the responsibility for Agency training should be at a level with adequate decision making and budget authority to ensure that training contributes appropriately to the accomplishment of the Agency's mission and goals.

Recommendation:  ;

l - Combine existing providers of formal training into a single organization, reporting to a l single Deputy EDO, with the responsibility and authority to effectively manage the Agency's training function.

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Tasking Area 2: Identification of all technical and non-technical training provided by AEOD/TTD, HR and others including the determination of the total costs associated with providing and attending training.

, Related Characteristic: The Agency's overall training budget should be managed to ensure the effectiveness and efficiency of various Agency learning activities l and to focus resources on the achievement of Agency goals.

I Survey and interview results indicated that senior management needs better information on training needs, priorities, and budget to ensure that organizational units are maintaining or improving skills. Additionally, managers noted that the training budget may need to be increased in times of lean overall Agency budgets to support Agency transition to new prograrns or to improve Agency performance. Managers also felt that the Agency has not focused sufficiently on training of staff to accommodate changes in government. Many noted that training is reactive rather than proactive to changing needs.

Agency managers are concerned about the training budgets being imbedded in various office budgets which then leads to training funds being subject to individual office cuts and priorities, as opposed to overall Agency training needs and priorities. Of particular note was the significant reduction in funds in the peviour budget for individual training opportunities administered through NRC Form 368 (368). Many marmgers specifically noted that cuts in the Agency-wide 368 funds did not sufficiently consider the office-by-office impacts. Cuts to 368 funds in some offices where individual specialized technical training needs were greater resulted in staff not being able to be trained in topics specifically related to the development of job skills and tnereby impacted the ability of the office to meet its goals. In other offices, where the specialized training needs were less, the impact was on individual professional development rather than on the ability of the office to meet goals.

None of the managers interviewed was able to discern the process used to prioritize Agency

training funds and allocate the funds among offices. In addition, many of those surveyed or interviewed noted that the decrease in the 368 funds has lead to the perception that the Agency is no longer committed to supporting continuing professional education. However, most managers stated that decisions related to the expenditure of training funds should be based on overall prioritized Agency needs rather than by criteria established by individual offices or divisions.

Most managers were unable to provice a realistic estimate of the costs associated with providing and attending the various leaming activities. Many survey comments suggested that training conducted by NRC staff was viewed as not incuning costs to the organization receiving the training. Varying definitions and opinions about what constitutes training have contributed to the

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inability of Agency managers to quantify the total training costs. The costs associated with providing formal training by the TTD or HR are easily determined since these training providers maintain detailed documentation. However, the costs associated with staff time to attend formal l training are not easily retrievable. Each of the offices and regions sponsors activities which are not considered training but during which teaming occurs. Counterpart meetings, for example, are l not considered or documented as training activities but do include some activities specifically designed to provide knowledge or skills to the staff. Additionally, efforts expended in required self-study and on-the-job activities to qualify as an inspector, while not always formal, are clearly learning activities.

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f In compiling the cost data the focus was on alliearning activities. Therefore, data on both formal training and informal teaming activities were collected. Only those activities considered representative of a normal year were included. Because the number of hours contained in an FTE varies within the Agency,1800 hours0.0208 days <br />0.5 hours <br />0.00298 weeks <br />6.849e-4 months <br /> per FTE was used. Attachment 2 summarizes costs associated with Agency learning activities. The staff time to attend training was estimated on an Agency-wide basis for FY 1997 at 176 FTE at a cost of $15.7 M. Contractor costs for presenting training by TTD, HR , and various Regions totaled S 5.3 M. Related costs for TTC rent and for training related travel costs totaled an additional 5 4.8 M. Salariss for Agency staff at the TTC and PDC totaled S 3.5 M. Total Agency expenditures in FY 1997 for presenting and attending formal training and completing a variety of informallearning activities was estimated at S 29.0 M.

Of particular note was the amount of work needed to compile the information to determine the total Agency training costs. While the budget to operate the various leaming centers was easy to obtain, the hours spent by students in formal training or informallearning and related travel costs were not. The data needed to determine overall Agency training costs were not easily accessible because they are documented in various ways by various Agency organizations. Compiling the data required hano tallies of paper records in some cases or ad hoc queries to databases, when they existed. Most Agency computer systems were not able to provide information at the level of detail needed to track training costs on an office-by-office basis. Discussions with OCFO indicated that upgrades to the Agency's financial tracking cystem are not intended to specifically address the tracking of training-related costs. However, the system capabilities will allow for easier manipulation of the data and will accommodate compiling data about these areas, if requested.

Recommendation:

• Integrate the budget for all training-related activities to ensure that the Agency can monitor, prioritize, and control the use of training funds to develop and maintain staff competencies.

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3 Tasking Area 3: Assessment of the processes used to establish training programs and training requirements.

Related Characteristic: Training should be focused on developing and maintaining skills specifically related to supporting the Agency's mission and the impact of training on job performance should be-monitored.

The opinions about the quality and quantity of training ranged widely. Interview and survey results indicate that many managers believe that budget cuts over the last several years have severely hampered the Agency's ability to train and develop staff on burrent and developing skills and concepts and have mostly eliminated the Agency's ability to conduct training in support of future needs. Some managers feel that there has not been an emphasis on training for the future as evidenced by the fact that they have not been asked to provide information on long term training needs based on current and projected Agency goals.

Interview results suggest that some respondents view overall management of staff training activities as disorganized, disconnected, and somewhat inefficient. This view was supported by some survey responses noting that, in many cases, required training that is not part of formal qualification programs seems to impart broad information, not job-specific skills. Of particular note was the lack of specific training designed to prepare many of the NRC staff to effectively fulfill their responsibilities as a regulator.

Others felt that many courses that are not part of formal qualification programs, but that they are still required to attend, do not appear to be directly related to skills needed for their specific job.

There were indications that, with the exception of some knowledge and skill validation procedures within formal qualification programs, employees can rarely avoid training even when they possess the skills or knowledge: that is, existing qualification are not considered when courses are required by the training Manual Chapters for inspectors and license reviewers. Some nf the respondents noted thet there is overlap among refrateri courses, which may result in inefficient and ineffective learning of key skills. Additionally, some inJicated that : raining, with the exception of that for inspectors, appears to be a very low priority. This may be due to the fact that most positions, other than inspectors and a few otherjob classifications, do not have documented formal l qualification programs. This is an issue that was also raised during an Executive Council briefing on the training review effort. The managers also noted that current training programs do not adequately orient and indoctrinate Agency staff to management philosophy and expectations related to performing their regulatory function.

The 1TD White Paper titled " Regulatory Skills Training integration Plan" was developed at the <

EDO's request and provides a number of recommendations for tetter integration of regulatory knowledge _ skills, and abilities into the technical training and qualification program to improve the regulatory skills of the technical staff. The paper outlines proposed revisions to the current program and provides a list of the knowledge and skills each of the revisions is intended to address.

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i Recommendations:

• Improve the processes used to approve, develop, and implement training ensuring: the use of a standcrdized, systematic approach to determine what training is needed as well as to determine the appropriate training audience; the use of objective criteria to obtain approval for making training a requirement; and the involvement of Agency training professionals to guide key phases of training development and evaluation.

Review, eva.luate, and fermalize staff training activities, including those proposed in the

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• Regulatory Skills Training integration Plan," using a standardized, systematic approach to the training process to ensure acquisition and maintenance of regulatory, technical, professional, and management skills, as appropriate, for job positions and functions in support of the Agency mission and goals.

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Tasking Area 4: Assessment of the process for evaluating training effectiveness and review policy, procedural, and organizational options to improve j training effectiveness and efficiency. l Related Characteristics: The transfer of leaming from training to job performance should be I monitored and evaluated formally and on a regular basis and the evaluation information used to modify training requirements to maintain a focus on ensuring long term Agency success.

Location of training centers should support efficient use of training resources.

One view documented in the surveys was that the cumulative Agency training activities do not

) consistently and effectively produce job performance improvements. This is made more i

significant by the observation by some staff that the Agency is not aware of lack of expertise.

Supervisors not understanding their role in developing their employees based on the needs of the organization was cited by managers as a possible reason for the lack of staff expertise. Many managers also noted the lack of a formal methodology for monitoring and evaluating the success of learning. Discussions with Agency training providers revealed that ~they believe that formal l qualification requirements should be developed and implemented using a standard training management process that incorporates needs analysis, design and developmer't of training based .

on clearly defined needs, implementation of training using methods and techniques best suited to meeting the defined needs, and ongoing evaluation of staff performance to ensure the effectiveness of training.

, Two issues related to training facilities were brought up a number of times in the surveys and I

interviews. The issues were the need to maintain multiple training centers and the need for multiple simulators. The desirability of maintaining multiple training facilities was questioned. The overwhelming opinion was that training should be presented at a location that is as close as possible to the majority of the students whenever possible. Most noted that to the extent practical, 4 out-of-town travel should be minimized. This is, in fact, the case to a large extent since only 45%

1 of Agency technical training courses are actually conducted at the Technical Training Center.

l Technical training not dependent on special facilities or equipment at TTC or a contractor facility is provided at the location having the majority of the students.

The fact that the TTC is located in Chattanooga was a topic in many interviews. Many managers and Regional Administrators noted that the remote location of the TTC is considered a disincentive

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to having staff attend training that is held at TTC. Many managers noted that even if it were to I cost more to present training if the TTC were locate.d at Headquarters, the move should be made I

since they believe it would result in a greater willingness of the staff to request technical training and of managers to send staff to training. Additionally, it was opined that some increased costs would be offset, at least in part, by reduced travel time and travel costs for some staff. Some of the managers noted one of the benefits of having training in a remote location is the inability of trainees to be recalled by their managers (i.e., students are out-of town). However, many of the managers noted that a very strong Agency commitment to avoid disruptions during training, regardless of the location, except for extreme cases, may eliminate that benefit. Some managers noted that locating the TTC near Headquarters would allow for greater opportunity to use recognized Agency technical experts in training of technical staff. Additionally, it would allow for 11

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t the efficient and effective communication of Agency philosophy and policy by actively involving Agency managers in the orientation and qualification processes.

Opinions were also obtained regarding to what extent managers felt that technology specific simulator training was needed. Most managers indicated that the technical knowledge of the staff was extremely valuable. However, they also noted that specific reactor-type simulator training was not needed for NRC staff to be successful as inspectors and regulators. Some managers noted that training should be more focused on the regulatory aspects of inspector performance rather than the technical aspects. While the existing simulator courses have some focus on regulatory skills needed by reactor operations inspectors, the current inspector qualification program is structured such that the preponderance of regulatory knowledge and skills are expected to be attained during self study and on-the-job training portions of inspector qualification requirements. The Director, NRR, and all four Regional Administrators stated that they believed that the number of simulators could be reduced without reducing the ability of NRC staff to conduct inspections.

The TRG was provided two documents related to simulator discussions that occurred during the FY 2000 budget reviews with the Program Review Committee and Executive Council. These two documents issued by the AEOD Director were titled ' Additional Simulator Information and Alternatives" and "Reclama of Preliminary Decision To Dispose of GE BWR/6, CE and B&W Simulators." While these documents provide many insights, which may not be known by those interviewed, the opinions expressed by NRC Office Directors and Regional Administrators support the recommendations below.

Recommendations:

- Use Agency training professionals to revise Management Directive 10.77

• Employee Development and Training" to delineate and require a standard, systematic approach to the training process for need determination, approval, development, implementation, and evaluation of all Agency training activities.

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. Consolidate Agency training resources in the Washington area.

+ Reduce the number of simulators to 1 BWR and 1 PWR.

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• Recommendation Summary:

Based on the information obtained from surveys, interviews, and Executive Council briefings, the i Training Review Group has the following recommendations to provide a greater likelihood of l success for the Agency training function. Each of the recommendations reflects the overall opinion of the group that was surveyed and interviewed as part of this study. None of the toples received exhaustive review. Therefore, the TRG believes that the recommendations contained in this report should be weighed against other more indepth studies that have been done or may be done in the futuere to determine the extent to which these opinions and recommendations may sitter the outcome of the studies.

1. Combine existing providers of formal training into a single organization, reporting to a single .

Deputy EDO, with the responsibility and authority to effectively manage the Agency's training ~

function.

2. Integrate t'he budget for all training-related activities to ensure that the Agency can monitor, prioritize, and control the use of training funds to develop and maintain staff competencies.

. 3. Improve the processes used to approve, develop, and implement training ensuring; the use of a standard, systematic approach to determine what training is needed as well as to determine the ,

appropriate training audience; the use of objective criteria to obtain approval for making training a j requirement; and the involvement of Agency training professionals to guide key phases of training development and evaluation.

- 4. Review, evaluate, and formalize staff training activities, including those proposed in the

" Regulatory Skills Training Integration Plan," using a standard, systematic approach to the training process to ensure acquisition and maintenance of reCulatory, technical, professional, and management skills, as appropriate, forjob positions and functions in support of the Agency mission and goals.

5. Use Agency training professionals to revise Management Directive 10.77 ' Employee Development and Training' to delineate and require a standard, systematic approach to the training process for need determination, approval, development, implementation, and evaluation of all Agency training activities.

6. Consolidate Agency training resources in the Washington area.

7. Reduce the number of simulators to 1 BWR and 1 PWR.

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g3 t. UNITED STATES i L e i S NUCLEAR REGULATORY COMMISSION i I WASHINGTON D.C. 306664001 ~ i

\*****.) March 17, 1998 l

l MEMORANDUM TO: JackW. Roe, Acting Director Division of Reactor Program Management Office of Nuclear Reactor Regulation ,

FROM: L Joseph Callan, Chair d i Executive Council TJ

SUBJECT:

TRAINING ACTIVITIES l l This memo is to assign to you the task of reviewing the agency's training activities. A team comprised of individuals not directly involved with the agency's training function has been established to assist you with the review. The team consists of Mary Ann Biamonte from NRR;  !

. Susan Shankman, Cindy Jones, and Pat Rathbun from NMSS; Kitty Thompson from RES; and Caudie Julian from Ril.

4 The team's review of the training activities should be aimed at identifying ways to improve both

! the effectivenes.s and efficiency of the agency's overall training function in preparing the NRC staff to perform their duties. To that end, the review should include:

. . identification of all technical and non-technical training provided by AEOD/TTD, HR and others.

The total average annual cost of training (both staff and contractor support used to provide training and the time spent by staff to attend training).

. The processes for approving the establishment of training programs and requiremants,

! consideration of the impact and cost of planned training and prioritization of training.

. The processes for evaluating the effectiveness of training provided.

. The adequacy of planning for training to address future agency needs (e.g., changing demographics, core capabilities, changing missions).

. Policy, procedural and organizational options to improve training effectiveness and efficiency. _

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Attachment 1

f The team should be prepared to provide monthly briefings to the EC on your progress. The EC will expect to discuss the team's interim recommendations within 4 months. A formal briefing of the EC to present the fina11aam recommendations will occur within 7 months.

Your point of contact whhin the Executive Council is Pat Norry.

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FY 1997 Ectim*.ted Agency Costs for Training Activities , d Contract Other Related NRC Training Student FTE Costs to Course Area instructor Costs Costs Staff Costs .Traming Hours Attend Traming' Total Costs TTD

ReactorTc-Gi4y -

$1,300,000 $ 850,0002 24,700 14 FTE TTD Specialized TechnicalTraining $700,000 31,000 17 FTE TTD TTD Rent $950,000 ,

TTD Support Costs * $ 430,000 i TTD 31 FTE TOTAL $2,000,000 $ 2,230,000 $ 3,000,000 55,700 $ 3,200,000 8 $ .10,500,000*

HR ExternalTraining* $ 1,900,000 57,000 31 FTE i HR in-house Courses 31,300,000 95,000 53 FTE ,

t HR TOTAL 84 FTE

$3,200,000 $ 500,000' 152,000 $ 7,500,000 $ 11,200,000 i TTDlHR Travel costs' . $ 1,800,000 $ 1,800,000 '

R:gional RegionIOffice 3 End Office sponsored  ;

Training training, self-Costs' study or OJT $ 100,000 110,000 61 FTE ' $5,400,000 176 FTE i Agrncy TOTAL $ 5,300,000 $ 4,800,000 $ 3,500,'300 318,000 $ 15,700,000 $ 28,900,000 ATTACHMENT 2 i t

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1.1 FTE = 1800 hours0.0208 days <br />0.5 hours <br />0.00298 weeks <br />6.849e-4 months <br /> .

2. Contractor support for simulators. This inc!udes significant one time costs in FY 1997. A more representative number for -

simulator contract support is the FY 1998 budget value of $570,000.

3. Includes costs for binders, printing, and other course related support costs.

4. TTC Staff Salary and Benefits Estimate = $ 103,000 per FTE (30 FTE)

5. Salary and Benefits Estimate for trainees at technical training courses - $ 103,000 per FTE

6. Contains individual extemal training, management development training and graduate fellowship training.

7. HR Staff Salary and Benefits Estimate = $ 74,725 per FTE (6 FTE) ,

8. " Travel Costs" are for student travel and per diem costs to attend courses, regardless of location.

9. Costs in addition to those reported by HR and TTD

10. Includes FTE assigned for coordination of training activities. Uses Ave. Salary and Benefits Estimate = $ 88,862 / FTE

a. These resources are primarily devoted to implementation of formal qualification programs for technical staff.

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