ML20199A744

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Provides for Commission Consideration & Endorsement of Staff Actions to Address Specific Guidance & Info Requested in COMSECY-96-054 on NRC Relationship W/Agreement States
ML20199A744
Person / Time
Issue date: 11/28/1997
From: Callan L
NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:
References
SECY-97-275, SECY-97-275-01, SECY-97-275-1, SECY-97-275-R, NUDOCS 9801280076
Download: ML20199A744 (65)


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P.OLICY ISSUE (Notation Vote)

November 28, 1997 SECY-97-275 EQt: The Commissioners Ernm L. Joseph Callan Executive Director for Operations Sublect GUIDELINES FOR PROVIDING ASSISTANCE TO AGREEMENT STATES AND ALTERNATIVES FOR TRAINING Puroose:

To provide for Commission coi sideration and endorsement of staff actions to address the specific guidance and information requested in COMSECY-96-054 on NRC's relationship with the Agreement States.

Backaround:

The Commission has considered the issue of NRC funding of Agreement State training, travel, and technical assistance since 1995 through SECY-95-017, SECY-95-192, and associated Staff Requirements Memoranda (SRM). The Commission directed that this issue be incluoed under Direction Setting issue 4 (DSI-4), "NRC's Relationship with Agreement States." The Commission released its preliminary view on DSI-4 on September 16,1996 and the final Commission's direction to staff was issued March 19,1997 as COMSECY-96-054. The staff addressed the criteria for funding of Agreement Stste training, travel and technical assistance in SECY-97-183 dated August 7,1997. The two additional items from COMSECY-96-054 to be addressed in this paper are:

1. Staff should develop guidance for offenng assistance to States on a case-by-case basis that would help the States' agencies identify and clarify their training needs to their appropriate autr.orities, e.g., the State Cabinet Secretary or legislative body. NRC should be prepared to offer such help (e g., a letter) if requested by the Agreement State; and .

Contact:

Dennis M. Sollenberger, OSP NOTE: TO BE MADE PUBLTCLY AVAILABLE (301)415-2819 WHEN YHE FINAL SRM IS MADE AVAILABLE John Ricci, AEOD (423) 855-6514 ,i 9901200076 971128 Illl(IHI ilWlpli 1 l' PDR SECY 97-275 R PDR ~

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2. Staff should also examine cost-effective attematives for providing training and technical assistance to Agreement States. The staff should provide the Commission with a report on available attematives and recommendations for assuring that NRC training and technical assistance are provided in a cost-effective manner.

Discussion' Assistance to States The staff developed the following guidance for offering assistance to States on a case-by-case ,

basis that would help the States' agencies identify and clarify their training needs to their appropriate authorities, such as the Department Director or legislature. The guidance to be used by staff includes background information explaining the previous and current NRC policies for funding of Agreement State training and associated travel. In addition, the guidance has the

-following major points.

  • The NRC staff is prepared to send a letter to the appropriate level within the State management organizc tion or legislature to cianfy the State's responsibility and the need for adequately traincd/ qualified staff. A letter would be sent as requested by the Radiation Control Program Director or other higher level management.
  • The State as an Agreement State is responcible for maintaining sufficiently trained staff to carry out their Agreement Staite program. Resources for training, including funds for tuition and out-of State travel, if necessary, should be a part of the budget for the radiation control program.
  • The training and qualifications of the Agreement State program staff will be evaluated as part of the Integrated Materials Performance Evaluation Program (IMPEP) review process.
  • The NRC/ Organization of Agreement States (OAS) Training Working Group has prepared a model for a training / qualification program which will be sent to the Agreement States for their use. The NRC will encourage the Agreement States to document such a program so that there is a systematic approach to the training / qualification program.
  • The NRC staff may be requested to make a presentation to the State's management or legislature. Any such requests would be evaluated on a case-by-case basis and the Regional staff (State Liaison or Agreement State Officers) would normally make these presentations covering the material described above.

The Commissioners This guidance, together with an example draft letter, will be finalized in an Office of State -

Programs (OSP) Internal Procedure subsequent to Commission review.

Technical Assistance The staff has evaluated the cost effectiveness of current guidance for providing technical assistance to Agreement States and has concluded that cost effective practices are currently in place. Management Directive 5.7, " Technical Assistance to Agrriement States," was issued in 1995 and identified the various types of technical assistance. In accordance with that guidance, the routine programmatic and technical assistance will continue to be addressed on a cost-free basis through telephone, email, letters, and docume .t transmittals. The "special technical assistance"(direct licensing or inspection technical assistance, including use of an NRC technical assistance contractor specif)cally to assist an Agreement State) will be evaluated on a case-by-case basis and would be cost reimbursable. The staff has not budgeted for this "special techr'ical assistance" effort given the recent history of several years with no such requests.

Cost Effective Training The NRC, at the request of the OAS, established a joint NRC/OAS Training Working Group (WG) which consisted of three NRC staff and three OAS representatives. The report is attached (Attachment 1) and the WG pruented the final reprt at the Ali Agreement States meeting October 16-18,1997. The report was formally submitted to NRC and the OAS on October 16,1997. The charter for the WG (see WG report) called for the WG to perform the following tasks:

1. Evaluate training courses and training subject areas for the Agreement State staff that are necessary to assure equivalency with NRC requirements and forward a recommendation to the OAS and the NRC.

The work in progress was presented at the 1996 All Agreement States meeting. The draft model program was sent to the States for comment in June 1997. The ,inal WG recommendations are in the attached WG report.

2. Evaluate the NRC policy for passing /failing courses and determine an acceptable policy and methods to implement a policy for the Agreement States.

The draft position was presented at the 1996 All Agreement States meeting and the final position (consistent with NRC practice) was sent to the Agreement States by All Agreement States letter dated November 20,1996 (see WG report).

3. Identify acceptable attemative training options, including the evaluation of technology and training methods that could be used to lower the cost of NRC training courses.

The Commissioners The WG met cnd evaluated the advantages and disadvantages for attemative methods of presenting NRC courses (see WG report). In addition, the WG identified options other than the NRC training program. These are 'isted in the WG report and are identified below.

Several alternatives to current NRC training are: (1) Regional training conducted by NRC, a contractor, or a group of State instructors; (2) agreements with local universities and colleges; (3) enhanced on-the-job or in-house training; (4) other methods of delivery of the NRC training; and (5) commercially available courses that meet the training objectives.

The WG examined potential attematives for providing NRC training for Agreement States. The WG focused initially on attemative methods of delivery of the current NRC training courses.

The major methods were: (1) Traditional Classroom: (2) Non-Traditional, Live Interactive Training (Video Teleconferencing, Interac'ive Video Teletraining, Audio To5conferencing (Audiographics Enhancement)); and (3) Non-Traditional, Self-Paced Trainirig [ Computer Based Training, Audio Tapes or CDS, Video Tapes, Intemet/Intranet Web-based Training, Printed Material (Self Study Manuals), or combinations of these media). These methods are defined and the advantages and disadvantages for each r.iethod are presented in the WG report.

The primary costs for altemative methods are:

  • Course material conversion
  • Trainer training and practice given the media selected
  • Media presentation developmerd (video / audio tapes, scripting), for some methodologies
  • Equipment purchase / rental / scheduling and technical support for NRC/ States, for some niethodologies To develop materials for presentation using the newer electronic media, the references recommend that a team of professionals be assembled. For videoconfemncing, this team would need to include course topic technical specialists, training specialists, and communications specialists while for other methods such as Computer Based Training (CBT) the team would need to include Programmers and Content Experts, Interface Designers, Writers, Editors, Researchers, Graphics and Sound Professionals and Animators and Video Professionals.

The WG discussed wl. ether technical courses would have the potential for modification for presentation using electronic communications or self-paced training. The general criteria used by the group were:

  • The course is mainly lecture presentation.
  • The course does not require field trips or extensice small group interaction.

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e. 1 The course length.should be relatively short or the course should be amenable to being

- broken into modules for presentation.

' The seven courses which potentially satisfy these criteria are identified in the WG report. As is -i

- evident,- only a very small fraction of the total courses meet these basic criteria. Of these .

seven, two have restrictions that must be addressed and two others are not routinely; scheduledc Staff has reviewed the WG report and concludes that videoconfo,encing, in

- particular, is not a good option for technical training provided to Agreement States because:

(1) the majority of the courses require special facilities, equipment, and/or field trips;

. (2) Agrooment State training courses are a week or more in length, making it difficult to hold F . student attention in a videoconference format; and (3) Agreement States do not carently have ,

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'the videoconferencing equipment to support reception of the training Additionally trairing courses presented using other non-traditional methods must be further evaluated to determine

' .if limitations imposed by the altamative training method could compromise the effectiveness of 5

=the training. - Although not directly related to or limited to Agreement State training, the Chief Information Officer will coordinate with other offices to assees whether there is a business case for future investments to support expanded use of videoconferencing-based training or other ,

p information technology to support training. The WG report will be reviewed as part of this -

'3 overall coordination.

n Attachment 2 contains additional information developed by the staff on attemative training  ;

methods,-evaluation of those methods, and training cost / cost effectiveness information.

Although it is evident from the research done to date that there are few if any organizations using techniques such as videoconferencing for week-long technical / professional training, several ventures into distance leaming techniques including Self Study and CBT have already been initiated by the staff for multi-day training courses and others will likely follow. The courses involved include Fuel Cycle Courses, Site Access Refresher Training,' Power Plant Engineering and possibly Fundamentals of Inspection Refresher. FY 1998 materials resources in support of conversion of fuel cycle curriculum (consisting of 8 distinct courses) to directed self r _ study amount to a one time e_xpenditure of $142,000. Another one time expenditure of L $250,000 is directed to the development of computer based enrichment facility information software that will benefit NRC Headquarters and Regional staff. For FY 199g, a one time axpenditure of $200,000 in budgeted for initial development of a fuel cycle course in a directed self study format. Approximately 0.2 FTE is dedicated to these efforts in each fiscal year. In t addition, approximately 0.1 to 0.2 FTE in FY 1998 and FY 1999 are engaged in research and evaluation of training needs wnich includes assessment of the feasibility of course conversion.

_ Although these courses are not directly related to the Agreement State cuniculum, they will <

provide a valuable foundation for evaluating feasibility and effectiveness of sons of the m distance loaming methods under consideration'.

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- The distinct advantages and disadvantages of each method of training presentation by NRC, i particularly resource implications, roust be considered in any decision to proceed to implement - I

- any specific methodology or combination of methodologies. Therefore, the staff concludes that '

the optimal solution at this time is to continae with the traditional classroom teaching .

environment for NRC traininc with Agreement States always having the option to use other training altematives. None of the Agreement State courses are planned for conversion at this time. ]

The staff will contioin to assess the feasibility of cource conversion to altemate delivery raethods, balance cw against savings and determine whether the not savings payback I

.warrants the use of r!temative delivery methods. At this time, the NRC's costs for course  :

Econversion far exceed any projected savir'gs.

The staff will continue its associaUon with organi.tations such as the American Society for j

, 1 Training and P eelopment (ASTD) to ensure that current information is'used in decisions

* .regarding cor usctiveness of training and to gain insights into the continual!y evolving process q of adapting dlw,nce loaming techniques to NRC training.

Recommandations: j The staff recommends that the Commission:

. Endorse the sWI's approach including (1) corit;nuation of research and evaluation of emerging training technobgies, and (2) coi..'arsion of selected courses or portions of courses to al'emate ,

methodologies where effectivene is and efficiency warrant.  ;

Baapurces-The budgeted resources for FY 1998 and beyond are sufficient to continue the classroom format for technical training presentatiott AEOD's FY 1998 budgeted resources for matedals technical training include $477,430 and 1,8 FTE in support of Traditional Classroom Training _ '

r . avaikhle to NRC and Agreemorit State staff. For FY 1999, the amount is $498,202 and 1.8 FTE. in addition, the OSP budget includes 0.6 FTE for course coordination with the Agreement

' States that includes course notification, selection of State students, distribution of course -

l certificates to the States and providing input on course content to AEOD, and $150,000 for:

i travel of sqreement State stcff to attend these courses. -

The current budget includes resources for some limited research, evaluation, and conversion activities that have no direct applicability to the Agreement States at this time. These resources and their pctercial impact on Agreement State training were discussed previously.

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Coordination-

The Office of General Counsel has no legal objection to this paper. The Office of the Chief-

- Financial Officer has reviewed this Commission papar for resource implications and has no -

objection. The Chief Information Officer has no objection to the material related to information

. technology discussed in this paper, L. soph Callan  :

Executive Director for Operations Attacnments:

- 1. NRCIOAS Training Working Group Report

2. Cost Analysis Information

- Commissioners' comments or consent should be provided directly to the bidace

- of the Secretary by COB Tuesday, December 16, 1997.

Commission Staff office comments, if any,'should be submitted to the Commissioners NLT Tuesday, December 9,1993 with an information copy to the- Office of the Secretary. If the paper.is of such a nature that it requires additional review and comment, the, Commissioners and the Secretariat should be apprised of when i comments may be exptcted.

- DISTRIBUTION:

Commisstoners OGC-OIG OPA OCA CIO-CFO . -

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- REGIONS B . SECY.

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0 REPORT NRC/OAS TRAINING WORKING GROUP ATTACHMENT 1

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ACKNOWLEDOMENT The NRC/OAS Training Working Group would like to thank NRC's Office of State Programs, Office for Analysis and Evaluation of Operational Data, and Office of Nuclear Material Safety and Safeguards, and the OAS States ofIllinois, Texas, and Utah for their assistance by allowing the Working Group members the time to particiste in this group effort. We thank the Office of State Programs for the funding support for the travel of the State Working Group members as well as hosting several of the meetings. We also thank the Technical Training Center (TTC) for hosting a meeting and the assistance of Rod Reed and Paul Knapp during that meeting. A special thanks to William (Bill) Silva and the State of Texas for his participation and assistance in the TTC meeting. We appreciated the input from the NRC and Agreement State staff that provided comments on the work in progress and the final report.

The Co-Chairs of the Working Group would like to thanx all the Working Group members for their input and assistance in making this effort successful.

Dennis M. Sollenberger Kathy Allen Co-Chair, NRC representative Co-Chair, OAS representative li

TABLE OF CONTENTS

- Acknav iedgment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Li Table of Contents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iii Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

- Methodology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 Comparison of NRC and Agreement State Training Categories . . . . . . . . . . . . . . . . 2 n, s Elments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 Summary of Basic and SpMaH=I Training For Agreement State Personnel . . . . . . . 3 Successful Completion of NRC Training Courses . . . . . . . . . . . . . . . . . . . . . . . . . . 4 Training Alternatives ............................................ 5 Appen.lices .

Appendix A, Final Charter, Joint NRC/ Agreement State Working Group to Evaluate Training for Materials Licensing and Inspection . . . . . . . . . A-1 Appendix B, Comparison of Courses / Subject Areas _ . . . . . , , . . . . . . . . . . . . . . . B-1 Appendix C, Essential Elements for Certain Training Areas . . . . . . . . . . . . . . . . . C-1 Appendix D, Sample Agreement State Training PoEcy Statement and Training Qualification Form . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . D-1 Appendir E, All Agreement State Letter (SP-96-118) on Successful Completion of NRC Training Courses . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . E-1 Appendix F, Training Alternatives for Technical Course Presentation . . . . . . . . . . F-1 4 1 1.

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INTRODUCTION j At the request of the Organization of Agreement States (OAS), a Working Group was .

established by the Nuclear Regulatory Commission (NRC) to evaluate the ongoing evolution of '

training programs for Agreement State personnel, the criteria for evaluation of Agreement State prot, rams in the area of training qualification, and the possible training options for Agreement State personnel. The Working Group consisted of three representatives from the NRC and diree representatives from Agreement States. The chaner for the Working Group is presented in Appendix A.

This document includes recommendations for establishing and documenting training programs and provides guidance for determining content of indivhl training courses. In addition, this document contains an appendix of alternative training options, and pros and cons for these options.

METHODOLOGY In order to ensure consistent staff training levels among Agreement States and between the NRC and . Agreement States, the NRC had providad funding for Agreement States to attend training courses developed by, or contracted for the NRC. When the NRC withdrew funding for these training courses, another mechanism was needed to guarantee consistent staff training levels in Agreement States. The Working Group therefore used the NRC's existing training program as the starting point for establishing guidelines for use by Agreement States.

1 For NRC inspectors and license reviewers to become " certified" by the NRC, they must complete the Core and Specialized training detailed in NRC's Inspection Manual Chapter 1246 (IMC 1246), " Formal Qualification Programs in the Nuclear Material Safety and Safeguards Program Area " An inspector or license reviewer who has not completed all of the requirements for certification may be approved under " interim" qualifications. The NRC has defined its training program and developed a very detailed Training and Qualification Journal that must be completed for each inspe: tor and license reviewer.

- Recognizing that Agreement States may not have the same task divisions as the NRC, and recognizing that the nuniper of inspector or license reviewer positions in an individual

- Agreement State may not warrant the development of extremely detailed qualifying procedures, the Working Group is proposing the following approach to training of Agreement State ps.vunel:

1._ Agreement States should develop lists of positions imd basic training requirements for those positions, and

< 2. . Agreement States abould develop some method to sign-off en completed areas of training. -(Some of the training requirements may be included in the requirements for hiring into tlw position.)

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The Working Group prepared a comparison of the training requirements in IMC 1246 based '

on the t-alaing categories prest.nted below. The comparison of NRC courses to subject areas .

needed for Agreement State staff training qualification are presented in Appendix B.

' Appendix C contains outlines for several NRC courses where the Working Group evaluated  :

the course content and developed the essential elements for that coutw. The essential elements posentation also identifies the level at which this information should be taught so that a State -

manager may be able to evaluate a training course for use in qualification of his/her staff. The Working Group did not evaluate all of the NRC courses due to time limitations. However, the NRC is providing a copy of its training marmals to the Agreement States for their use if they choose to develop their own course or evaluate other commercial sources.

COMPARISON OF NRC AND AGREEMENT STATE TRAINING CATEGORIES NRC Training Categories Agreement State Training Categories Core Training - Basic Training -

Minimum formal classroom and on-the-job Minimum formal classroom or on-the-job training required for a specific inspector or training required for a specific inspector or _

license reviewer. license reviewer.

1 Specialized Training _ Specialized Training - l Additional training beyond core, necessary Additional training necessary for categories 1 l

for certain licensed categories of use of of radioactive material uses (such as i radioactive materials. medical, radiography, well logglig, etc.).

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Supplemental Training - Advanced Training -

f Additional training used to enhance Additional training used to enhance revsewer's or inspector's expertise. reviewer's or inspector's expertise. l l

Refresher Training - Continuing Educatian -  ;

i Training designed to update and maintain Cominuing education designed to update qualification, and maintain level of proficiency. Methods used to accomplish this may include  !

l training courses, professional meetings, staff meetings, policy and guidance documents, newsletters, access to ,

1 professional journals or newsletters, etc.

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i e PROGRAM ELEMENTS The Working Group developed suggested program elements that could be used by the Agreement States to develop a training qualification program tailored for their program and fulfilling the overall objective of having staff meet minimum qualification requirements that provide for a national consistency in the regulatory program.

The Agreement States shoold document a training program that, at a minimum, contains a statement of policy, minimum qualifications for staff training, and supervisory responsibility for ensuring this policy is implemented. A sample training policy statement and a sample staff qualifications form with supervisory sign-off are included as Appendix D. A generic form

^ could be developed or a customized form for each individual could be used.

SUMMARY

OF BASIC AND SPECIALIZED TRAINING FOR AGREEMENT STATE PERSONNEL Each individual State would establish or maintain lists of positions and the areas of training to be provided for those positions. States should establish a sign-off system to track when training is provided. The following training areas are recommended for license reviewers and inspectors.

BASIC TRAINING AREAS:

m Essentials of Health Physics - This is the minimum amount of health physics training necessary to perform effectively. Any of the following methods can be used to establish this minimum training:

B.S. degree or other advanced degree in health physics; or B.S. or B.A. degree with equivalent training and experience in health physics; or Successful completion of the 5-week health physics course; or A training program that adequately covers the topics covered during the 5-week health physics course, m Overall Program Orientation - This includes a description of the State radiation program, a State Regulations - This may in:lude information such as delineation of responsibility for development and interpretation of State regulations, m Available Regulatory Guidance, Procedures, Resources 3

i s . Essentials of performing specific job functions:-

For license reviewers, this includes performing license reviews according to the State's procedures and an overview of the function of inspectors.- ,

For inspectors, this includes training in performing inspections according to the State's procedures and training in trr.nsportatiori of radioactive materials.-

SPECIA1.17FD TRAINING:-

Various subject areas would be covered with the license reviewer before being assigned responsibility for reviewing the corresponding types oflicenses. In addition, various subject areas would be covered with the inspector before being assigned responsibility for working as the lead inspector for the corresponding types oflicenses. Each Agreement State is responsible for ensuring licensing and inspection coverage for all types of licenses issued by the State.

ADVANCED TRAINING: .

This includes training that may be provided to certain individuals'in order to expand or develop an area of expertise.

EQUIVA? FNCY Agreement State Program staff may demonstrate proficiency in a program oi subject area by:

Successfully completing an NRC course; or Passing a "saaning" or " challenge" examination; or Demonstrating an appropriate level of expertise in a particular subject area to management, because of training and experience; or Successfully completing training that covers the essential elements for a particular ,

subject area, as identified by the Working Group.

SUCCESSFUL COMPLETION OF NRC TRAINING COURSES The Working Group reviewed the NRC practice for successful completion of training for NRC employees attending the materials training courses offered by the NRC. The Working Group reviewed the proposed practice to be applied to Agreement State personnel and prescated the -

practice at the September 1996 All Agreement States meeting. Comments on the practice were requested. . Following the meeting, the practice for successful completion of ".C training 4

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courses by Agreement State staff was sent to the States by All Agreement States letter (SP-96-118) dated November 20,1996 (Appendix E).

TRAINING ALTERNATIVES 1

, The Working Group was tasked with identifying alternatives for receiving training that were to include alternatives to traditional classroom training prograrra. Below is a list of courses resources, and other options that cousd be used to gain the imowledge needed to regulate radioactive materials. Appendix F to this report is a list of alternative training presentation methods that the Working Group considered for delivery of the NRC training courses.

Appendix F includes the advantages and disadvantages identified by the Working Group for the different alternatives, i COURSES s Commercially available training courses (Government, Universities, National I. abs, Private Companies, and others).

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- NOTE: National organizations, such as the Health Physics Society (HPS) may have a list of available courses, a Training courses provided by other government agencies (such as EPA or HHS).

e Contractors willing to develop a course to meet specific needs, a Regional training - share costs of developing training courses or videos among several States.

OPTIONS OTHER THAN COURSES e In-house training programs, m:ntoring and on-the-job training.

a Computer-based training currently available.

e Professional topical or annual meetings (AAPM, HPS, ANS, AS/NRC workshops, etc.).

m - Videos that are currently available.

- NOTE: Tine NRC and some Agreement States have collections of videos.

HPS has a collection of videos from PEP courses,

s. Supplement in-house training with site visits to licensed facilities.

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s a Check the world wide web for new websites that may contain information to supplement training, or may have information on other training resources.

's " Audit" manufacturer's training courses.

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Appendix A i

Joint NRC An.-:= -; State Working Group To Evaluate Training for Materials Licensing and Inspection Final Charter

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P11RPOSE A working group consisting of representatives from the Nuclear Regulatory Commission (NRC) and the Agreement States has been formed to evaluate th: ongoing evolution of tra' ming ,

programs for Agreement State personnel, the criteria for evaluation of Agreement State programs in the area of training qualification, and the possible trai' ling options for Agreement State personnel.

BACKGROUND By letter dated November 14,1995, Mr. Richard Ratliff, Chair, Orgr.nizadon of Agreement States (OAS), presented OAS concerns to the NRC including concerns in the area of training and requested that an operational committee or workiry group be established to consider identification of core courses, identification of additional training requirements for Agreement State personnel, and identification of acceptable alternate training options. The NRC responded to the letter on December 28,1995, agreeing to the proposal ta establish a working group to address the training issues of the OAS.

Over the last several years the training program conducted by NRC for Agreement State personnel has gc,ne through an evolution in which the training developed and conducted for Agreement States has been merged with tM training program for NRC staff. The overall coordination of this combined program is toe responsibility of the Technical Training Division (TTD). Office for Analysis and Evaluation of Operational Data (AEOD).' Other NRC offices and Regions provide input to the course content and training needs. The Office of State Programs has collected and provided input on the Agreement State training needs.

The NRC has recently revised its training requirements for materials licensing and inspection staff. The requirements are now in one document, NRC's Inspection Manual Chapter 1246.

The NRC has proposed that the Agreement State' staff meet similar training requirements and that the Agreement State radiation control program directors formally establish staff qualification criteria and document that staff are qualified to independently perform work as they complete various training levelsc The qualifications and traicing of Agreement State personnel have also been identified as one of the co'nmon performance indicators under the

- Integrated Materials Performance Evaluation Program (IMPEP) for evaluaticg Agreement .

State and NRC Regional materials regulatory programs. Specific criteria to ted-k this i evaluation are needed to ensure uniformity for this program. This proposal was presented at the October 1995 All Agreement States meeting, which resulted in the above referenced letter from the OAS.

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'Ihe Commission will discontinue the funding for Agreement State staff travel and centractor costs associated with Agreement State staff training beginning in fiscal year 1997,' This action has prompted Agreement States to investigate alternate training methods to those made available by the NRC, - The working group will not address the funding issue but will r.ddress possible alternate training methods. i KOPE OF WORK The NRC/OAS Training Working Group will address the Agreement State training issues as identified in the OAS letter of November 14,1995 and other issues identified to the group by -

OAS or the NRC.

IASKS In evaluating the potential training necessary for Agreement State personnel to have equivalent

. qualifications as NRC materials and inspection personnel, the Working Group will be performing the following tasks:

1. To evaluate the proposed training courses and training subject area'. for the Agreement State staff that are necessary to assure equivalency with NRC requirements and forward a recommendation to the OAS and the NRC.
2. To evaluate the NRC policy for passing /failing courses and determine an acceptabie policy and methods to implement a policy for the Agreement States.
3. To identify acceptable alternative training options, including the evaluation of -

- technology ana training methods that could be used to lower the cost of training Courses.

= WORKING GROUP ORGANI7ATION_AND OPERATIONS Initially the following personnel will be on the Working Group, s

NRC - Dennis Sollenberger, Office of State Programs Catherine Haney, Office of Nuclear Material Safety and Safeguards John Ricci.iKfice for Analysis and Evaluation of Operational Data

. OAS - Kathy Allen, Blinois Ikp=w of Nuclear Safety Marilyn Kelso, Texas Department of Health William Sinclair. Utah Department of Environmental Quality .

The Working Group selected Dennis M. Sollenberger and Kathy Allen to be co-chairs for the Working Group. .

,.p A-2 L - - . L .. , , _ , . - . -

4 The Worldng Group collectively will be responsible for developing a work plan, monitoring j progress, preparing drafts of minutes and other products. Logistical and travel support for Working Group meetings, including travel and per diem exgra; for Agreement State -

members, will be provided by NRC.-

1 Working Group meetings are not subject'.o the requisi-res of the Federal Advisory  :

Comminee Act (FACA) ht they will bc ==W in advance through the NRC Public  :

Meeting Annonent System. Maxhaum use will be made of other appropriate media for facilitating ir.teraction with the Workits Group, e.g., conference calls, facsimiles, and electronic mail. Working Group meetings will be open to the public and will be held in the Washington, DC area or other locations as agreed upon by the Working Group members.

Other persons attending Working Group meetings will be welcome to provide comments to the Working Group for its consideration in either written form or arally at times specified by the _ ,

Working Group co-chairs. Meeting minutes and draft and final documents produced by the

. Working Group will be publicly available from the NRC Public Document Room at the ,

4

. _ Gelman Building, 2120 L St.', N.W., Washington, DC 20037.

Gh J

3 4

1 A3

WORKING GROUP %FrMRRRS - COMMUNICATION INFORMATION Dennis Sollenberger dms4@nrc. gov (301) 415 2819 voice U.S. Nuclear Regulatory Commission (301) 415-3502 fax Document Control Desk PI-37 Washington, DC 20555 Attention: Dennis Sollenberger - OSP Catherine.Hanev exh@nrc. gov (301) 415-6825 voice U.S. Nuclear Regulatory Commission (301) 415-5369 fax Document Control Desk -

PI-37 Washington, DC 20555 Attention: Catherine Haney -IMNS Jnhn Rlerl- jltl@nrc. gov (423) 855-6514 voice U.S. Nuclear Regulatory Commission (423) 855-6546 fax Technical Training Division 5746 Mulin Road, Suite 200 Chattanooga, TN 37411 5677

, Auention: John Ricci rathy Alten k_ allen @idns. state.il.us (217) 785-9931 voice Illinois Department of Nuclear Safety (217) 7821328 fax 1035 Outer Park Drive Springfield,IL 62704 MarilynXcisa mkelso@brcl.tdh. state.tx.us (512) 834-6688 voice Texas Department of Health (512) 834-6708 fax Bureau of Radiation Control 1100 West 49th Street .

? Austin, TX 78756-3189 William Sinclair eqrad.baincial@ state.ut.us (801) 536-425.* voice Utah Department of Environmental Quality (801) 533 4097 fax Division of Radiation Control 168 North 1950 West P.O. Box 144850 -

Salt Lake City, UT 84114-4850 A4 H

Appendix B COMPARISON OF COURSES / SUBJECT AREAS au IMC 246 " Core" Training IN LI Agreement State Training IN/LI Inspection Procedures X X Essentials ofInspection IN - B Licensing Practice & Promi X Essentials of Licensing LI - B I

H.P. Technology (2 weeks) X X Advanced Health Physics AD Diagnostic & Therapeutic Nuclear X X Elements of Nuciar Medicine SP Medicine Teletherapy & Brachytherapy X X Elements of Medical Therapy SP Safety Aspects ofIndust. Radiog. X X Elements of Indust. Radiog. SP Transportation of Rad. Mat. X X Elements of Transportation IN - B Root Cause/ Incident Investigation X Elements ofInvestigations AD Inspect. for Performance (Mat.) X Effective Comm. for Inspectors X OSHA Indoctrination X Int. Dosimetry & W.B. Counting SP SP Safety Aspects of Well Logging SP SP Elements of Well Logging SP Irradiator Technology SP SP Elements of PoolIrradiators SP Env. Monit, for Radioactivity SP SP Elements of Env. Monitoring SP l

Air Sampling for Rad. Mat. SP SP Respiratory Protection SP Rad. Surveys - Decunmissioning SP Health Physics Topical Review R R Essentials of Health Physics IN/LI-B IN means inspectors, LI means license reviewers, B means basic training, SP means specialized training, AD means advanced training, R means refresher training i

B-1 l

t 4

t 4

l it AFPendix C f

d NRC/OAS TRAINING WORKING GROUP ESSENTIAL ELEMENTS FOR CERTAIN TRAINING AREAS d

f 4

r l'

l ..

i-i-

C. L,

.=_ _ _ . _ _ -- . _ _ . _ .

Beste Heskt *hysics Essential Elements

l. INTRODUCTION l l

1.1 Atomic / Nuclear Structure [2]

1.2 - Modes / Rates of Decay [1]

1.2.1 alpha, beta, gamma, x-rays, neutron l 1.2.2 halflife i 1.2.3 transient / secular equilibrium i 1.3 Production ofX Rays,[2] -l 1.4 Interaction with Matter [2]  !

l.4.1 Photoelectric Effect 1.4.2 Compton Scattering 1.4.3 Pair Production 1.4.4 Neutron Capture 1.5 Terminology (SI & Special Units)[1]

1.5.1 Activity 1.5.2 Dose i

1.5.3 Exposure l.6 Background Radiation [3]

1.7 Exposure Pathways [2]

1.7.1 Ingestion ,

1.7.2 Inhalation 1.7.3 Absorption 1.7.4 Contaminated Wound 1.7.5 Direct Expo:ure 1.8 - Biology / Effects ofRadiation [2]

, 1.8.1 Somatic / Genetic /In-Utero 1.8.2 Stochastic /Non-Stochastic (Deterministic /Non-Deterministic) 1.8.3 li;gh Dose Effects

, 1.9 - Regulatory Emironment [2]

1.9.1 Federal (NRCDOT/ EPA /FDA/ OSHA) 1.9.2 State (Agreement /Non Agreement /CRCPD) 1.9.3 Advisory Organizations (NCRP/ICRP/IAEA)

NRC/0A5 Traistag Working Group . 4 October 1997 i

. .__ - = . . . .

. Emes %Ekmag

2. APPLICATIONS . -

2.1 Sources of Radiation [2]

' 2.1.1 sealed 2.1.2 unsealed 2.1.3 plated

- 2.1.4' machine generated 22 Uses [3]

- 2.2.1 Medical 2.2.2 Industrial 2.2.3 Academic 2.2.4 Consumer Products 2.2.5 Reactor / Fuel Cycle 2.3 Licensee / Registrant Radiation Safety Program [1]

2.3.1 facility design & engine: ring controls 2.3.2 ALARA 2.3.3 surveys 2.3.4 contamination control / spills 2.3.5 respiratory protection 2.3.6 waste handling and disposal 2.3.7 dose assessment 2.3.8 transportation

3. INSTRUMENTS 3.1 Detectors (types and modes of operation) [1]

3.1.1 Gas Filled-3.1.1.1 GM Proportional 3.1.1.2 3.1.1.3 Ionization i.

3.1.2 Scintillation 3.1.3 Semiconductor 3.2 Measurement Systems [1]

3.2.1 Meten 3.2.2 Scalers 3.2.3 Multi Channel Analyzer (MCA)

NRCMAS Tralaing Worklag Group . u October 1997 r

' Beele Heath Physees EsseenalElesseets l.

- 3.3 Operational Parameters [2]

3.3.1 . Efficiency

  • 3.3.2 Resolution 3.4 Air Samplers [3]

3.5 Calibration [3]

4. SURVEYS / MONITORING / STATISTICS 4.1 Types [1]

4.1.1 Radiation Levels 4.1.2 -Contamination 41.3 Bioassay 4.1.4 Effluents 4.2 Techniques [2]

4.2.1. Sample Collection 4.2.2 Evaluation of Results 4.2.3 Spectmscopy-4.2.4 RadionuclideIdentification +

4.3 Ststistics [3]

4.3.1 Minimum Detectable Activity (MDA)/ Lower Limit of Detecdon (LLD) 4.3.2 Counting Time 4.3.3 Dead Time :

5. DOSE ASSESSMENT
5.1 PersonnelMonitoring [2]

5.1.1 Devices 5.1.2 - Applicability 5.2 - External [1)-

5.2.1 ~ Point /Line/ Area / Volume Sources 5.2.2 Submersion 5.2.3' Hot Particles MRC/DA5 Tralalag Woridag Group U1- , Octokr 1997 4

w

- ,y .w.,-. -

Basic Health Physics Essestial Elesmente

$3 Internal [2]

5.3.: Biological / Effective IIalf Life .

5.3.2 Intake Retention Fraction (IRF) 53.3 Annual Limit onIntake (ALI) 5.3.4 Derived Air Concentration (DAC) 5.3.5 EPA Federal Guidance Report #11 5.3.6 ICRP-30 5.3.7 Medical Internal Radiation Dosimetry (hDRD) 5.4 Modelling [3]

5.4.1 Use and Limitations 5.4.2 Types (RESRAD/C')MPLY/MICROSFuct.D/MIRDOSE etc)

6. LABORATORY EXERCISES Laboratory exercises are recommeaded to reinforce concepts and proside practical application of the subject areas.

KEY TO DEPTH OF INSTRUCTION: The numbers in [#] refer to training at an undegradu-ate equivalent level where:

[1] = In depth (advanced undergraduate course)

[2] = Medium depth (basic undergraduate course)

[3] = Not in depth (undergraduate survey course)

I NRCK)AS Training Working Group IV October 1997 i

l

l

, Diegoestic and Therapeetle Nuclear Medicine EssentW Elemee3

. _ . .. .- - - . . -, ~ - _ .-- .__ __ - -

l. DIAGNOSTIC NUCLEAR MEDICINE 1.1 Equipment (gamma camera, dose calibmtor) [2]

1.1.1 Principle ofoperation 1.1.2 Uses  !

1.1.3 Calibration and Problems Encountered if Calibration is Not Performed 1.1.4 Required Function Tests 1.2 Nuclear Medicine Studies (Provide the following information for various studies) [2] l 1.2.1 Purpose of Study

1.2.2 Type and Quantity of Radionuclides Used (dosage)

- 1.2.3 Approximate Dose to Patients (dose) l.2.4 Equipment and Material Required 1.2.5 Special Function /QC Tests 1.2.6 Additional Radiological Considerations 1.3 Positron Emmission Tomography (PET) [3]

1.3.1 Equipmeut 1.3.2 Sources and Function Tests 1.3.3 Production and Handling of Material ,

i 1.3.4 Mobile PET and Generators i

1.4 New Modalities [3]

1.5 Radiation Safety Concerns [1] l 1.5.1 Contamination 1.5.1.1 Typical Areas of Contamination (including patient-caused) 1.5.2 Airbome Hazards

1.5.3 Engine

ring Controls 1.5.4 Receipt. Use and Transport of Material l.5.4.1 Mobile Facilities

- 1.5.4.2 Administration in Areas Other than Nuclear Medicine Department 1.5.4.3 Return of Material to Pharmacy 1.5.5 Waste Disposal NRC/OAS Training Working Group i October 1997

y m m er.,.mk N heru ed z wn . -

j

. 2. SEALED SOURCES FOR DIAONOSIS [3] [

l 2.1 Types of Sources l

2.2 Uses
  • l 2.3 Radiation Safety Concerns  !
i
3. THERAPEUTICNUCLEARMEDICINE  !

NOTE: Focus on material not already presented in 1. above Equipment [3]

) 3.1  !

I t

1 3.1.1 Principle ofoperation 3

3.1.2 Uses ,

3.1.3 Calibration and Problems Encountered if Calibration is not performed  !

! 3.1.4, Required Function Tests 1

l i 3.2 Therapy Studies (Provide the following information fb several typical therapies) [2] ].

i 1

) 3.2.1 Purpose of Study ,  ;

3.2.2 Treatment Planning 3.2.3 Type and Qa ..it af Radionuclides Used (dosage) '

3.2.4 . Approximste Dv4 to Datieras (dose)

- 3.2.5 . Equipment an:1 Material Roquired 3.2.6 Special Function /QC Tests 3.2.7 Additional Radiologc4 C ansiderations ,

~ 3.3 New Modailties [3]

3.4 Radiation Safety Concems [1]

3.4.1 Contamination 3.4.1.1 Typical Areas of Contamination 3.4.1.2 Patient Caused Contamination 3.4.2 Typical Dose Rates

'3.4.3 Airborne Hazards 4 3.4.4 hp:34 ontrols- C t 3.4.5 Bloassays j 3.4.6 Training for Ancillary Personnel  !

3.4,7. Receipt, Use and Transport of Material  ;

3.4.7.1 Mobt Facilities .

3.4.7.2 Adadtstr: tion in Areas Other than Nuclear Medicine Department  ;

3.4.7.3 Return of Material to Pharmacy - 1 i

IneQUA5 Tretolag Wortdag Group - .u, Bc"isliirTWi >

._____r

Diagnestie end Therapeutic Neeleer Med6eine Essential Elements 3M.8 Waste Disposal

4. SEALED SOURCE 111ERAPEUTlC PLANNING [3]

4.1 Evaluation of Patient Condition 4.2 Measurement of Patient 4.3 Simulation ofTreatment 4.4 Determine Accuracy ofInformation 4.5 Calculate Treatment Plan

5. MANUALBRACHYTHERAPY[2]

5.1 Overview 5.1.1 Applicator 5.1.2 Radionuclides 5.1.3 Forms (Seeds, Needles, Tubes) 5.1.4 Uses Oncluding Superficial and Interstitial Treatments) 5.2 Radiation Safety Concems 5.2.1 Instrumentation 5.2.2 Training for Ancillary Personnel 5.2.3 Source Inventory

6. REMOTEBRACHYTHERAPY[2]

6.1 Overview 6.1.1 Devices Oligh Dose Remote Afterloader GIDR) and Low Dose Remote Afterloader(LDR))

6.1.2 Applicators 6.1.3 Rad!onuclides 6.1.4 Uses 6.2 Radiation Safety Concems .

6.2.1 Instrumentation 6.2.2 Training for Ancillary Personnel 6.2.3 Source Inventory 6.2.4 Engineering Controls Onterlocks, etc.)

6.2.5 Special Function /QC Tests 6.2.6 Emergency Procedures NRC/UA5 Trolstag Working Group m. October 1997

o INegnestic and Thorspostic Neeleer Medicine Essential Eleaseets

7. GAMMA STEREOTACTIC RADIOSURGERY 7.1 Overview [3]

7.1.1 Device Design 7.1.2 Uses 7.2 Radiation Safety Concems [2]

7.2.1 Instrumentation 7.2.2 Engineering Controls (Interlocks, etc.)

7.2.3 Special Function /QC Tests 7.2.4 Source Loading 4 '8 . TELETHERAPY 8.1 Overview [3]

8.1.1 Device 2.1.2 Uses (both medical and non-medical) 8.2 P.adiation Safety Concems [2]

8.2.1 Instrumentation 8.2.2 Engineering Controls (Interlochs, etc.)

8.2.3 Special Function /QC Tests 8.2.4 .C rce Exchange

9. REGULATORY SKILLS Additional discusslora or site viks may help inspectors or license resiewers draw correlations between the information presented in this course and their particular responsibilities.

KEY TO DEPTH OF INSTRUCTION: The numbers in [#] refer to training at an undegradu. ,

ate equivalent level where:

[1] = In depth (advanced undergraduate ::ourse)

[2] = Medium depth (basic undergraduate cource)

[3] = Not in depth (undergraduate sun'ey course)

NOTE: 'Ihis course outline assumes participant has completed a basic health physics course (se outline for Basic. Health Physics course) and has reviewed the applicable regulations prior to attending this course.

A Glossary of medical and automical terms used in this co'ese should be prosided for students to reference.

NRC/DA5 Traiolog Working Group IV October 1997

-,.w .. , y -4 -

. seawy Aspwe et seewertet memesrephy Emeth th a

1. INTRODUCTION [2]

l.1 Tenninology 1.2 History of Radiography 1.3 Other Types of NDT

2. TYPES AND USES OF SOURCES OF RADIATION [2]  ;

2.1 Radlonuclide Scaled Sources (ANSI N542) 2.2 Machine Produced 1

3. RADIOGRAPHY EQUIPMENT [1]

3.1 Radionuclide (ANSI N432) 3.1.1 Radiographic Exposure Device 3.1.2 Crank-out 3.1.3 Guide Tube 3.1.4 Collimator '

3.1.5 Source Changer 3.1.6 Film 3.2 Machine Produced 3.2.1 Head 3.2.2 Power Supply 3.2.3 Control Panel 3.2.4 Film

4. SPECIALTY E>POSURE DEVICES [2]

4.1 Pipeliners 4.2 Crawlers

5. SPECIAL CONSIDERATIONS [1]

5.1 Radiography Personnel Qualifications 5.2 Personnel Monitoring 5.2.1 Direct Reading Pocket Dosimeter ,

5.2.2 Alarming Rate Meter 5.2.3 Film BadgefrLD 5.3 Area Posting 5.4 - Storage of Exposure Devices and Sources 5.5 . Transportation ofRAM NROUA5 Trelaing Workleg Groep i October 1997 m

sesWy Aspwe of ledertrial Radhgrepby Ementbl Elesments 5.6 Radiation Snrvey Requirements 5.7 Reciprocity  :

5.8 Inspection Procedures (Office & Field) 1

6. RADIOGRAPHIC PROCESS [2] l 6.1 Setup ,

6.2 Exposure 6.3 Exposure Verification 6.4 Breakdown

7. CASE STUDIES [2]  :

Source Disconnects / Retrieval Overexposures Transportation Incidents Equipment Failures Loss of Control of RAM

8. REGULATORY SKILLS Additional discussions may hip inspectors or license reviewers draw correlations between the infonnation presented in this course and their particular responsibilities. Site visits to a radiography operation or facilty are highly recommended.

KEY TO DEPTH OF INSTRUCrlON: The numbers in [#) refer to training at an undegradu-ate equivalent level where:

[1] = In depth (advanced undergraduate course)

[2] = Medium depth (basic undergraduate course)

[3] = Not in depth (undergraduate survey course)

NOTE: This course outline assumes participant has completed a basic health physics course (se outline for Basic Health Physics course) and has viewed the applicable regulations prior to attending this course.

A Glossary ofindustrial radiography terms used in this course should be provided for students to reference.

NRCA)A5 Training Woridag Group II October 1997

. _ . . . _ - __ ~ - - - - . _ - _ - _ _ . - . -. . - . _ . - _ - - ._-. - . . . _ .

i Tremoportat6es of Radlenethe Material Essestiel Elesments i

l.INTP!s4tTC@N i U Aatt%rity (IXT1, ? 'RC, CRCPD, IAEA) [3] .

.2 kpn ?hilitV 13) I

' '; . ' ncrator t.) . ransporter

! Acceiving Facility 1.3 Definitions specific to radioactive materials transportation [1]

2. DOT RADIOACTIVE MATERIALS CLASSIFICATION [1) 2.1 Excepted materials - limited quantity Instnunents and anicles, articles of U, DU or Th 2.2 Type A Quantity 2.3 Type B Quantity 2.4 liighway Route Controlled Quantity 2.5 Fissile Material 2.6' Low Specific Activity 2.7 Surface Contaminated Objects
3. TRANSPORTATION LIMITS [1]

3.1 Radiation Levels 3.2 Contamination Levels and Empty Packages 3.3 Thermal Levels

4. PACKAGINGS AND PACKAGES 4.1 Authorized Packagings [2]

4.2 Packaging Tests [3]

4.3 Quality Assurance [2]

5. CARRIERREQUIREMENTS[2]

5.1 Blocking and Bracing 5.2 Segregation

6. COMMUNICATION REQUIREMENTS 6.1 Marking [1]

6.2 Labeling [1]

6.3 Placarding [1] i 6.4 Shipping Papers [1]

6.5 Training requirements and emergency response [2] l l

NRCADA5 Trelaing Working Group i October 1997

T. . " et N Materest Ieeestial Elesmeses i

7. *!1tANSPORTATION SAFETY INSPECTION AND ENFORCEMENT [2] }

7.1 Things to look for/ inspection techniques l 7.2 - NRC/ State Enforcement Experience (lessons learned) ,

8. TRANSPORTATION SAFEOUARDS [3]

t 8.1 Applicability 8.2 Requirements ,

8.3 Inspections

9. - TRANSPORTAT10N OF RADIOACTIVE WASTE [3]

9.1 Generator requirements [

9.2 Wate Classification  :

9.3 Waste Characteristics i 9.4 Uniform Radioactive Waste Manifest

10. - REGULATORY SKILLS i Additional discussions or site visits may help inspectors or license reviewers draw conelationsbetween the information presented in this course and their particular responsibil ities.

KEY TO DEPTH OFINSTRUCTION: The numbers in [#) refer to training at an undegradu- i ste equivalent level where:

' [1] = In depth (advanced undergraduate course) l

_ [2] = Medium depth (basic undergraduate course)  ;

[3) = Not in depth (undergraduate survey course)

NOTE: This course outline assumes participant has completed a basic health physics course (se outline for Basic Health Physics course) and has reviewed the applicable regulations prior to 9antline this Course. ,

f A Glossary of transportation terms used in this course should be provided for students to reference. 4

+

PHtOUA5 Troising Worldsg Group u - October 1997  ;

i

l

- sofWy Aspwm of wen imaging Emotial Elemeek ,

i

1. INTRODUCTION [2]

1.1 Terminology 1.2 Drilling Rig Layout / Industrial Hazards 1.3 Geology of Petroleum 1.4 Drilling Process 1.5 Drilling Muds, Cementing, Fracturing

2. EQUIPMENT [])

2.1 Well Logging Source Description and Uses 2.2 Logging Tools 2.3 Collar Markers 2.4 Fishing Tools

3. LOGGING PROCESS [3]

3.1 The Logging Supervisor 3.2 Radiation Logging '

3.3 Mineral Logging 3.4 Logging While Drilling 3.5 Analysis ofLogs

4. TRACER STUDIES [2]

4.1 Tracer Surveys, and Handling Procedures for Tracer Materials 4.2 Radioactive Tracer injection to Monitor Subsurface Fluid and Oas Movement 4.3 - Methods for Radioactive Tagging of Cement and Fracture Propping Agents

5. RADIATION SAFETY PROGRAM CONSIDERATIONS [2]

5.1 Large Operations 5.2 Small(Single-Owner) Operations 5.3 Procedures for ketrieval and Abandonment of Sources 5.4 Decontamination of Well Site

6. CASE STUDIES [2]

6.1 Well Site Fire and Scaled Sources Involved 6.2 - OtherIncidents

7. REOULATORY SKILLS Additional discussions may hip inspectors or license reviewers draw correlations between the

' information presented in this course and their particular responsibilities. Site visits to a well drilling or legging operation are highly recommended.

MRC/DA5 Tralalog Worklag Group i October 1997

l. ,

Safety Aspects of Well1Aggleg Essential Elesments a KEY TO DEPTH OF INSTRUCTION: The numbers in [#] refer to training at an undegradu-ate equivalent level where:

[1] = In depth (advanced undergraduate course)

[2) = Medium depth (basic undergraduate course) '

[3] = Not in depth (undergraduate sun'ey course)

NOTE: This course outline assumes participant has completed a basic health physics course (se outline for Basic Health Physics course) and has reviewed the applicable regulations prior to attending tids course.

A Glossary cf well drilling and logging terms used in this course shoul8e provided for students to referenec.

NRC/OAS Training Working Group II October 195@ -

Sofety /, w oflarge Irrediators Essential Elesments suummuur*

1. INTRODUCTION 1.1 Types, use, and operation modes ofirradiators [2] ,

1.1.1 Self shielded and pool 1.1.2 Continuous, Batch, and Off Canier 1.2 Definitions specific to irradiators [1]

1.3 Components [1]

1.4 Federal / State Regulations and Standards (NRC, OSHA, FDA, ANSI,) [2]

2. FACILITY DESIGN AND ASSOCIATED TESTING 2.1 Water pool requirements [1]

2.2 Ventilation [1]

2.3 Shielding [1]

2.4 Product Handling [2]

2.5 Interlocks [1]

2.6 Fire Suppression [1]

> 2.7 Seismic Consideration [2]

2.8 Access Control [1]

3. MAINTENANCE 3.1 Source loading [2]

3.2 Routine [1]

3.2.1 Leak testing 3.2.2 Safety checks 3.2.3 Water Pool quality 3.2.4 Ventilation 3.2.5 Interlocks 3.2.6 Product liandling

4. EMERGENCY PROCEDURES [2]

4.1 Types 4.2 Past events / accidents

5. REGULATORY SKILLS Additional discussions may hip inspectors or license reviewers draw correlations between the infonnation presented in this course arid their particular responsibilities. For pool irradiators, site visits are highly reconunended.

M5 Tralelag Working Group i October 1997

Sefety Aaports of tarseIrrediators Essential Eleaneets -

KEY TO DEPTH OF INSTRUCTION: The numbers in [#] refer to training at an undsgradu.

ate equivalent level where: l

[1] = In depth (advanced undergraduate course)

[2] = Medium depth (basic undergraduate course)

[3] = Not in depth (undergraduate sun'ey course)

NOTE: This course outline assumes participant has completed a basic health physics course (se outline for Basic Health Physics course) and has reviewed the applicable regulations prior to attending this course.

A Glossary ofirradiator terms used in this course should be provided for students to '

reference.

I NRC10A5 Traintag Working Group ' H. October 1997

4 1

i Appendix D i

SAMPLE AGREEMENT STATE TRAINING POLICY STATEMENT l We will ensure that staff will be qualified to perfonn licensing and inspection functions for all types of licenses issued by the State.

i An individual will not be a lead inspector at a licensed facility unless the individual has demonstrated competency in the program training areas applicable to that type of license. An individual will not be a senior license reviewer for a license unless the individual has demonstrated competency in the program training areas applicable to that type of license.

The program training areas and essential elements to be covered in each program training area '

are described in [NRC or State Guidance document specify the exact document).

When an individual has demonstrated competency in a particular training area to managenwnt, the training chart will be completed by that member of management.

Refresher training will be provided, as needed. This additional training recognizes that i

inspector and reviewer training does not stop with initial qualifwation, but that training should be made available for experienced inspectors and reviewers on the basis of need, special circumstances, and the necessity of keeping current with inspection and licensing programs, i

i e

D1

SAMPLE AGREEMENT STATE TRAINING QUALIFICATION FORM i Name: Date ofIlire : .__

Date Management Training Areas Completed Initials / Signature Comments BASIC TRAINI(.

Degree in Health ycs Overall program t.. atation Review of State Regulat: u ,

Review oflocation of Reg. Guides

& reference material Essentials ofInspection Essentials of Licensing .

Essentials of Transportation SPECIALIZED TRAINING _

Elements of Nuclear Medicine Elernents of Medical Therapy Elements of Indust. Radiog.

Elements of Transportation ,

Elements of Well Logging Elements of Pool Irradiators Elements of Env. Monitoring ADVANCED TRAINING Advanced Health Physics Elements ofInvestigations _

D2 1

y - .,- - -

e , . , . , .,

-M -4 p.42,_ ,_-4%+ .b m & s -,L4 #,Mwe4. m433,_A,,c_,,.,%.5h.4,EA., AA_.44h.& &.4 J.4,$ 44,&,_.~._MM,g4._&,.4,,h4Sw_,- ,WM _4 a gwp _.m _sa.Wa- A.44 6,5 .(.4a.ahmi.h 4.W mdi.,4,,h.,..an 1

I i

i I

t r

d t

4

- i

. 'i Appendix E

' ALL AGREEMENT STATES LETTER (SP %118) l ON SUCCESSFUL COMPLETION OF NRC TRAINING COURSES  !

s 6

9 4

e 4

+

E1 F

. . , - jv -w .- - - . -- vv- . a ,-w,,y.,, #-wy,. .m.,,,,, , , , , , ,,y_, , -, , ,, wewrv',w - -

m-eE.---se.-e---ee------

7__.__._. ,

't,,',.* g UNffSD STATES i

. NUCLEAR RESULATORY COMMISSloN  !

' ' WAeIIIIIefool, D,c. SAIMEM i Noves6er 20,1996 f

,,g.

I  ;

i i i ALL AGREEMENT STATES MASSACHUSETTS, OHIO, OKLAHOMA, PENNSYLVANIA

! TRANSMITTAL OF STATE AGREEMENTS PROGRAM INFORMATION (SP 98118)

Your ettention is invited to the enclosed correspondence which contains:

INCIDENT AND EVENT INFORMATION.......

i PROGRAM MANAGEMENT INFORMATION.

I L TRAINING COURSE INFORMATION...........XX POSITION ON SUCCESSFUL I COMPLETION OF TRAINING ,

COURSES -

TICHNIC AL INFORMATION...................... l

~

OTHER INFORM S Y0N.............................  :

. i Supplementalinformation: This letter clarifies the Nuclear Regulatory Commission (NRC) i position on successful completion of training courses by Agreement State staff. j The Technical Training Division's policy on successful completion of courses by NRC staff is described in the Technical Training Division Courses Catalog at pages vili and ix )

(reformatted copy enclosed), i With the goal of having equivalently treined individuals whether in Agreement States or NRC, we plan to follow the same approach regarding Agreement State staff attendance at >

. NRC training courses. We expect Agreement State staff attending an NRC course to take j any_ examination, if given, and grads of 70% will be considered passing. For students  ;

succc3sfully passing courses, the certificates with the examinations will be sent vis - l

- transmittalletter to their respective Program Directors to be distributed to tN students.  ;

, Students will receive a copy of the transmittal letter. These will be sent on a periodic benis, usually guarterly, depending on the number of courses,

)

i 4 Soperate' notifications, together with the completed exams, will be sent to Program -

Directors, with a copy of the letter to the students, for those individuals that have not successfully completed a course. These notifications will be gnade within 2 weeks of our l receipt of the course results. Progrera Directors may request e re examinstion by writing i directly to Mr. Russell L. Andtrson, Chief, Spec! wilted Techrdcol Training Stanch Technical 1

- Training Division, Osborne Offico Center,' Suite 200,5700 Brainerd Road,' Chattanooge,

- Tannamnea 374114017.

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. . *. , l SP.96118 2 W f9 2  !

If you have any questions regarding this correspondence, please contact me or the ,

individuel named below. ,

4 POINT OF CONTACT: Dennis M. Sollenberger TELEPHONE: (301)415 2819 FAX: 1301) 415 3502 INTERNET: DMS49NRC. GOV 4J (N Poul H. Lohous, Deputy Director ,

Offr;e of State Programs

Enclosure:

As stated 4

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I ENCLOSURE 1 l

,! i TECHNICAL TRAINING DIVISION p0LICIES ON COURSE EXAMINATIONS  :

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(Taken verbatim from the Course Catalog) hamination Poliev j Examinations are given at the end of most TTD courses. Students rcquired by NRC Inspection Manuel Chapter 1248 (or other formal requiremental to complete a course as ,

part of their qualification progrom must pass the examination. The passing grade for all  !

TTD courses is 70% except for Site Access Training, Site Access Refresher Training, and ^

NMSS Radiation Worker Training which require a score of 80%. Some employee qualification programs may require a higher or lower passing grade for some courses.

i Examinations for TTD courses are linked to loaming objectives associated with course
modules. These looming objectives are provided to students et the beginning of courses '

and are normally included as part of the course manual. Examinations for reactor technology courses and some specialized technical training courses we normally randomly.  :

i generated by a Computerized Examination Sank System which c:-tains validated

! questions.

! After course examinations have been graded, course reporting memoranda with actual  !

l - course grades will be sont to the appropriate region or program office via the training

- coordinator and to the NRC Training SyWoms Administrator. Students will receive a copy of this letter along with the completed examination if the examination was not previously retumed. Course reporting memoranda for students who satisfactorily complete a course (or course series) will reflect that the minimum requirements have been met, and a training

- certificate will be provided.

l

[ Since there is typically no pre course examination, the final course examiri don grade is

! not necessarilyindicative of the level of effort expended by the student. Examination p

results indicate only the knowledge level of the student at the conclusion of a course, and the numerical grade should not be used as a performance indicator.

Examination results are normally considered final, if a question concoming the grading of an enemination arises, the examination will be regraded provided the examination has been discussed with the student's management: the student's management requests the -

regrading of the examination in writing, to the appropriate TTD Branch Chief; and the original examination is returned to the TTC. The complete examination will be regraded by

- en instructor who was not associated with the original examination. Any regraded examination is considered as the final grade for the examination and will be retumed to the student's management.

1 Emulvalency Examination Poliev Equivalency examinations may be given to experienced personnel for rottuired courses that are part of formal qualification programs to allow validation of the course. These ,

examinations must be requested by the employee's immediate supervisor to the cognizant '

',, ' TTD Stanch Chief. Students who validate courses typlcally miss out on regulatory insights and perspectives, emerging technical issues. and technical interactions with their peers.

t

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jf, . .. * , f f

Equivalency examinations may be take the TTC or in the employee's regional or  !

i program office and are normally taken ori the regular examination day for the course that is  :

, being validated.

I i Raamamina11on Policy  !

l Written reexaminations may be given to students who receive failing grades, subject to i certain limitations. Reexaminations are rarely given to students who received a course grade of less than 50E No reexaminations are given, regardless of the grade, if the course which has been failed is not required training for the individual unless a request is .

. received from the stadent's management. Only one reexamination will be given to a student for any given course. Any student who falls a reexamination must repeat the course to satisfy the training requirement.  ;

Reexam nations must be requested by the student's management to the cognizant TTD Br6nch Chief. Such requests must be received by the TTD within 30 working days from ,

the date the examination letter identifying the failure was mailed to the student and i immediate supervisor. A prepared reexamination will then be mailed with a cover letter to ,

the stiwient's immedietJ supervire. This letter willindicate how the reexamination should  ;

  • be administered. The completed reexamination must be returned to the TTC immediately  ;

upon completion. l l

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4 Appendix F TRAINING ALTERNATIVES FOR TECIINICAL COURSE. PRESENTATION F1

TRAINING ALTERNATIVES FOR TECHNICAL COURSE PRESENTATION Introdne:lon The WorWMbup reviewed several references on distance learning and selected the major meths for evaltuten. b report defines the general terms and methods used in distance lemming and prets the advantages and disadvantages for the training mrthods evejusted by the Working Group.

DeSmitions Distance lemmir,2. any lea ning that takes place without the physical presence of the instructor with the leen This can include technoloths yet to be developed as well as technologies, such as corresp-h courses, that have been around for many years.

Teleconferencing - Two wr/ tjewodt onununication berma two or more gioups, or three or '

more individuals, who are in separateilutdons; includes group communication vis udio, -

sudiographics, video, and computer, -

Teletraining One way electronic communication (instructor to lemmer) with limited feedback to the instructor via telephone, fax, keypad, or other communicatton method.

Methods Consides ed a:: Tralelag Presentation Alternatives The Working Group evaluated the followits training methods:

Traditional Cla sroom - The teamer and the instructor are at the same site. This is the traditional

- classroom training environment. The instructor receives immediate feedback from the students both visually and audibly.-

Video Teleconferencing . The learners can see and hear the instructor, and the instructor can see and hear the teamers. . It is sometimes refened to as "two way, two way," referring to the two-way transmission of both an audio and video signal. With video teleconferencing, the equipment -

is oAen the same at both the instructor and the leamer sites. This provides the flexibility for any of the sites within the system to become an instructor site.

. Interactive Video Teletraining - Tbsi learners can both see and hear the instructor by watching a -

television monitor. It is different from static television in that the instructor receives l'n'= Hate feedback from the leamers either frwi audio systems, keypad viewer response system, telephone, fax, or a combination of the above.

Audio Teleconferencing - The teamers een hear the instructor and the instructor can hear the

' leamen in an irr.eractive environment. Audio teleconferencing is greatly enhmW with the F2I F +

y- _ .v _t -

4 distribution of prepared leamer materials, such as print based workbooks, videotapes,35 mm slides, or other audiovisual aids.

Audiographics In addition to audio teleconferencing, the instmetor and learners are able to share computer genested graphics and slides. His technique requires that the instructor and the Icamer sites have the equipment needed for audio telecon'erencing as well as a personal computer, audiographics software, a special modem, and an interactive tablet.

Computer Based Training - The teamer uses a desk top computer to improve skills and knowledge. This can use inter / intra net, CD ROM, or other media.

Internet/Intranet Interactive communications via the compute- through the inter /m* tra net through the use of chat rooms or other techniques.

Printed Material - The instructor prepares written instructional material that is distributed and used at the Icamer's discretion. May provide for limited interaction with the instructor via telephone or fax on an as needed basis.

Video Tape - A video tape is prepared of the instructer presenting the subject material.

Audio Tape - An audio tape is prepared of the instructor presenting the subject material.

These altemative methods for presentation of technical courses are logically divided into the following flow diagram.

LEARNER INFORMATION TRANSFER ENVIRONMENT l

LEARNER ,

l Non Traditional Traditional 1 Claseroom Classroom Self-Paced Live Interactive

-Video Tapes -Teleconfotencing .

-Internet/Intranet -Teletraining

- Printed Material (Audlographics)

-Computer Based Taining '

- Audio Tapes /CDs F3

The presentation of advantages and disadvantages of the course presentation alternatives are grouped according to the logic flow above.

TRADITIONAL CLASSROOM TRADITIONAL CLASSROOM TRADITIONAL CLASSROOM TRAINING TRAINING ADVANTAGES DISADVANTAGES

  • More flexibility in terms of material e Physical limitation of classroom size presented
  • Travel /per diem costs .
  • Ifighly interactive can request
  • Ab!!ity to sec/ hear instructors special assistance o Each group receives slightly different
  • Allows hands-on demonstrations, use training of training aids, field trips
  • Quality ofinstructors varies e immediate feedback on learner
  • Instructor availability comprehension e Fewer distractions e Traditional training, no technophobia e Materials readily available FQ

(

NON-TRADITIONAL CLASSROOM VIDEO TELECONFERENCING VIDEO TELECONFERENCING ADVANTAGES DISADVANTAGES e Can easily be recorded for future use e liigh cost for transmission need e Everyone receives identical ISDN phone lines information e liigh cost for equipment

  • Trainer sees leamers e Difficult to manage visual interactions
  • Instmetors and learners have the at several sites flexibility of selecting the most
  • Focus is on technology instead of convenient training site interaction (movement of cameras).
  • Leamers can interact with each other distactions to instructors
  • Reach people that normally would not
  • Prc distabution of materials be reached e Limited time for transmission of information(different time zones)
  • Decreased informal interaction among students
  • Reliability of transmission e Scheduling conflicts with equipment and/or room o Instmetor cannot deviate from script due to time constraints INTERACTIVE VIDEO INTERACTIVE VIDEO TELETRAINING TELETRAINING ADVANTAGES DlSADVANTAGES e Valuable for large groups at several e Uses keypad or fax to gain response sites from students
  • Instmetor can monitor fecoback from o Only useful for multiple choice leamers (A,B,C,D) type questions
  • When feedback mechanisms are used, o Predistribution of materials needed learners are more accountable for
  • Instructo: :annot deviate from script attending and interacting due to time constraints e Extensive equipment
  • Satellite downlink dishes at remote sites e Thorough equipment training at remote site e Scheduling conflicts with equipment and/or room F-5

i AUDIO TELECONFERENCE AUDIO TELECONFERENCE ADVANTAGES DISADVANTAGES

  • Inexpensive o Simple setup e Not appropriate iflive video is needed
  • Minimal equipment training e Requires pre-distribution of visual e Uses existing phone Hnes materials AUDIOGRAPHICS ENIIANCEMENT AUDIOGRAPHICS ENHANCEMENT ADVANTAGES DISADVANTAGES e Ability to share digitiud information
  • May require pre-distribution ofimage e Trainer can write information ales i Requires computer literacy to develop course materials COMPUTER BASED TRAINING COMPUTER BASED TRAINING ADVANTAGES DISADVANTAGES e Very flexible once developed self e High development costs - need paced training contractc,r help e inexpensive e Lengthy development / timeliness (12-
  • Evaluation built ir.to instruction 18 months) e Can use existing videos / visuals e Moderate computer literacy needed to e Convenient use e Tracking of studeut progress e Very few programs available on a commercial basis
  • Distractions, computer glitches e Question of exam availability / security l F6

AUDIO TAPES OR CDs AUDIO TAPES OR CDs ADVANTAGES DISADVANTAGES e Inexpensive e Non inter:ctive o Equipment available o Quality varies (studio vs live, tape e Simplest technology length)

  • Convenient'
  • Laborintensive to produce well e Private e Could be boring ifnot dor s well e Selfpaced
  • May be able to modify when information changea
  • Unlimited access
  • Mass distribution e Can mark tapes for review e As technology advances, CDs, DVDs may be considered VIDEO TAPES VIDEO TAPES ~

ADVANTAGES DISADVANTAGES

  • View parts of course that could not be e Becomes obsolete as information done with audio only changes e Can view places that are not
  • Non interactive accessible o Quality varies (tape length) e Familiar technology e Laborintensive to produce well e Easily edited
  • Unlimited acce:s
  • Mass distribution e Can mark tapes for review F7

l INTERNET/INTRANET WEB BASED INTRANET/INTRANET WEB BASED TRAINING TRAINING ADVANTAGES DISADVANTAGES

  • Materials readily updated e Computer literacy to create web site
  • Inexpensive distribution costs e Video / audio transmission limited e Access to multiple training with single e Security considerations (unauthorized software access or possible tampering with e Accessible by 27 million people files) e Cross platform access e CBT does not work well on the Web e Trainers have ability to update as (large versus small files) and needed interactiveness e Access speed and reliability (graphics are especially a problem) e Limited interactivity e Finding location of site e Differences in viewers / browsers may result in need for standardization PRINTED MATERIAL PRINTED MATERIAL ADVANTAGES DISADVANTAGES t
  • Material can be converted to e Large amount ofpaper used electronic format e Bulky in a hard copy format e inexpensive e Distribution costs e Can highlight, can reproduce easily e Labor intensiv to maintain current e Easily revised e Can be boring as compared to more e Adaptable to in house training, can visual stimulating programs convert to specialized training for staff e Very flexible, go anywhere you want, easily reviewed
  • Not technologically dependent e Recyclable The distinct advantages and disadvantages of each method of training presentation need to be considered in any decision to proceed to implement any specific methodology or combination of methodologies. The status quo would be to continue with the traditional classroom teaching erwironment for NRC training with Agreement States always having the option to use other training alternatives, Conversion to any of the other methodologies would require significant time and resources to modify the current materials to be presentable in the selected mode.

F8 l

The costs for conversion and presentation identified at this time are: [

e Course material conversion (This may be accomplished in house or via a contractor  ;

i depending on the complexity of the method and the material.)

e Trainer training and pract!ce given the med's selected j e Media presentation development (video / audio tapes, scripting for live presentations) e Equipment purchase / rental / scheduling and technical rupport for NRC/ States

'Ihe references reviewed by the Working Group recommend that a team ofprofessionals be  ;

assembled to develop materials for presentation using the newer electronic media. This team  ;

should include technical specialists, training specialists, and communict.tlons specialists.

The Working Group discussed several technical courses that would have the potentfal for ,

modification for presentation using electronic communications. The general criteria used by the

. group were: .

e The course in mainly lecture presentation.  :

e The course does not require field trips or extensive small group interaction, e 'Ihe course length should be relatively short or the course should be amenable to being broken into modules for presentation.  ;

The Working Group reviewed the courses currently being presented by the Technical Training Division of NRC using the general criteria above.1he courses identified as potentially convertible at this time were:

H 117. Introductory Heahh Physics (1 week, NRC staff taught)

H 120 Radiological Surveys In Support of Decommissioning (2 days, contractor taught)

H 201 Health Physics Technology (2 weeks, NRC taught)*

H 312 Internal Dosimetry and Whole Body Counting (1 week, contractor taught)

H 401 Health Physics Topical Review (3 days, contractor taught)

H 901 Health Physics Techn) logy Overview (I week,NRC taught) 0 109 Licensing Pinctices and Procedures (1 week, NRC taught)"

  • (Daily quines would require the presence of an on-site facilitator. Quines cannot be graded ,

locally but must be returned to the instructors. Quizzes are normally graded each night to .

provide students with instant feedback and to permit students to become familiar with the gradhg process, This would not be possible for remote audiences.)

    • (Individuals at remote sites can do workshops among themselves === lag these is more than one person at the site Results can be discussed for general review by all participants; however, .

cross fertilization / exchange ofideas between NRC Regional / Headquarters and State participants during the workshop analysis will not cccur, only during final discussions.) -

F9 4

- ~ _ - - . .g., , , m ,, -, .c- % - , _ __-.,o_v. .. .._. , , , , , . . ., .-m,, .. .._, ...m...,,_-c..m.

The limited number of courses identified was partly due to the lack of experience in electronic  ;

media presentation as well as the nu.nber of courses that have site visits and special smup activities that may no: be easily accomplished through the above training techniques. The Working Group also recognized that the resources to convert these course have not been -

specifically included in the tech *.al training budget. Therefore, the Working Group suggests that NRC consider a pilot or trial program to evaluate NRC's ability to convert a course tc u alternative presentation mode and evaluste the costs of conversion and implementation of the converted course. The Working Group did not identify any references that discussed distance learning experience with courses in the week or longer range. Such information would aid in the

. conversion and implementation process.

References

  • Distance Learning, A Step-by Step Guide for Trainers," IL Mantyla and J.R. Oividen, j' American Society for Training Development,1640 King Street, Box 1443, Alexandria, VA 22313.'2043, July 1996.

INFO LINE," Practical Guidelines for Training and Development Professionals, Effective Distance Learning " American Society for Training Development,1640 King Street, Box 1443, Alexandria, VA 22313 2043,1997

" Course Catalog," Technical Training Division, U.S. NRC, Match 1997, Inspection Manual Chapter 1246," Formal Qualification Programs for the Nuclear Material g

Safety und Safeguards Program Area,'- U.S. Nuclear Regulatory Commission, July 1996 E

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COST ANALYGIS INFORMATION ATTACHMENT 2

i

, i. e TRAINING COST ANALYSIS INFORMATION i ALTERNATIVES Altematve* to the centralized standard classroom training are (1) Regional trair ing conducted by NRC, a contractor, or a group of State instructors, (2) agreements with local universities and -

colleges, (3) enhanced on-the-job or in-house training, (4) other methods of delivery cf the NRC training, and (5) commercially available courses.

Regional Training - This method reduces some travel expenses but increases the cost of .

presentation if the course is presented more often than is currently scheduled. This method is used at times when a specific training need is brought to the Technical Training Dl vision's (TTD) attention. Examples of regional training include (1) the recent presentation of tne licensing .

, course in Region I which supplied eight students and two instructors and (2) a few years ago the inspection Procedures course was held in Califomia and Tennessee where 10 plus students

- were from the host States. .NRC Regional offices have hosted training courses for years with other Regions or Headquarters staff traveling to the host Region. The TTD has presented certain courses in each Region when the audience size justified the multiple presentations.

Agreements with Universities, Colleges, or other Providers - This method would reduce the travel and per diem expenses when these arrangements are with local institutions, This method could also include other educators such as local contract instructors that have the expertise to teach the essential elements for the subject area. This method has the potential to develop inte diversity in the material presented which could lead to implementation inconsistencies. This method has limited use in that there must be a local provider for this service or thls method is not practical.

Enhanced On-The-Job Training - This method saves the most out of pocket expenses but -

has some significant drawbacks. The level of instruction is dependent on the training of the-existing staff and their ability to train others._ For small programs this method may only be used

for State r;mcific training since extending it to the NRC course areas would tie up the staff of the program in the presentation as well as receiving the training and the licensing and insp6ction work would not get accomplished. For larger programs with stable staffing, this method would have less of an impact and has greater potential.

Alternative Methods for Presentation of NRC Courses - An evaluation of the presentation of NRC r.ourses through non-traditional leaming methods which are ideniifed in the NRC/OAS Training Working Group (WG) report is presented below.

~. Commercially Available Courses - 3em are many contractors that will provide training for a

> fee. The NRC uses these contractors for a portion of its training program and lists courses in its Course Catalog for which NRC staff can individua ly register to fill a specialty training need.

Several of the NRC contractors also offer the same course commercially.

1 i

Cost Analysis" 1  :)

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, . - - _ , . _ _ ~ , ,- . . _ . .

?

POOL OF STUDENTS i

- The max! mum audience for a new training course would be the total materials staff for both the NRC and the Agreement States. The total staffing for the Agreement States is approximately 350400 staff that currently work in the materials portion of the Agreement State regulatory program, in addition, the NRC staffing for the materials program and the health physics portion ,

of the reactor program (those potentially attending the special technical training programs) is estimated to be approximately 150 staff. This limits the maximum audience to 500-550 students.-

For most courses, NRC and Agreement State staff have received training over the years such that the maximum number of students in any one year is mainly the new hires plus individuais l who are expanding their expertise or have recently transferred to a different job that requires additional technical training. Thus, the maximum number of students for a given course would i likely not exceed 100 students. Distance leaming experts have indicated that this is a very small audience for some of the more high-technology oriented non-traditional training methods.

i EQQL OF INSTRUCTORS The instructors for the courses listed below include NRC staff, State staff, and contractors. The courses with costs in the right column are contractor taught. State instructors provide lectures in three courses. NRC staff teach the primary lectures in three of the courses. To be i consistent with previous costing analysis for Agreement State training, the non-contractor instructor costs (i.e., NRC and State staff instructors) are not included in the cost analysis.

COST PER STUDENT 4-The cost per student for traditional classroom presentation at a central location would consist of the cost of course presentation divided by the number of students plus the travel /per diem costs which will vary based on the location of the course and the student's location. The most costly course presentation on a per week per student basis ($30,200 for 16 students) represents a F - course tuition cost of J,cout $1,887 per student.- Agreement State student travel expenses range from near zero to $1,700 per student with an average of about $1,100 per student, based

on the Federal travel regulation costs, if the States are paying these costs, then the travel

g costs could be lower if the State can use advance purchase super-saver fares, otherwise the airfares are significantly higher, since they do not have access to the Federal airfare rates.

Travel costs may not be completely eliminated even if the course is provided via videoconferencing. The students may have to travel to a regional site depending on the availab!!ity of the equipment needed to receive the transmission.

- The costs vary based on the contract and the type of course to be presented. _ Courses that have a significant amount of the material that is presented through site visits, field trips, or

_ laboratory exercises may need to limit the size of the class, and thus the per student costs are Lhigher.-

n Contracted costs are fixedc Although one can determine the minimum cost per student by dividing the contractor cost by the maximum possible number of attendees, in reality, if fewer-

= students attend, the total cost will not change but the cost per student trained will increase.

This is true for all types of training, even videoconferencing.

. Cost Analysis ' 2

.. t COURSES CURRENTLY SCHEDULED FOR PRESENTATION l

The courses that are scheduled to be presented that both NRC and Agreement State staff

- would_ attend are presented in the following table with the estimated tuition costs based on the ,

curront contractor costsc All of the courses except two are a week in length or more.

Courne Courne Title Dalai Locahon Cost / Student G 108 Inspecton Procedures 07/27-31/98 Chattanooga, TN SO 09/14-18/98 G-109 . Licensing Prachces and 06/01-05/98 Chattanooga, TN $0 Procedures 09/28 10/02/98 G-205 Root Cause/ Incident TBD* TBD $1,080

. Investigation Workshop G-304. Inspecting for Performance - TBD TBD $191 Materials Version H 109 Applied Health Physics 03/02-04/03/98- Oak Ridge, TN - $6,042 H-111 Environmental Monitoring for 10/20-24/97 Oak Ridge, TN $1,275 Radioachvity . 06/15 19/98 H 117 Introductory Health Physics 07/13-17/98 Rockville, MD SO H-119 Air Sampling For Radioachve 06/08-12/98 Oak Ridge, TN $1,333 Materials H 120 Radiological Surveys in 04/21-22/98 Rockville, MD $667 Support of Decommissioning H-201 Health Physics Technology . 10/27-11/07/97 - Chattanooga, TN SO 04/27-05/08/98 H-304 Diagnostic and Therapeutic - 03/23-27/98 Houston, TX $1,887 Nuclear Medicine 08/10-14/98 H-305 Safety Aspects ofIndustrial 05/11-15/98 Niantic, CT $775 Radiography 08/10-14/98 H-308 - Transpoiinon of Radioactwe -04/27-05/01/98 Columbia, SC

$785 Materials 06/22-26/98 H-312 - :Intemal Dosimetry and Whole - 12/08-12/97 King of Prussia, $636 Body Counting : PA

~

H-313 : Teletherapy and 03/16-20/98- Houston, TX - $1,887 Brachytherapy 08/17-21/98

'H-314 Safety Aspects of Welt 11/03-07/97 Houston, TX $0 1 1.ogging;

H 315 Irradiator Technology TBD . Montreal, Canada $1650-

.TBD -To Be Determined - Dates will be set as additional information becomes available, Cost Analysis: 3 i

nm > -

-w -

.- LOST PRODUCTMTY 4 Lost productivity is the work time needed to accomplish the training course that is not spent in 1

- trainingc For the week long courses, students normally travel to the training location on the weekend and retum home on Friday aftemoon or Saturday moming._ Therefore, since the time in class and off duty time is not considered lost productivity, the only time truly lost is Friday aftemoon.-

For the shorter courses, there is the travel time both before and after the training since the ,

training is normally schedule so that all activities associated with the training may be . ,

acccmplished during normal working hours.

INFORMATION NEEDS FOR COST ESTIMATING For a detailed cost evaluation on a per student basis at least the fonowing information needs to e be considered:

1 Students (Learners) - to provide training in the most cost effective manner it is important to carefully evaluate the potential audience in terms of numbers, location, educational background, organizational affiliation and access to videoconferencing equipment or altemative training sources. ,

instructors - to provide training in the most cost effective manner it is important to carefully evaluate the instructors in terms of number required for each course, location and access to videoconferencing equipment (if that mode is to be used) and their level of familiarity with such

- equipment sad mode of presentation (i.e the need for extensive instructor training or, worst case, inebility to adapt to the technological requirements).

Logistics - to provide training in the most cost effective manner it is important to carefully evaluate the logistical requirements including the length of the course and whether it can be

' - subdivided into modules, the variation in time zones of the students and the instructors and the availability of local facilitators for ensuring the operation of the equipment, the availability of the materials and the proctoring of quizzes and examinations.

Infrastructure - to provide training in the most cost effective manner it is important to carefully evaluate the available infrastructure including the cost and availability of the equipment required

- for transmission and reception of videoconferenced training (if that is the mode selected), or the

= availability of computer hardware needed to run computer based training software and the . _

availability of support for the reproduction and distribution of computer based training software, printed materials and/or audiovisual training materials.-

x Course Content - to provide training in the most cost effective manner it is important to

carefully evaluate the course material to ensure that the appropriate method of delivery is selected given the highly technical nature of the training provided, the requirement for intra-fstudent communication or access to training aids or specialized facilities.

Cost Analysis = 4-

- .n: ~ ... . . ,-. - . ~ - , . - -: - - . . - --

-- - . - ~.- - - - -. - .- _ - . - - .- . - -.- - - . - - . .. . - - .

If, it should be noted that, although a particular. mode of delivery may be ideal for a particular course when considering only one of the information needs identified above, it may not be ideal when the other factors are considered such as infrastructure or Logistics. Therefore, all the

' above must be considered in identifying the most effective training modality. Such an evaluation requires a team approach, for which fully sufficient resources are not currently -

included in the budget .Therefore, the use of traditional classroom training for most courses, . ,

twhich has proven to be effective, will continue until resources are available to comprehensively l l- address the uss of other training modalities. .,

i -

In addition to the review of alternative training methods done by the WG, the Technical Training  ;

Division (TTD) of the Office for Analysis and Evaluation of Operational Data (AEOD) has

[ investigated the potential advantages and cost of developing attemative training methods. Part  ;

of this work has included attendance at multiple meetings of the American Socie.ty for Training L and Development (ASTD) including the Intemational Conference and Exposition, May 18-22,

! 1997, in Washington, D.C. and the ASTD Technical Training Conference and Exposition, l  ; September 24-26,1997, in St. Louis, Missouri.- Information gained from the experiences of

- other training organizations has consistently wamed that conversion to any of the other.

.. methodologies would require significant financial and human resources to modify the current i . materials to be presentable in the selected mode. The staff is not aware of any organization -

l that has successfully moved highly technical / professional intense course material, such as is normal in NRC courses, to altamate training methods.

5

[ Presentation of a course in any of the distance leaming or trainig methods requires conversion

. of the training material into a format that is amenable to the method being employec;. .

! Conversion to any of these methodologies would require significant time and resources to j modify the current materials to be presentable in the selected mode. The costs for conversion

and presentation identified at this time are
- e Course material conversion (speakers at the ASTD conferences consistently wamed against attempting to accomplish such conversions with in-house resources and strongly recommended that it be performed using a team of experts which would involve contractors particularly in light of the complexity and amount of the training materials.)

e Trainer training and practice given the media selected (speakers at the ASTD conferences indicated that when using videoconferencing, a presenter requires eight

hours of preparation and practice for each hour of presentation) Of course, tHs
limitation is not applicable if the mode selected is self study.

o Media presentation development (v!deo/ audio tapes, scripting), for some methodologies.

4-

.e Equipment purchase / rental / scheduling and technical support for NRC/ States, for some

methodologies, i To develop materials for presentation using the newer electronic media,- the consistent g recommendation is that a team of professionals be assembled. For videoconfersncing, thia
team would need to include course topic technical specialists, training specialists, and . ,

, communications specialists while for other methods such as Computer Based Training (CBT) the team would need to include Programmers and Content Experts, Interface Designers, Writers, Editors,- Researchers, Graphics and Sound Professionals and Animators and Vxleo

. Professionals. '

VCost Analysis? 5

. ..  :.: = - . -- . .- . _ _ .

COST EFFECTIVENESS OF NRC TRAINING FOR NRC AND AGREEMENT STATES Considerations of cost effectiveness of training must include consideration of the NRC's Organizational Values and Mission Statement as well as its Veion Statement that all -

stakeholders have the utmost respect for and confidence in the NRC. Such a statement would apply equally to the Agreement States.

Gince the majority of the NRC courses available to the Agreement States involve Field Trips, Exercises or other ' Hands-On" activities, these courses will be continued in their present format which has proven highly offective.

The primary method of evaluating effectiveness at present is the examination administered at the conclusion of the training course; However, there cre also many intangibles associated with training effectiveness which may not be readily observable. Subsequent " performance based' evaluations of the overall regulatory program such as is accomplished through the Integrated Materials Performance Evaluation Program (IMPEP) review may provide a more " practical' indicator of training effectiveness.

For Agreement States considering altematives to NRC training, the staff believes that potentially cost effective methods include Regional training by a contractor or Agreement State instructors, universities, and in-house and on-the-job training.

The staff has also generally evaluated the cost effectiveness of the current presentation  !

methods for NRC-presented courses and presentation altematives identified in this paper. With no cost to the Agreement States for course development, the option of cost-free space available attendance (with the Agreement State paying only for travel), and NRC limited funding for training and associated travel based on individual Agreement State need, the staff concludes that current methods of NRC training course presentation to Agreement States are cost effective from the Agreement State perspective. In addition, for certain training courses, some Agreement States may also find it cost effective to reimburse NRC for a pro rata share of the technical contractor costs (i.e., pay tuition to NRC). Current methods include not only course presentation at the Technical Training Center but also the presentation of some courses at White Flint North, NRC Regional offices, and at NRC contractor locations, which facilitates attendance by Agreement States that are near these training locations.

The cost-effectiveness of training presentation methods depends mainly on the cost of course development or conversion and the method of presentation, the cost of attendance, and the amount of the knowledge imparted to the student.

Costs for the current mode of course presentation (traditional classroom) for a typical NRC taught five-day course include the typical travel costs (transportation, lodging and per diem) and range from $500-$1,500 with an average of about $1,000 per NRC student if a course is converted to another mode of annual presentation, the cost of conversion and presentation would mainly be compared to the travel costs saved. For modes of presentation such as self L study, the cost of conversion'would be compared to only the cost of travel. We will still need to provide manuals and the student time will still need to be dedicated to the training.

- Fur a 24 student class taught at an NRC facility by NRC staff using the traditional classroom

- training mode, the total cost would range from $12,000 - $36,000 (about 97% from travel related 6xpenses). The range of costs depends on where the course is presented and the cost Cost Analysis 6

4

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for the instructors to travel to the training location could increase the estimate by several-

, thousand dollars depending on location.

. For the same class size and training mode taught by a contractor at an NRC facility,' the manual .

g costs would be in the contract but the other costs would be the same plus the contract =

expenses (up to $35,000) for a total ranging from about $47,000 - $71,000 (about 45% from travel related expenses) or about $2,000 - $3,000 por student.

L For courses taught at the contractor locations, the contract costs are sometimes higher or the ,

class size limited such that the cost per student is higher or the total contract costs are higher -

than was used above for the in-house contractor course example. The location of the contractor also affects the travel expenses. Therefore, the total costs for a contractor location course could cost up to an additional 10 to 20% of an in-house contractor taught course.

Since most contracted courses involve site visits, field trips, and hands-on experiences with

' specialized equipment, these courses must be taught on-site with the students traveling to the l contractor's designated location. Although the lecture portion of these courses could be presented through distance loaming techniques, the hands-on portion would require travel to F such facilities locally or to the contractor's location for this portion of the course. This would

require significant coordination with the student's office to arrange this portion of their training

- experience. This imposes an additional burden on local management but it is feasible.

[

The NRC has some limited experience with contrac, tor produced Training Videotapes: AEOD E has produced several 20 minute training videotapes extolling " Good Practices' in medical institutions and Safety in Industrial Radiography. Each of these short videos, required about one year to produce, cost approximately $110,000 and required approximately 120 NRC staff-hours, A 100-minute training videotape covering the new 10 CFR Part 20 regulations, required about one year to produce, cost over $100,000 and engaged considerably more NRC _

. resources.- The Office of Public Affairs (OPA) produced a 20-minute video entitled, "Public Safety and the NRC," which required about 2 years to produce, cost about $80,000 and took

about 0.5 FTE for Project Management.

All of the above mentioned videos are relatively simple, using individuals to state the message, 1 supplemented with some computer graphics or on-site footage. The above listed costs for <

i these videos dealing with diverse subject matter are, in general, consistent. It is evident that an

entire one week training course accomplished in this manner, at a cost rate of up to a L maximum of $1,000 - $5,000 per minute, would be very costly.

Not all modes of delivery will be equally effective. Given the content of the courses, there will be inherent differences in effectiveness among the various modes. i in addition, for any given

-_ modality, there will be differences in the receptiveness of the individuals comprising the -

audience. Given the traditional training method as the baseline, it is possible that

_ videoconferencing may be more effective for some students but less effective for others while -

the situation may be reversed for CBT. Although it may be possible to estimate the costs of conversion to alternative methods in advance, the effectiveness will not be readily evaluated -

E until the new method has been fully implemented For example, all of the non-traditional l delivery methods,- or combinations thereof, eliminate the cost of student travel and could eventually result in a significant NRC and Agreement State cost savings. However, any

- estimate of the effectiveness of the alternative training method would be speculative and

. subject to wide variability given the diversity of the audience (both in terms of educational I

L Cost Analysis '_ 7 m

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I background and ability to interact with modern technology). Effectiveness vanability based on

_ diversity of student backgrounds may be a common factor for all presentation methodologies.

EQUPMENT The NRC has purchased videoconferencing equipment for each Regional office, Headquarters, and the Technical Training Center. Currently this equipment is not amenable to effective . >

distance training since it can only be used to transmit information from one site to one other ,

4 site. To be cost effective, it will be necessary to communicate from at least one site to all other

, sites with enhanced cost effectiveness when the individual instructors, which may be located ,st several different sites, can provide that instruction from those sites. In reality, to be truly 3 efficient and to prr' duce an effective class leaming environment, all sites must be able to :

communicate with all other sites nearly simultaneously.

2[ Other methods of course presentation such as computer based training or other self-study  ;

e methods could be implemented without significant additional equipment. The major cost for th.s

, training is the cost of conversion of the material for presentation.

The istaff has' not conducted a survey of the States to determine the availability of the

, equipment if distance training were to be initiated by NRC to provide technical training to its staff. The State of Texas used videoconferencing equipment to participate in a conference call with the Organization of Agreement States which lasted slightly more than an hour. Other State callers did not have the equipment available to them. The availat ility of the aquipment for time periods of one or more weeks at a time is unlikely given the need to schedule the time well in advance.

TRAINING NEEDS New course development for NRC and Agreement State materials program staff during the next h few years is not anticipated, so costs of attematives are almost exclusively associated with the use of non-traditional delivery methods.

In recent years, the NRC staff hac made up less than half the students in most materials program coursesi The majority of students attending NRC training came from the Agreement  :

l States with additional attendees from other segments of the Federal Govemment, such as l DOD, DOE, DOT, and EPA, with a small number being representatives of foraign regulatory

. agencies. The Federal agencies and foreign representatives will not be considered further.
- The cost effectiveness of this training will need to include the impact on the State staff and their availability to participate if altemative training methods are used for the presentation of NRC's training program. Historically, the Agreement States have had sufficient training needs to fill s'l available space in the '. C training courses. With NRC discontinuing the funding for training

' and travel, some Agreement States have not had enough funding to meet all of their training needs The training needs identified by the Agreement States for fiscal year 1998 exceed the capacity of the NRC courses. A portion of the Agreement State training need identified to NRC

, does not have State funding for the travel associated with couras attendance. .The Agreement  :

!. State students that have funding will continue to be selected in an equitable manner and those '

students that cannot be accommodated will be considered for the next available course.

1.

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