Text

Integrated Assessment of Training Needs for Reactor Projects Staff
	ML20205L003
Person / Time
Issue date:	01/12/1999
From:	; NRC
To:	;
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ML20205K986	List: ML20205K981; ML20205K997; ML20205L003;
References
	NUDOCS 9904140088
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January 12,1999 (10:00AM)

Integrated Assessment of Training Needs for Reactor Projects Staff Contents Purpose

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7 Discussion..... $ib. Mt...................... E.l.k......

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h Recommended Tral.riliig anddialification Program for React ci.dlafil....

...... 5 Basic Trainin~gProgram:

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.... 5 t0Eed Self1S Fundamentals'o i. dy.of Regu 6,.0 do,ur Struc. n e

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Fundiihentals 6f fspeElidn (or Lic5nsl6$ Dour

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.... 8 Inc. dent Response ing..... e..

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... 9 Advanced T/aining Prhyldm.6... g h@.1 h)$ tors

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.. 10 Effehtive Com uHicatidh for NR Igbl

.................. 10 Perf6fniance-ased To" niques Ises........................... 10 P RAVlikining k.... !:. '...................................... 1 1 StruMEfed OrFthe-job iiial$ng Post-Oualifinfon Tfiliiing PrIgram. (OJT)..............................

....................................12 Rea

.P.ddiam Update Training................................ 12

Ref, r>Tra i ni n g............................................. 1 3 Col In g Trainin g...............,............................ 13 Pfa'nt Specific Training......................................... 13 Resources and Planning...

................................................14 Cost Estimate for Recommended Training Program...................

... 14 Resource Comparison (Current vs Recommended IMC 1245)................. 17

. Attschment 1 - Recommended Training Program for Reactor Projects Staff. Attachment 1 - 1 l - Review of Regional DRP JTA Training Recommendations... Attachment 2 - 1 - Review of NRR DRP JTA Recommendation.............. Attachment 3 - 1 I

9904140088 990323 I

PDR ORG NRRA PDR

1 Purpose Job task analyses (JTAs) for the Regional and Nuclear Reactor Regulation (NRR) Divisions of Reactor Projects (DRP) positions were completed in August 1997 and July 1998, respectively.

A JTA is a systematic method used to obtain valid task lists for specific jobs, as well as importance, difficulty, consequence, and satisfaction rankings for the tasks, which can then be used for job redesign, development of job descriptions, training needs assessment, and curriculum development. A number of recommendations regarding staff training activities were made by the contractor in both JTA reports, in July 16,1998 and August 25,1998 memos from the Director, NRR to the Director, AEOD, the Technical Training Division (TTD) was requested to review the contractor's recommendations documented in these reports and develop actions to address the recommendations. In November 1998 the Commission approved the consolidation of TTD and the Human Resources Development staff of the Office of Human Resources within the Office of Human Resources (HR). This report comprises actions recommended by the new consolidated training organization within HR to address needed revisions to the regional and NRR DRP staff training and qualific rograms.

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Although the JTAsfan$lhe d provided results for regional D nc Chiefs (BCs),

Project Engineers (F3Ed), S r, Resident inspectors (SRis), a esid nspectors (Ris),

and for NRR DRP fdject Di ors (PDs), Project Managers a

sing Assistants (LAs), the review focused pn y on developing

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g required for Resident inspectorfadd Proj ana ositions

" vie s lim due to time and resource constraintiTEnd to n act NEtie d o

that env ed to produce the highest payoff. JTA6sults ir@di6 / eft ihste t T82 r.

1spe ask 8 require initial training and 118 requiro perio eir trdininydn i 197 ct ger tasks,156 of recommendations, based o%q' irefpp, odic refn$s require initial training tihd 106 u

ining his rprovides a number j

rpJTA res its and ott)gr p,p,nent) uts d gsed below, that are intended to improve the quali pnd consistency of reacto proje staff ning programs and job performance.

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Discussion n,

in September 1998pa. detail evie he Regional DRP JTA report was completed and a number of actions 6$Eessa addr he contractor's recommendations were developed. A preliminary report v$5)p ro to N and is included as Attachment 2 to this report.

Subsequently, the 3fi e NRR DRP JTA report was begun. As this review progressed, many similarities a git ks and KSAs for regional and NRR positions, the need to apply the actions necessa

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dress the regional DRP JTA contractor recommendations to any resulting NRR D P training program, and the potential for effectiveness and efficiency gains 1

that could result from implementation of a consistent, parallel training and qualification program for both regional and NRR DRP staff were noted.

The NRR DRP JTA report indicated that NRR project managers feel undervalued and would like greater opportunity for professional growth. One likely reason for this observation is the l

lack of a comparable level of training required between project managers and their regional counterparts even though the level of knowledge and skills required is similar for these positions. Instituting a comparable formal training and qualification program for project i

managers would tend to raise their stature and attending some of the same courses would 2

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increase the appreciation these positions have for one another's role in the regulatory process.

This also would provide for greater consistency in implementation of joint and interf acing responsibilities since both positions would get the same message (i.e., same training on policy and processes.) Similar parallel training programs would facilitate movement between inspector and project manager positions and potentially enhance the ability of staff to move to supervisory positions in either the region or NRR DRP organizations.

l From the new consolidated training organLation's perspective, the most effective and efficient means of meeting the training needs of both regional and NRR DRP staff is to consolidate the actions into one combined prnject. This report recommends revision and restructuring of Inspection Manual Chapter (IMC) 1245 " Inspector Qualification Program for the Office of Nuclear Reactor Regulation Inspection Program" as well as development and implementation of a parallel training and qualification program for NRR project management staff. A preliminary report of actions to address the NRR DRP JTA contractor recommendations was provided to NRR and is included as Attachment 3 to this report.

ed to address contractor recommen'd ns rimarily based on Specific actions (Il5NG5(i51op'ct Manager JTA results. However Resident inspectorsnd Proje

~ 45su s for the other DRP positions were revie0 ed and]dr3 raining and qualification progra

ededM Ris, SRis, and pes iddicate that a similar KSA base i such that the revis5dinspeci ui@lsobe implemented for Senior Resident 165pecto'rl5End Project Enginee[sgBecaus!

e6%ew Licensing Assistant positions,?a6d their} tasks arey(arge adtplril veI5l ure,j not considered an Eial ing ram Licensing l

efficient use of agepc{resourde's'to'ddyel '

spp"ults f Assistants. It is recommende'd%ased'o$

re's is position, t applicable portions j

of the proj nt manad5Etraininghn'd qualif a on ygr s wE[l[As exis} lng nontechnical training courses, be irWplemented to proiyl'de Licensiq ssistan'ts%eedebSAs.

f With regard to Brari Chiefs i d Proh Directors T sult owt imilar KSA base as for Resident Inspectors ornoject Mahagers, refpeg; ly,is%8eded. This suggests that newly assigned BCs;or PDs shpuld c%lete an jn rjnbject manager training and l

qualification progra_ngequirements notgeviousi ;

. For example,if they were promoted from the jgpector projecganager s and previously completed the inspector or project manager training igualifMion program, upon assignment to the BC or PD position they shouldhlfead ssessgeMSAs indicated by the JTA for the BC or PD position supervisoryteIrid management KSAs, (2) a broader knowledge of with the exception g) thap what will be covered in the recommended inspect Management Directives

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program and (3) a tir'osdeFand more detailed knowledge of region or NRR-specific policies and I

procedures. The JTWdid not focus on nor was the agency's supervisory and managerial development prd@ams reviewed. Structured self-study modules could be developed for items (2) and (3), if desired. Separate from the JTA, however, there are a few currently required courses that probably should be included in a formal BC/PD training program. These are: The CFO's Program and Resource Management training, the ClO's Information Management course, and the PRA for Technical Managers course (unless the person completed inspector or PM PRA training within a couple of years).

After development and implementation of the inspector (i.e., IMC 1245) and project manager training and qualification progtams are completed, comparable programs can be more effectively and efficiently developed for other positions, as necessary. In the interest of consistency and effectiveness, particula'r consideration should be given to appropriate revisions 3

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.a for regional Division of Reactor Safety inspector disciplines covered by IMC 1245 and Office of Nuclear Materials Safety and Safeguards (NMSS) positions covered by IMC 1246 " Formal Qualification Programs in the Nuclear Materials Safety and Safeguards Program Area."

In addition to the JTA results and contractor recommendations, recommendations from other training-related reports were also considered in formulating the training and qualification program for reactor projects staff recommended in this paper. In response to an Executive Director for Operations (EDO) request that the technical training staff provide recommendations for better integration of regulatory knowledge, skills, and abilities (KSAs) into the technical training and qualification program to improve the regulatory skills of the staff, a staff paper titled

" Regulatory Skills Training Integration Plan" was developed in February 1998. It included a number of recommendations intended to improve the quality and consistency of reactor operations inspector regulatory training. Similar improvements were recommended for other inspector disciplines and reactor program staff.

In April 1998, the Executive Council formed a Training Review Group 4TRG) led by Jack W.

Roe, NRR, to rev'le@Ihe"hagency's training activities in order to idedtif iways to improve the effectiveness and shipinciy4f the agency's training function in "pkringMRC employees to 3

perform their dutiesDThe teidh' delivered a final written report i ptembH 1998. One of the nic'$ pingjactivities to team's recommendEti6'ns wa's!" Review, evaluate, and formaliz f trdi ensure provision addf6aintehance of regulatory, technical, noni skills as appropriatitojjob pdsiti6ns and, fun 6tions(ij?s'OkortiEd ; ag%

mission and goals.

the Job Task Analyte 9for NRRind R66Io/nibthddology.includihal"DiA5fons Use standard syste'riisiapproshh to tIsliiIn the results and insights of encyM6[e cap 513ilitiesTsisessment."

Paper on Regulatory,S' kills Inthgrationfahd th'e a#

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6 OlG Report 95A-043 inconsistency in t$ Operating'Re' actor inspectio ogram N @(,

$O following with rega6td inspectoir trairiing:

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... NRC's on-the-job training prohram is loo 5ely structoredand not closely rnonitored. In addition, the coh" ept of agency traididg needsiirh,pf6{dinent, particularly regarding certain aspects of insp ting, suchis thefidw to's' 6f,f hdamental inspection techniques.,, "

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&d OlG Report 97A-21 evievCbf tthe P bt Manager Position in the Office of Nuclear Reactor Regulation"was al;

view'e). Ret to staff training and qualification, this OlG report stated:

"We also fou

'NRC has not provided adequate management oversight to ensure PMs are suffi8ently trained to perform their jobs. For example, in 1989, NRR established its current guidance which idutied the types of training needed by PMs to perform their various assignments, but this guidance has not been followed. This has resulted in a disparity of training among PMs. In addition, PMs are expected to perform certain job tasks without receiving formal training in how to accomplish those tasks.

Ineffectual training oversight, combined with the lack of clear PM expectations and competing job demands, may prevent PMs from achieving their maximum effectiveness."

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Since this report integrates insights from the Job Task Analyses for NRR and Regional Divisions of Reactor Projects staff, the TTD White Paper on Regulatory Skills integration, and the OlG reports, implementation of the actions contained within this report should resolve JTA contractor recommendations, TRG recommendations, and OlG recommendatioas related to training for reactor projects positions. Actions developed within this report, as well as the results of further analyses of JTA data, will allow design, development, and implementation of appropriate training to provide the foundation necessary for reactor projects staff to effectively and efficiently execute their tasks in support of NRC mission, policy, and goals. It should be recognized, however, that ongoing agency initiatives currently being designed in accordance with the EDO's tasking memo such as changes to organizations and positions, licensee i

assessment process, enforcement policy, risk-informed regulation, and revision of the inspection program must be well underway and communicated to the training staff before appropriate training can be designed and developed.

Recommended Training and Qualificat!on Program for Reactor Projects Staff ouQtlid jor elements of the recommended h ang qualification l

program for reactor.pr,ojects ff. This recommended progra

% d and structured to address JTA, TRGMand Ol ommendations and to efficient d eff ively provide the r

level of KSAs indicat6h by t sults of the JTAs. This progr pi dundancies in the current IMC 1245 (6 gram, treamlines, ntegr d

ce rning activities such that each subsequent;activit lds andpxy pds revi etivi The program maximizes the useEfjxistin ind.mgijiz unt sou necessary to

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levels of training:

Train g;to th c telop and implem'eht the pioggnm.

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' asic Training, Advanced Training, ar} ;Ppst Qu 5

arallel pal s for r{ actor i 3 ction staff (left

,.rogram is further stfuctured alohg ty%ght boxe l

boxes) and one for!NRR licen_ sing l staf ajo progra lekments are explained in more d,et,a,il in they yowirgaragrap gg

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The basic training (rogram i

. ml to foc fundamental KSAs. The goal of the basic l

training program is!toimake p Lyi dividua productive as efficiently as possible. For l

maximum effectiveh50~s, th ining ies within the basic training program should be done d

tbe before any of the Advanced Training Program in the order presen[t(5{and mpleting the Basic Training Program, staff should be able to l

activities are begurii fter perform routine job;f6Wct%ns with some limited supervisory oversight. An interim qualification status should be oo, risidered for most individuals at this point.

p Structured Self-Study l

JTA results indicate that most tasks require a detailed level knowledge or working level knowledge of specific policies and procedures for successful task performance. Structured self-study is necessary to ensure an appropriate level of knowledge of policy and procedures specific to one's job. As currently implemented, IMC 1245 initial training attempts to provide inspectors,with a smattering of everything they may possibly need for their inspection career.

The program meets the intent to r greater or lesser degree depending on the specific training activity and/or the individual efforts of the student. IMC 1245 currently does not define precise 5

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requirements or measurable standards for satisfactory completion and management verification of self-study or on-the-job (OJT) activities. Since these are simply alternate training methods, the same standards and controls that apply to formal classroom training, i.e., learning objectives, lesson plans, standards for successful course completion, etc. should be implemented for self-study and OJT as well. Self-study and on-the-job training activities should be more focused, structured, and sequenced to increase the effectiveness of these activities. It is recommended that current IMC 1245 self-study and OJT activities be streamlined and focused to cover only those activities specifically needed for performance of he priority tasks.

Self-study activities are most effective if they precede and tie directly to a subsequent formal course or on-the-job training activity (i.e., the student reads and studies the document, then has an opportunity to discuss anJi apply it). A structured self-study guide would be developed for each document for which a detailed knowledge or workirig level knowledge is indicated by the JTAs. Each self-study guide would be structured to include the objective of the activity, specific actions required by the student, specific requirements for management involvement and oversight, and measurable standards for acceptable completi f each activity. Related guides would be c'EnWi55dinto a module which would link to a f u e and would be r

required as pre-woMfpydguisite for formal course attendan i*s grates and sequences learninfEdtivities*such that each subsequent activi Jilds expands on the previous activities.[Thb qualifi$htion guides could be develope 3 co otor or by NRC staff. In eithw case,IEh'is eff5tMould require involvement by Ehd,.

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g RTNj I [t Fundamentals of R6gulatio[nic$ursel 9W"y @h

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Development and iihh$ mentation!of aWew Fundainen of R

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recommended for in~ phetion SN$licerisInb personnei.'

pur "e of th'e^tdurse would be to s

establish a consistSritjegulat6iyllinow" ledge base fof al.

Cr lor pr$girEm staff. This new course would ccvef the followl,ngjignifiddnt topics:1

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$44 Legal authorityb{ the NRG ')J i

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b Ch pplan, the ' hjhmission, and staff in regulation; The role of the CEgress G

NRC culture art nag lon; ph

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nt hy; Principles of Gq eg Strategic Plan t nning dgeting, and Performance Management Processes; j

NRC organizatij J

NRC regulator $

ework; i

Regulatory process; Regulatory documents; Understanding NRC regulations; Integrated regulatory asjessment process; Licensing, inspection, Assessment, Enforcement Relationship and Processes; Case studies in NRC regulations; Risk-informed, performance-based regulation; Compliance and safety; Allegations; Hearings; and Freedom of Information Act.

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i A portion of the subject matter currently covered in the Fundamentals of Inspection Course (FOlC) will be moved to this new course. (FOIC will be retained and may be revised to include subject matter necessary to fill task and KSA gaps identified by the regional JTA). In addition, the course willinclude material from the NRC: What it is and What It Does and The Regulatory Process courses, Allegation training, as well as subject matter for which new training materials would have to be developed. The course would be developed and taught by a combination of reacter program subject matter experts and agency training staff.

Reactor Technology Training The JTAs verify the need for detailed technical knowledge of plant systems, structures, and components as well as detailed knowledge of: integrated systems operation; radiation / reactor accidents and incidents; abnormal conditions in power reactors; emergency and containment features; plant licensing basis, updated final safety analysis report (UFSAR), and technical specifications (TS and how they are applied; licensee definition o rability as presented in the plant's technis)diT[EEiiications; and working level knowledg ntgonditions and associated rules and 5~g01ations; control room instruments and nsq ment; generic

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7 reactor operating p$bl, ems @hd,ed operation of reactor systepty as tion

,eactors; and sbfety i

es a strong need aspects of the desiggnd in for inspectors and project maggers to successfull omplete ic reactor technology traininggch is spjo7.a,llygsged ss bje tter. Therefore, the current IMC 1245 reactor tectinopgy training.re m

for tori ctors should be retained. In additidS$ilis rec $ffimend5ft6At311 curren d fut proj planagers complete o'r PWR Eoss tralNirig cEursNil ng cor tion e Westinghouse full a full course seriesj(dE{ plant d$Md'n fo6vbich thefAreQignec pept should make courses series) for;t ana MEminati6tEsifor ekkerienced stdN pspppr '

' revise l pddition, the content te. l use of equivalency @6tachnolodhtrainihgishould be$ valuated Is necessary to and length of reactb support the new risbinformed ba'5elinE;irispectionyro *.

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Since the large majoSty of thejtpden@hopulatio, )

r technology training has been e

regionalinspectorsythe regugtory skillgovered e courses are heavily weighted toward inspectors. While ost of th'asd skillshould als beneficial for project managers, there may hat cMb be n%'f' ore, it is recommended that in addition to use dlin these courses to specifically provide project be some adjustmeg gth. There manager job skill rgggi{emp/t work with project managers that have been both i results, agency trainin. taf s

Ye completed reactor technology training, to identify adjustments that project managers, "

[f both inspectors and project managers.

would meet the nee.

pr The JTAs validate the need for vendor-specific simulator training for both inspectors and PMs.

Vendor-specific simulator training is a highly effective and efficient method for reactor projects staff to achieve a comprehensive level of understanding of vendor-specific system design and operation, integrated tvstems operation for all plant modes, plant transient and accident response, and application of emergency procedures and severe accident guidelines necessary to support inspection and licensing decisions. Vendor-specific simulator training provides the student with direct experienco of all plant modes, numerous transient and accident conditions, and practice in assessing the regulatory and risk significanco of various plant conditions.

These skills cannot be provided in the classroom or through OJT.

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l Integrated Regulatory Assessment Process Course Both JTAs identified a weakness regarding the lack of training on the current processes for assessment of licensee performance including Systematic Assessment of Licensee Performance, Plant Performance Reviews, Senior Management Meetings, Enforcement Policy, and license review processes. To address this weakness, development of a new Integrated Regulatory Assessment Process course is recommended for project managers and inspectors.

This course would cover the JTA tasks and KSAs related to assessment of licensee performance. Development of this course would begin immediately following approval of the new assessment process. The course will cover policy, processes, and procedures as well as include practical exorcises to provide thG skills necessary for implementation of the process including licensing, inspection, assessment, and enforcen snt activities. The course would be developed and taught by a combination of reactor program subject matter experts and agency training staff.

Fundamentals of In,sgection (or Licensing) Course

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9 The Fundamentals:of l[pspe'6 tion course (FOlC) will be retained o 'Ever3some subject matter will be moved to the3ew FliNdhmentals of Regulation course d ssedjfeviously, and subject matter necessary tsfiilitask End KSA gaps identified by the re JTAnilay:be added.

j of Licensin$cour talle[

nd als of Inspection Development of a ame course)is recommelidhd. ThisI6ursWNodld pro 0ide an!ilitrod on arid 6verview of the project manager's jd8"and coheE$rojd6tIrnlEagefidskdlErid ass lated $p:This S'As related to policy, principles, and procsEses for [esctor IIdin'siig ac~'ivitie for Licensing Assistdnts. Exaihple tadksjnclude:" 4@$$

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Process amend @m$

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pg SQ Process ordersg forcerddnt dishrdtion (NOE Process notice of requests; Process 2.206 Nions;%

h6 Perform lead pr9jyt manader tasksht Multi-plant Actions (MPAs),

Generic Safety 3s ues (GSis) andDnresolved Safety issues (USIs);

Manage indeprTn' sWSht fuct storage installation (ISFSI) activities; Manage improv$$

Mnversions; and Manage deco,rdi $foning and licanse terminations.

The course would be developed and taught by a combination of NRR subject matter experts and agency training staff.

Structured On-the-job Training (OJT)

OJT is required to facilitate the transition of learning in a self-study or classroom environment to application in the job environment for high priority tasks. As part of basic training for project managers, an NRC headquarters (HO) assignment with an experienced NRR project manager, preferably associated with the reference plant or a plant of similar design, is recommended.

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The OJT activities in HQ (preferably performed after Fundamentals of Licensing course) would l

include observation or participation in, for example, routine licensing activities, SERs, public hearings, review of operating reports, interactions with licensees, regions, technical review, OGC, etc., Commission meetings, etc.

The parallel basic training activity for inspectors would require an on-site assignment at a reference plant or a plant of similar design with an experienced Senior Resident or Resident inspector. The on-site OJT modules for inspectors would include On Site Systcms Walkdowns (preferably performed after completion of the reactor technology systems course), Plant Operations Observations (preferably af ter completion of the reactor technology series simulator course), and Resident inspector Shadow (preferably performed after completion of Fundamentals of Inspection course), Self-study of plant specific licensing documents, plant procedures, and databases would be included as part of each of the on-site OJT modules.

The program is structured to provide the student formal training in regulatory and technical knowledge and skills culminating with the OJT activities which alloyyghe student to integrate, et nowledge and skills in the real, bu%ru6tured and supervised, job prioritize, and appfyE3w)'nt would include job spe setting. Each OJT;assignrpe to high priority tasks' and KSAs indicated'bVld by 18s" student, specific requirements "igbjecti/e the (TAs and be structured to include t s specific actions reqEire ejyisoryjoversight, and table completion ofpach acti egl.jhIification guides could measurable standaid@for accep$by NRC staffh in pjthA@ase, be developed by a Eonjracto(or ffo "uld require involvement by NR$alnd regiorn} sutijepi tristter ijgpeg@as wo]g sa training staff.

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JTA results indicatskhbt respainsN to events and incide s'is a 6 h consegudnce and high difficulty task for bdih"ibspectors and project manag'ersMhis sfrangly iridic 5tes a need for initial and periodic training'.9This training is currently pro'vlded6y the ricident response staff. It is recommended that this trainirig be formalized andiinciddeddn/ e" formal training and h

qualification progra'msjor inspect' ors ajd project)nhrjd(ejd.

$d Information Tech ology Trdining 9 ut ed Mf pid Information techno knoiv,l6dge and' skills necessary to support reactor projects staff duties and responsibilitiasy (d't$6 identified. Relevant training should then be developed and incorporated into tilei training on the foljohng so$I training and qualification program for these pos ftware, for example: AIRS, ADAMS, NT, Corel 8 training, etc.

Effective trainindf6r information technology knowledge and skills may be integrated within various technical and regulatory skills courses, or separate IT courses rnay be required. In addition, the need for periodic continuing and refresher training for information technology should also be evaluated and implemented.

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Advanced Training Program The Advanced Training Program builds on the KSAs acquired in the Basic Training Program.

Therefore, all Basic Training activities must be successfully completed before any Advanced Training activities are begun. Like Basic Training, the Advanced Training activities should be completed in the order presented for maximum effectiveness.*The Advanced Training Program activities provide broader and more detailed knowledge and skills necessary for independent job task performance. The use of performance-based training methods such as case studies and role play will be incorporated to the maximum extent possible to ensure direct application of classroom activities to performance of tasks on the job. The goal of the content and structure of the Basic and Advanced Programs is to provide a complete, comprehensive series of training activities that build on each other, avoid duplication, and effectively and efficiently provide the appropriate level of job knowledge and skills for successful independent implementation of job j

tasks required of reactor projects staff.

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Effective Communications for NRC Regulators g

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M A significant numbe$of hid$r{ority tasks require effective oral $n rift communication skuls. Therefore, itil5Yecommended that the current course titl6ENffecti Communications for NRC Inspectors (IMCd245-f fQe Communications fofNRC Re% ired course for inspectors) be rlbiille,d gulators and adjustments'be made71idhe address applicable %oject m' nkger KSAs ashellss'ihi$ ecto %'a6l a

S'As. Nils course should also be revised to includdiwritten corn' usiha'tlo(ifsNills(direc'tivfapplic

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m Inspection ReportsTrid SafetYifvalualidn Report formst/contenM(or example) and include i~

job environment. Th6 Effectivb1ComrnUnications for NRC Inspd6[ ors colh i

t contracted. Agency tfaining p'irsonndlfih conjunction wittj NRRiind regidflaf staff, will have to I

determine the most' effective Andefficidrit method.to prbVide thsihsw co0rse.

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$N Ih hM Y The current Fundanibntals ofilhspectihiY$1nspectinpfor Performance, and Field Techniques and Regulatory ProcessEsYcoursA@for ins"e~ctors werd developed and implemented at different times in the past a

f6r ditf8Mnt, b ATed purposes. While the JTA indicatos that the essential elements esdc#,ourses still needed, the JTA also identified gaps or weaknesses for a,

b"s$ In the interest of efficiency, effectiveness, and completeness, it is core inspection prddb$erf6t"related high priority tasks and KSAs such as implementatio i

recommended thaf$eTe three courses be reviewed, revised, and restructured to result in two I

courses. The twWresulting courses would be a new Fundamentals of Inspection courso (discussed above under Basic Training) and a new Field Techniques and Regulatory Processes (FTRP) course. The content of these courses would be based on high priority tasks and KSAs related to implementation of the inspection program in support of the integrated regulatory I

assessment process. The new Fundamentals of Inspection course will provide knowledge of

'aspection philosophy, policy and procedures, while the new Field Techniques and Regulatory Processes course would provide skills necessary for implementation of the inspection program.

The new Field Techniques and Regulatory Processes course would be heavily weighted toward ase studies and workshops to allow for performance-oriented application of the tools and 10 1

l

techniques taught. The course would be developed and taught by a combination of reactor program subject matter experts and agency training staff.

)

Development of a Reactor Licensing Practices and Procedures course (roughly parallel to the Field Techniques and Regulatory Practices and Inspecting for Performance courses for inspectors) is recommended for project managers. This course would provide skills necessary for conduct of NPR project manager's high priority, day-to-day tasks. This course would cover licensing procedures and provide practical exercises for students to demonstrate the application of routine licensing practices and procedures. Case studies would be utilized to illustrate methods and practice skills required for processing licensing actions and other licensing activities. The course wou!d be developed and taught by a combination of NRR subject matter experts and agency training staff.

PRA Training The NRR JTA digo,t,i,dentify any PRA-related tasks or KSAs. H r, it is assumed that project managerswillirEkdire a knowledge and skilllevel approxirga e al to inspectors (i.e.,

PRA. Technology and Regulatory Perspectives (P-111) course) ere or a place-holder for PRA training for PMs% includ5d in the parallel program. NRR i

'uld d e the roles and responsibiliti i for alPM in a*ctirig on risk-informed licensing act articular the PM's authority te with5Eassisikrice from the NRR PRA= ranct{j" interfaces with the NRR PRA L.nch.iB$ sed on}th'dse roles a es 1st ' es,t ing and NRR subject matter exF.

3 cani6"eh develop'japf

la SA PM d determine whether existing trairi.ng caRbe used br(whet,

M-specific training e

tral ngis

, ded, 6udies used for PMs would have to be newly developed basedon risk-nioat pbut. [glice is needed, portions of;P-111 migh_t bepppro gaini cas3 y actp f Course development and idstruction E661di b

'ne throug~

' NEEL) in

~ istin ntrad x

conjunction with NARjubject[6jstter prts.

2%

IMJ Structured On-the; job Training!(OJ l

NM d$

I in addition to the nifed.for KSAs;relat plant-ific design, operation, and regulatory dsignificEnifnum high pnority tasks require knowledge of interfacing issues and history,(ptive co TUnicati processes and effe lls between inspectors, project managers, other regional and HO staffdand 'a'nsee si f. OJT assignments in 110, a region, and at a are necessary for i nd PMs to facilitate an understanding of the regulatory process

~'

and task interface of advanced training for inspectors, a headquarters rotation with j

an experienced NlB roject manager and a regional rotation with an experie,ced Project Engineer, preferb y associated with the Reference Plant or a plant of similar design, is

)

recommended. The OJT activities in HQ would include observation or participation in, for example, routine licensing activities, SERs, public hearings, review of operating reports, interactions with licensees, regions, technical review, OGC, etc., Commission meetings, etc.

The regional rotation would include observation or participation in such activities as processing allegations, enforcement conferences, event followup / response, and routine communications with licensees and HQs organizations, etc. Self-study of NRR and Regional procedures would be required as part of these O.fr assignments.

I 11

The parallel advanced training activity for project managers would require an on-site assignment at a plant with an experienced Senior Resident or Resident inspector and a regional rotation with an experienced Project Engineer, preferably associated wNh the reference plant or a plant of similar design. The NRR JTA indicates that a detailed level of knowledge of plant specific documents and procedures; structures, systems, and components; licensee organization; and licensing and regulatory history are necessary for effective performance of PM regulatory responsibilities. This on-site assignment at a plant will provide knowledge of plant specific design, operation, and organization for project managers, as well as self-study of plant specific licensing documents, inspection and enforcement history, plant procedures, and databases. The regional rotation would include observation or participation in such activities as processing allegations, enforcement conferences, event followup / response, and routine communications with licensees and HOs organizations, etc. Self-study of licensee and Regional procedures would be required as part of these OJT assignments.

Each OJT assignment would include job specific activities related to high priority tasks and KSAs indicated by f each actid, apecific actions required"b,the JTAs and be structured to include the objepp yJ5SiGdent, specific requirements for manag involvement and oversight, and measurable standards for acceptable completio e

ivity. The qualification guidesidoLid bPdeveloped by a contractor or by N,

staff.

either case, this effort would require,16folver%6ht,by NRR and regional subject tr}-

re pas well as agency training staff.

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Post-Qualificatiorp{rfining;@Prdgrah y

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The JTA results indicate that oVerj50%:ofithe R ident'llispect and P ct Manager tasks necessary refresher training inian!effe%llowing Sctidde$are ihnded) provide require periodic refresher training! Th 6tive, efficient /a n=eht manner / The year. In addition, plant specific ~trainin,[g is recommelnrecommended

, ima "two vi/Esks of training per la or co tion each time an inspector or project manager is assigndd 16 a newjlant. Th{ne" jo*r po qualification training on information technology; systems that ort theirea orprogram should also be evaluated and included in the training;and q6alificati rogram$' 1

@g Reactor Program Uhdate T Ining A

i A yearly continuingl$ihindcourse that would provide a consistent periodic formal update on new policies and pr666ddfds for reactor projects staff is recommended. Subject matter for this course would be d6tirniined by NRR management with regional input and would be developed and presented b7 agency subject matter experts in conjunction with agency training staff.

Topics would most likely change from year to year. Potential subject matter may have to be prioritized to only include the highest priority material in order to maintain the efficiency and effectiveness of the training. The length of the training would be determined by the number of topics necessary, the content, and the depth of information to be covered. This course would replace or incorporate the Fundamentals of Inspection Refresher. This course would also replace or incorporate the " training week" that the regions currently implement. In addition, any

)

" required" training that is identified during the year would be included in this course, such that the need for ad hoc training beyond this course should be rare.

12

Refresher Training A refresher course for project managers should be developed covering high difficulty /high consequence tasks identified by the JTA: example tasks include processing certain license actions such as power uprates and improved technical specifications conversions; participating in the hearing process; conducting 10 CFR 50.59 reviews; takirig action for NRR as necessary to assist in resolution of issues regarding operability / nonconforming conditions (e.g., operability determinations); performing technical reviews and preparing safety evaluations; identifying safety issues related to the current licensing basis and items that might require licensing action or that have an effect on a licensing action in process; processing notice of enforcement discretion (NOED) requests; processing notice of enforcement discretion; participating in licensee assessment process; performing lead PM tasks for MPAs, GSIs, and USIs; managing decommissioning and license terminations. The course would cover a review of important licensing procedures and processes and case studies of real-life successes and problem areas.

The course would be required once every three years after completion of initial qualification requirements.

T f.

A reactor technolojy$$hfreireskrequirement in the appropriate te n for project managers %The heied for detailed technical knowledg%;gg dutihhtas pf plagtsystems, structures, and components ispisted for@significant number of project maia of one of the followMcourssippce every three years;ypould

" 1sisduir'e~ ment:

w

, 4B)[agechnology Review Westinghouse Tec{ipology (Fp1WP),fiE BWR/4 Kech ;1pgy course (R-90x series)hr EOPyslinufstdpiefiehbe (g {efR 70, g], ries);1p}he appropr cqurs reactor technologygj

g QlAg g g

g it is recommended %M the cujr'e[nt IMC)245 refrhshe' rdInin WW mg

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g 9

ier retained. The currentgequirements are; attendance;at Tectgology gegw Course and EOP Simulator Refreshe,fyourse 1% ap@opriate reactor,

nologEpnce every three years. The 4

I current efforts to expand the integrationiof regulatop skills and e'cyniques into these courses should be continuedA h bs bMf f W>W

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Continuing Trainingh A

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A continuing trainithre,quird nt of o'n'ejcourse every three years af ter completion of initial qualification requirdfrients is, so recordmended for inspectors and project managers. A focused selection o'I ry, technical, and nontechnical courses should be established and periodically review 8d dated to provide continuing training on high priority tasks and KSAs considering the ne'e'd f the individual and the direction of the program. Example courses include: Root CEdie/ Incident Investigation, NRC and its Environment, Perspectives on Reactor l

Safety, Problem Solving and Decision Making, etc.

j inspectors and PMs would then nominally attend one refresher / continuing training course per year, in addition to the Reactor Program Update Training.

Plant Specific Training The JTAs indicate that a detailed level of knowledge of plant specific documents; design; operational, transient, and accident response; and licensing and regulatory history are 13 I

r.

necessary for effective performance of inspector and project manager regulatory responsibilities. The lack of training and qualification requirements covering plant specific KSAs is a JTA-identified weakness for both project managers and Ris. Therefore, to provide plant specific KSAs vrithin a specified time af ter assignment to a new plant each time a project manager or inspector is reassigned, a post-qualification requirement is recommend" " -luding:

(1) completion of plant specific self-study and OJT modules and (2) completion of P appropriate reactor technology training. For a plant assignment involving a differem.. tor vendor, this would mean completion of the full course series and/or cross training course for that reactor technology area. For a plant assignment involving a reactor vendor for which the appropriate technology full course series or cross training course was previously completed, completion of the appropriate technology review course and EOP simulator refresher course would be necessary (unless completed within the last three years to meet the reactor technology refresher requirement discussed above).

These plant specific self-study and O,lT modules would be the same as those developed for the initial training process during the on-site assignment with an exp ced Senior Resident inspector or ResTddIdti or (Basic training for inspectors, A rjidd t ining for project managers). The q uides could be developed by a ractor by NRC staff. In either case, this ef oul ulre involvement by NRR and r nal s ect matter experts, as well as agency ng s Resources and PI ng 3

I Once a consensus ache dhe conce e

n thi per, O recommended that the agency training * 'anizatishYin cohj0Act on' N

nd egioli evelop an action plan with activities l milest delwhf6fipould sdtis '

tly b fud propriate office operating plans. Tt flowin fovidEEestimated r4s est velo mplement the recommended pro

'and

' paTn of staffiline om initi lification per current IMC 1245 1reme 5/5rsu "at to coriipIet ial ication per the recommended prodr'am.

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Cost Estimate for omml ed T i ing Pr Jam Activities

15

. NRC FTE Contract S New Develop Fundamentalsj gulation 0.1 FTE Integrated RIgulatory Assessment 0.2 FTE Fundamenta!s of Licensing 0.2 FTE Reactor Licensing Practices and Procedures 0.5 FTE PRA Training for Project Managers 0.2 FTE

$ 30K Refresher Training for Project Managers 0.2 FTE Development of 17 self-study and 6 OJT guides (contracted) 0.2 FTE

$575K Development of 17 self-study and 6 OJT guides (NRC staff) 4.0 FTE Total for new development (one time expense):

(Self-study /OJT guides contracted) 1.6 FTC

$605K 14

(Self-study /OJT guides NRC staff) 5.4 FTE S 30K Implementation (per year):

j Fundamentals of Regulation 0.1 FTE Integrated Regulatory Assessment 0.1 FTE Fundamentals of Licensing 0.1 FTE Reactor Licensing Practices & Procedures 0.1 FTE PRA Training for PMs

<0.1 FTE

$15K Refresher Training for PMs 0.1 FTE Update self-study and OJT guides 0.1 FTE Total for implementation (per year) 0.6 FTE

$15K Assumptions:

Assumed j0, hours of development for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months of class,tirne t

Assumed 180gho,urs = 1 FTE

/d y j FTE numbers incl 0de training staff and subject matterjexperts -

Fundam$ntals ofiRsgulation: Subject matter from FO,NRO hat it is and What it Does,:aAd Reglilatory Processes courses already elo '

stimated new developfhedt appfdximately 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months of class;ti,me.

NdxirMiy doubled the time to accountTor ass'eid6fy and repshkagjrig'6f New co rse. (8X1 /1800=0.04x2=0.08 Ip]to 0.1 M

j y

rounded)d,Regula,o,ryp yj j ') Course:%jclas Integrate ss9ssrpeqj A0 0)/1800=0.22 Fundamentials of Licensing Course: 40 classhours'(40x10) 800=0.22 I

Reactor Lichnsing practice 5'ind Proceduresihl40 class hourps}()0x10)/1800=0.22, f

doubledjo' Account }or dev$lfpment of caseltudies[d.22x2=0$ ounded up 10 0.5 FTE.

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PRA Trainidg for ect Managers: 0.2'FTE.for contract project management, cost estimate based o Trelo@Tient of PRATE 6h'n'oiogyEnd Regulatory Perspectives course for'inspectoid}! ividdby 2 (80 classTours vs 40 class hours) d RefreshehTraininyldr ProjAbt!Manag6rsi40ilass hours (40x10)/1800=0.22 One selfstudy guiddfor eab ourse (E11 guides),6 OJT guides (one each for PM and$lte rotatid ne each for inspcetor HQ, Region, and site rotation),

HQ, Regi, ' guidbY(one f6feach OJT module) Assumed 320 hours0.0037 days 0.0889 hours 5.291005e-4 weeks 1.2176e-4 months developme 6 self-s per guidd.

32dM3)/1800= 4 FTE. Assumed $25K for contractor development of each S.

T guide. The actual method for development can be a combination of in-ho d contracted (i.e. does not have to be all developed in-house or all devel6 5ed by a contractor).

1 Maintain and teach one 40 hour4.62963e-4 days 0.0111 hours 6.613757e-5 weeks 1.522e-5 months course with 2 instructors: 80 hrs instruction plus 32 hours3.703704e-4 days 0.00889 hours 5.291005e-5 weeks 1.2176e-5 months preparation plus 40 hrs course maintenance = 152/1800 = 0.08 rounded up to 0.1 FTE Maintain and teach one 40 hour4.62963e-4 days 0.0111 hours 6.613757e-5 weeks 1.522e-5 months course with 3 instructors: 120 hrs instruction plus 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months preparation plus 40 hrs course maintenance = 208/1800 = 0.12 FTE rounded down to 0.1 FTE Assumed approximately 8 hrs per self-study and OJT guide per year to maintain and update (8x23)/1800= 0.1 FTE.

l l

15

Assumed that revision of Fundamentals of Inspection, inspecting for Performance course, Field Techniques, and reactor technology courses will be done within normal processes for course maintenance and upgrade.

Assumed that incorporation of NRC: What It is and What it Does and Regulatory l

Processes courses subject matter into the Fundamentals of Regulation course and revision of Effective Communication for NRC Inspectors to Effective Communication for NRC Regulators will be done within normal processes for course maintenance and upgrade.

Assumed that resources currently utilized te present FOIR, regional training weeks and various ad hoc training will be reprogrammed to develop and conduct yearly Reactor Program Update for refresher training.

Actuallengths of new courses will depend on the amount and depth of subject matter to be covered.

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1 Resource Comparison (Current vs Recommended IMC 1245) l Current IMC 1245 Requirements 20-25 weeks X 40 hrs /wk =

900 hrs for current program (Self-study /OJT) 15 weeks X 40 hrs /wk =

M hrs for current procram (Courses)

Total 150u nrs /1800 hrs = 0.83 FTE for approximately 1 year j

Recommended Training Program Requirements Basic Training (First Year) 10 weeks X 40 hrs / week =

400 hrs (courses) 10 weeks X 40 hrs / week =

400 hrs (Self-study) 2 weeks X 40 hrs / week =

80 hrs (OJT) 880 hrs /1800 hrs = 0.49 FTF,Auring the first year.

Total (Basic)%

n

$ }VQg n:

Advanced Trainin (Second Year) u 4 weeks X 40 hrs / week =,

160 hrs (courses) 4 weeks x 40 hrs / week = > !,

160 hrs,(Self-study) 2 weeks X 40 hrs / Geek =

80 hrs:(OJT4f Total (Advanced)W n

'400l hrs /18 prs 2

uring e second year.

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Program Total 1280 hrs /1800 hrs!

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f I Assumed 1 week per course fo@rrall coursei,$ d n leng$#qr Assumptions:

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'"ctu' If-y module Assumed 2~ weeks of OJT.for Bh$iic Trai N ep f OJT for Advanced Training Estimates do hot includo' Site $cidess Tra$lggh SHA Indoctrination which would be in the new $rdg; ram). programs}( }SHA Indgination may be able to be inc required under both Of 20 - 25 weeks'for self-study a 3T under the current IMC 1245 program is an estimate froin the red, ions pro 0fded to the Training Review Group.

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1 17

. - Recommended Training Program for Reactor Projects Staff Basic Training inspection and Licensing Staffs Joint Training Strue:ured Self-Study Pre-work Examples: Atomic Energy Act of 1954, Energy Reorganization Act of 1974,10 CFR Part 0 and Part 1, NRC Strategic Plan, NUREG-0325, NRC Management Directives (MD) 9.1,3.1,8.8 Fundamentals of Regulation Course Establish a consistent regulatory knowledge base for all NRC reactor projects staff r ??5 StIuctured $ elf-Study Pre-work U )'

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Exa~ ples: 10'CFR 50, Appendix A, Selected F Sectlhns?

m Stdhddrd Rend @ Plan, Technical Spe.cificatiod WG7 Re$$drTecl$Aiog[hikik {fSehs/Cro, f h

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$h\\ h Develop knowl6dge and; skills' related t,dpndorispecificyN perform.ance-based regufatory sifetyzassessment!of pla desiidj control f6om dopfiguration,inie{iryted shtl ems $gt]h s

operation for all plant modes, conduct ofpperatiops, transjent andiccident ?bsp'ons%{nnd applicdtiorifofjemeIdehgy pro'c'5dures ahdisever) accident 30idelir{$' ! 17 s

... mo aw se Structtired if-Stud g-work 55 Exa jes RC MD,8.6,8.13,8.5, inspection Manual Chapter (1

3 2510, inspection Procedure (IP) 93808, NUREG-1_

,AO EG/BR-0195, and NRR Office Letter No.1301

g. -

Integrated Regulatory Assessment Process Course Provide knowledge and skills on policy, processes, and procedures for implementation of licensing, inspection, assessment, and enforcement activities. - 1

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Inspection Path Licensin.g, Path Structured Self-Study Pre-work Structured Self-Study Pre-work Examples: 10 CFR Self-Study Quizzes, Examples: 10 CFR Self-Study Quizzes, IMC 0102,0330,1010,2515,2560, Project Manager Handbook, NRR Office 9900, Core Inspection Procedures Letters Fundamentals of Inspection Course Fundamentals of Licensing Course Provide knowledge of policy, principles, Provide knowledge of policy, principles, and procedures for implementation of the and procedures for implementation of,

inspection program reactor licensing activities Self-study and OJT:atylant Self-study andbJT [n HQ Provide knowie'dge' arid $ kills related Qi3 78 [~

Providp[powl and skills i

to plant specificidocur$irds and procedures; stidhfures,Ysystems, and necessary for i

'entation of I

components;li8SIsee o" Ahization;

' g*licensirjdsdtidiN and licensing i regu

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4 acilfthghn u standing of the g Q j$

rpgulatof pro and task Provide knowth" ge and s

necessary for lhemen jop of f g jg terfacejs

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INN Regulhoryj}G[Qlde f.101, NUREG

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Exarpples: N,13 D

06('C;jP 9370 0845, g0325, NRC IP 93800, 4ji,MC 1 NUF l

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' dent [p'onse Training (AEOD/lRD)

ProJ4dejkf[ ledge and skills forimplementation of NRC f

incidept< Response Program p'

Information Technology Training l

Provide knowledge and skills for use of information technology l

necessary to support effective and efficient implementation of reactor program licensing, inspection, assessment, and enforcement activities.

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Advanced Training inspection and Licensing Staffs Joint Training Structured Self-Study Pre-work Examples: NRC MDs 3.57,5.5,3.5, IMC 0610,0301,1120, 0230, NRR Office Letters 603,903 Effective Communications for NRC Regulators Provide knowledge and skills for effective oral and written communications in support of regulatory processes inspe,,ction Path _

Licensing Paih_

Structured SelfTtsd fi work Structured S'~if[ Study Pre-work

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50.72, and 50.73:$p0.55'(af,tSO.59, Examples: 10 CFft Examplesi?:10 CFR'5jl,50.90-92,50'109, 40500; RegulatorIM.50j 3755R37001, and

[ 2.205,2.206;fNRC[4Md 8.11 71707671750, 50.55(a), 50.5$ (f), 50M9, 2.202, 2.204, 61726,62703.375 0 ides 1)$and g;-

Geriyric Letter 91-)

NUREG-0933; u

1.555; NUREG-1022})NUREG/CR-5L5,1; S $ F4ClAdmidistrativ tier 95-05; IP Generic Letters (GL)}87-09, _8817, 917; p

't 9-3700,1; NRR.Offic. tiers Nos. 906, 7

06,91-18,93-03, an'd 95-07)f!

. i; 500ft;03,901,90331201,and 1300 Field TechniqueE$d Reg $latory hji Re$$ tor Lic$nsing betices and Processes CourEd3{

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activities program.

Case studies orkg6 bps pr 3

Case studies and workshops orovide performance-opepted plicatione performance-oriented application of the tools and techpiques taught the tools and techniques taught

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! Examples: NRC Safety Goal Policy; PRA Examples: NRC Safety Goal Policy; PRA l I Policy Statement; PRA implementation Policy Statement; PRA Implementation Plan; Generic Letter 88-20; Regulatory

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Plan; Generic Letter 88-20; Regulatory l

Guides 1.1741.178 and SRP Chapters;

, Guides 1.174-1.178 and SRP Chapters; NUREG/CR-2300; NUREG-1489 NUREG/CR-2300; NUREG-1489 j

(Appendix C); NUREG-1560; NUREG-i j (Appendix C); NUREG-1560; NUREG-1449 l

l1449 PRA Technology & Regulatory PRA Training for Project Managers Perspectives (P-111)

Provides knowledge of PRA Provides knowledge of PRA principles, practices, and policy Provides knowledge and skills for principles, practices, and policy Provides knowledggand snills for applicati PRA results for application 8fMRArssDits for licensird

)in monitoring f

l inspection planiiidg, riiohitoring license" arter ce, e' i reviewing licensee perfo'rissnca,'diid reviewing risk-in ed ment son.

risk-informed ddc0mentatidn.

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Post-Qualification Training Reactor Program Update Training (once per year)

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requirements for inspectors will be Managers, once per three years Reactor technology refresher course retained with continued integration of a

regulatory skills and techniques requiremeRgnce per three years r%h XQ Q f LQ;el R$

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y - 5

!. - Review of Regional DRP JTA Training Reccmmendations Volume 11 of the job task analysis (JTA) report for the regional Division of Reactor Projects (DRP) personnel deals specifically with training recommendations developed by the contractor.

As requested in the July 16,1998 memo from the Director, NRR to the Director, AEOD, the Technical Training Division (TTD) reviewed the contractor's recommendations and developed actions to address the recommendations, it should be recognized that the contractor's recommendations generally follow a standard systems approach to training methodology which is consistent with TTD's usual practice for development and implementation of technical training. Therefore, the majority of the recommendations are considered to be valid and have been raised previously in other forums.

The focus of TTD's review was on the resident inspector position, since it is essentially the only DRP position that currently has a formal qualification and training program. At a general level, the JTA appears to capture the essential elements of a resident inspector's job. The JTA results indicate that the majority of resident inspector tasks require: formal training. Of 182 tasks,148 requir'elinifiai3I31ning and 118 require periodic refresheit} dining. TTD developed a high level matrix which(%udlitstively cross-references tasks, lea Chapter (IMC) 124b}eguiremsnts using Section ll " Training Requiremen (Westinghouse PWR Operations inspdctor" as' die basis. This matrix indicate's t6fmMt f the JTA-identified tasks, LOs, and KSAs re coidyd bpsopeppe op!'Mg245I(;ekired t%1 However, as expected po'ential:gapsgoveriaps, and weaknessesperejdeintified.

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In order to q'Jantify and appropriately address the gapsicyerlaps; and we$knesses, i

development of learnin'g objectives at:th' !KSA level and a, detailed reviewfof the specific

~

o content of training couises, self/studyka~ rid on-the-job training (OJT) acti$iljed will be required.

Since the contractohdid not p(rbtide lehrning objectides f5i; KSA learning objectives at tilo tas Is9el, a'idi ince thellMC[1245 raif6tudy and OJT activities s

currently do not haveIdarning %ectidsj this wilibe.ay@'sburodiidensiv process.

i a*s M

%hl N.$

h W

The Task Ratings f,6 esidehtJnspectors (Volume I, Appendix 1, Exhibit 1, pages 1-4 thru l-13) 4 were also reviewed'a curs 6p levelhhe results of a detailed aneiyses of this data will be useful for designing raining [and for prioritizing training activities and resources. Overall, tasks rated as high frequihi'

(#f consequence, high difficulty, and/or low satisfaction typically are given higher prioritfg ign, development, and implementation of training activities. For example, tasks with?

ombination of high frequency /high difficulty /high consequence ratings are highest prioritp for initial training because these tasks are those that the resident inspectors do most often, are the most difficult, and have the highest consequences if done improperly.

For example, the top five tasks in this category are:

Compare plant conditions with technical specifications and other appropriate regulatory requirements; Ensure compliance with the NRC's rules, regulations, etc.;

Verify control room configuration consistent with current plant conditions; Attachment ? - 1

Make technical judgments concerning safety consequences / significance, compliance, and corrective actions; and Evaluate the licensee's control in identifying, resolving, and preventing problems.

Training for these and other high priority tasks, in addition to being done early, should a'so use performance-based learning methods and employ rigorous evaluation critoria to ensure mastery of knowledge and skills necessary for task performance. Further analysis of the task ratings and matrix data will be necessary to fully address the training recommendations.

The following paragraphs provide responses and actions to address each specific recommendation made in the JTA. It should be recognized that ongoing agency initiatives such as changes to the organization of the regions and position descriptions for the DRP staff, assessment process, enforcement policy, risk-informed regulation, and revision of the inspection program must be well underway and communicated to the training staff before appropriate training can be designed and deva!cped. The following summarizes the actions that will be required to resolve the JTA remmmendatic:s:

Identify a I ning required ter regional DRP staff,t Review and evaluate the content of IM6 245$'Ifstudy, formal courses, and onf job trdiiling in conjunction with other t(ai g requi mersts to eliminate overlap any veloMrajning to fill gaps.

Sequence andfestru b thepalific$tiondr:

in ra streamline initial qualificatiord)ErigineersI(jisiincorp~h'd$r'ad(Mng A equiremEr rdtEtral ng a' lefros$.eq'uirements for SRis qualin tion y and Project pes), Md

.,onti r training requirement}Nj pf

{g ' Vp jp kg Streamline and iormal,1zejelf kt0jy and OJTpr @d" f "eme 1s Mb M

9Id 9

5 de the objective of each requir6me;nt, specific actions requ, red by h(Aspecific-requirements for i

tu completion of e;pch requir]andfEer-*ght, aiid managemefti,ijnvolverysiit tandards for acceptable ura eme y

pyd k

h l

Id ndardize; form @a be nd require consistent implementation of tra Consolidat a

and qualifi fi6ii regulis61ent "regionaPand HQ positions that support the reactor i

F program.

q f

between the program office and training staff early in the Ensure corr!

process of

'ng new policy, processes or procedures so that resources and priorities anaged appropriately and training is timely and effective.

11-1 :

The Technical Training Center should match KSAs and LOs with existing training and develop training to fill tlie gaps.

Agree..TTD matched the contractor's KSAs and LOs for the Resident inspector position with the current IMC 1245 training and qualification requirements. Potential gaps, overlaps, and weaknesses were identified in the current program. IMC 1245 self-study, formal courses, and on-the-job training sequence and content should be reviewed and evaluated to eliminate unnecessary overlap and to ensure complete, efficient, and comprehensive coverage of tasks, LOs, and KSAs. In order to quantify and appropriately address the gaps, overlaps, and - 2

'J

weaknesses, development of learning objectives at the KSA level and a detailed review of the specific content of training courses, self-study, and OJT activities will be required. Since the contractor did not provide learning objectives for KSAs, but instead deve'oped learning objectives at the task level, and since the IMC 1245 self-study and OJT activities currently do not have learning objectives, this will be a resource intensive, but essentiai process.

Potential overlaps were identified for many tasks. Many tasks are cross-referenced with multiple combinations of self-study, OJT, and formal classroom training requirements. Some intentional overlap !s necessary because of the d!fficulty or importance of a task, or for example, training that is designed to build on earlier training may have some overlap to refresh the students' knowledge of the material. However, unnecessary overlap should be identified and eliminated.

Potential ga as and weaknesses were iaeritified for a number of tasks and related KSAs including in.,pection and assessment processes (Systematic Assessment of Licensee Performance, Plant Performance Reviews, Senior Management Meetings, enforcement, license review process), plan.t support (Inspection Procedure 71750), engirteering (Inspection Procedure 37550,37551)il,icensee controls (Inspection Procedure'40500)j writing inspection and assessment documents (pC 0610, notices of violation, MR,l }N,:SAtS, PIM, MIPS, TIA, l

media packages, c]resEonse to incidents and accidents, an%y design, documents,jand issdes); Weaknesses were identified rega,lant-sg5pif rding;adeguate coverage of KSAs related to matedal curr5n,tiy covered by IMC 1245 Ouallfl5atii$ Guidhs (OGs) 2,4,5,6 x

and 8 (CFR, regulat'o'ry guidaEce' NRCJnspe$ tion f2idUal, inOUs6h cod'e's'and standards, and NRC Management Directives)lp

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'f Enhanced training should be develop 6b for docuriientsfor,which'the JTA1 indicates a working level knowledge (WLK)' is needed (vai 6us inspectiorf$ceduries', NUREG-0737, various GLs, M

INPO guidelines.10 CFR 50.59.i,LIMCi9900, NSACA25l(design basis documents and GL 91-18, etc.) OJT t: 1 covers the Tin ^ajorityIdfinspectionfrelhteti tasl[i('for example, IMC 1245 OGs

~

7A, inspection Accoml animehth and[9@, Perforflin " ' Obssved Inspection Activities) i should be validated. ln'additionfNainihhor plantjsEecj (ty operation, 9B - Site managemen

~

4A - facility specific documents,i9A - Observationiof:fa review, as well as site. specific Issues iihd SERs,gc[islicking for plant assignments following M

W initial qualification. @~

a(l Actions to ensure adequate;Mc,overageof these tsks may involve redesign of existing tra aa w

development of new~traininy' activities. For example, an OJT module designed to ensure that Ris and Senior Resident inspectorr. attain a WLK of plant specific design, documents, and issues within a reasonable time frame following assignment to a new plant is highly recommended to close this gap. Other identified gaps such as emergency response training can be remedied by integrating all required inspector training into IMC 1245.

All required tiaining for inspectors (emergency response training, allegation training, incident investigation training, etc) should be identified and incorporated into the resulting training progiam. Existing training requirements minus overlap plus training activities to fill the gaps will l

'A WLK is defined by the contractor ac " the ability to implement or apply relevant aspects of a subject'; - 3 l

then need to be structured and sequenced to constitute a complete, effective, and efficient program.

Il-1a: Training content should be based on KSAs with a varied approach:

(1):

For discipline-based requirements, training should convey knowledge.

(2):

For general material, training must cover the ability to identify and assimilate knowledge.

(3):

Use KSAs for job selection and training program selection.

(4):

Use KSAs to set OJT performance criteria, with the understanding that performance standards must be objective and measurable.

Agree. The matrix shows that most KSAs are covered by some training activity. Insrection program training requirements should be reviewed for adequate coverage of tasks, LOs, and KSAs and for overlap and potential consolidation or elimination of training requirements.

Agrebk; training, training currently required by IMC [24(i fkrhal (1):

g sesja mix of accepted standard thods to convey knowledge (class corr entations and self-studies,{tsiin'ulatoAsamp' nd provide the ability to identifgId as ate knowledge (case study, f ining, OJT, etc.). The most effeoflye a imethod for successfbl~acco ' s'hment of training objectives sholid,c e to be employed.

W g

Same comment as$jth (1 W @ g %g p[f}i (2):

S (3):

This wo i necess t e a r/i$ 57 chang in c nt a yjo 1 Ilection and training general:e]ngineer KGAs andgive them inspelddiice i,

program 5 election $EActice'shThe currint pr iro

] pth evidence of ct6r KS qualifica"tl6n and trEilhirig p&ess. The a'g'en~"icurre. hrou $

ge IMC 1245 hasr method to collect and objd6(idely evaTdate stifffKSAs. A3wedbr.the S$s' identified in the JTA could be a velddhle inpui he Capabilities #6 dift.##

f&

ME1Ry (4):

Agree. 'f enti 245 requir$$i$nts do not contain measurable standards of perfopance.

reg

. nts should be redesigned to incorporate objective and mee Trable orma andards. The KSAs would be used to aid in establis O

Brformf. ce criteria. See Recommendation ll-3.

Il-1b: Training c hould also be based on LOs:

(1)

Streamline and sequence LOs by eliminating duplication, placing global LOs before specific ones, and LOs for near-term tasks ahead of those for tasks to be performed later.

(2)

Compare the streamlined list of LOs to existing training to 6 termine where to modify existing training.

(3)

Elaborate on LOs to include performance standards and provide conceptual training: the ability to identify and synthesize critical information to apply to plant-specific situations. - 4 9

Agree. The matrix shows that most task level Los are covered by some training activity.

Inspec'. ion program training requirements should be reviewed and revised to eliminate overlap and fillidentified gaps, and to ensure cornplete, efficient, and comprehensive coverage of tasks and KSAs identified by the JTA as requiring training. Initial training should be streamlined to include global and near-term tasks and continuing and refresher training should be designeo to ensure complete, efficient and comprehensive coverage of longer-term tasks and KSAs identified by the JTA as requiring refresher training. This process involves the provisions of (1),

(2), and (3). Since the contractor did not provide learning objectives for KSAs, but instead developed learning objectives at the task level, and since the IMC 1245 self-study and OJT activities currently do not have learning objectives, this will be a resource intensive, but essential process. Also see Recommendation ll-2.

Il-1c: Use the LOs to establish a training program that mirrors progression through positions. Ensure that capability requirements (and training that will satisfy those requirements) are well-known.

Agree. If positionieIuiEdInents for the regional DRP positions are i

across the 4 regions, thelposition level training for the Senior R5sid$ t r)ged and spector and PE positions should bd;depelop6dland incorporated into IMC 1245higewly

'gned Branch Chiefs should be required;t6'complitsiany IMC 1245 initial qualificatiortrequi.

_s not previously completed. In aoditidn, contiiluing and refresher training requirb~ enti?

Id be required for i

m

d Branch Chiefs.

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y ll-2: Efforts to devels'p trainingtshould focus o_n hig@h-consequence ivities, on material that serves the greatest nuniber of'sfuderNs,6'nI asle(pre 'requisi aterial, on b

i activities for whichnar-terrii job p5rfdrmance is expected $nd ori ivities that show a

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difficulty-satisfactio'n' gap. M

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$ ad Agree. Preliminary a'n lysis oET5sk RMngs for Rb' iddNt tr3specto'rs (Volume I, Appendix 1, s

Exhibit 1, pages 1-4 thh l-13)%ad pey6Nned. D6tsliedMrialysii'N this data aids in making Y

decisions regarding design, deyelopm$N, and implSn5dntition of training activities at:d prioritizing training. Tsdurce eral$sks ratddfs high frequency, high consequence, high difficulty, and/or hl hMfficui "w sat iction combination typical!y are given higher priority in design, developme ndi bment ylfof training activities. A summary of the results of the Resident inspecto ng clud lere to give a sense of th,e tasks that the JTA identified as high priority from aSa standpoint. Further analysis of the task rating data in i

combination with thbjtsilE LOs, KSAs/IMC 1245 requirements matrix will be usefulin making specific training gNgrain design decisions.

High consequence activities identified in the JTA include:

Testify at public hearings; Respond to incidents or accidents; Participate in special reactive team inspections (AIT, diagnoctic evaluation team, special task force);

Make technical judgments concerning safety consequences / significance, compliance, and corrective actions; Prepare media packages for management press briefings;

- 5

i Coordinate agency response; Verify control room configuration consistent with current plant conditions; Compare plant conditions with technical specifications and other appropriate regulatory requirements; Verify engineered safety features arsd support system equipment configuration consistent with the plant's current condition:

Lead inspections; Assess and communicate plant status to NRC; and Receive and document allegations.

Basic (pre-requisite) material includes the KSAs identified for Position Level Requirements:

WLK of integrated plant operations; WLK of engineered safeguards systems; WLK of electrical, thermal, hydraulic, and nuclear design; WLK of operational quality assurance, station procedures,,and core surveillance; and Oral and Writ'thrTornprehension and expression.

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a Activities for which hear-terrp job performance is expected are i6d cated frequency /high difficiiljy/high consequence ratings. JTA results?ahr}tifie^dM, ta e1following tasks in this category:

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Compara plarft$ conditions with t$chnical sdecili$diions arNihtheryddpropriate regulatory requirements @

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Ensure com; ilia _nce with the Nuclear Regulatory,C' mmissgn's (NRC's) rules, o

e.

,jh Kyg h.

regulations,, etcj;

,7 Verify cor. trol. room configuration consistent with current plant conditions; Make technical? judgments cor$rning safety corsi6querj;c'e's/sigSfI6s'nce, compliance, and correctye actions;; ;

jin gj f!k

%' preventing problems, Evaluate thalicenseeVoontrol.id identifyingArosolv,

hS Verify engine leipi safety,featureyjand sufij5prt s%;n Assess overQll conduct of opelrations; HG/

ystem equipment configuration consistent g'rt including licenjs)hevent reports (LERs), nonconformanc Review repo

^

l t he plant's currer t: condition, evaluation r,

s, LO, Code obFederal Regulations (CFR) 50.59 reports, independent engineenng_ group rpports; Conduct ingectyps in areas of technical competence; Review written procedures; Observe arid evaluate maintenance activities; and Observe and evaluate surveillance activities.

Activities that show a difficulty-satisfaction gap include:

Prepare package for PPR; Prepare package for Senior Management Meeting (SMM);

Integrate inspection findings Review plant probabilistic safety assessment or independent examination program; Review engineering analyses (including 10 CFR 50.59) and operability evaluations.

Prepare enforcement package;

- 6

F l

l Modify scope of inspection as conditions warrant; Evaluate design change process; Conduct pre-operational inspections; Recommend improvements in the NRC inspection program; Address specific safety concern issues through the NRR licensee review process; and Review adequacy of engineering procedures.

As currently written, IMC 1245 initial training attempts to provide inspectors with a smattering of everything they may possibly need for their inspection career. The program meets the intent to a greater or lesser degree depending on the specific training activi+y and/or the individual efforts of the student.- (See Recommendation ll-1 for program gaps and weaknesses.) The training burden is very high for new inspectors, then tapers off to an average of less than one week per year of refresher training for experienced inspectors. This does not include ad hoc training that is required outside of IMC 1245, such as emergency response training and non technical training.

The training process ade more efficient and effective lid ting training

}am and then sequencing the trai acti'v to give the requirements with({brib inspecron staff jus

'trai hey need at the time the know e an ills are needed. For example, initial qu tion irements should be streamlin co al and near-term me goal of initial tasks creating a b rainin pgram that covers training is to make idriEw ins ~

pr p,gigucti$as q y as ible ecialized training inspectors would bd@$luded ]pector'81 " l' irks adgIylel ri ll qu ges disciplines o>

requirements for in'di ualins

,a pl pec~

odule for resident ti tion mpletion of these modules (as continuQ trainin yvoul e requirM kn in btor assigned to a new Olynt. If po j re' iilementd "gion RP " tions are determineu and standardized a,crqss the 4! regions en positi train ort

'icr Resident Inspector and PE p65itions shl661d be beloped.

'i l

Continuing and ref er train req I

ted to cover longer-term tasks and KSAs identiped by gefJTA $pents[equiri r training. The resulting program would constitute a plete,~

pre ive se raining activities that build on each other, avoid dupt

,and tive d effici tly provide the appropriate level of job i

knowledge and ski ces fori entation of the inspection program.

I l

Continuing and ret ing should be flexible enough to incorporate updates in policy, processes and pro such that the addition of training requirements beyond the 1

l established progJr u,d be rare. This requires close coordination between the program office and the trdm ng staff as policy, processes, and/or procedures undergo changes. In addition, to ensure consistent and efficient communication and application of agency policy and processes, formal qualification and training requirements for all regional and headquarters I

positions that support the reactor program should be developed, standardized, and consistently implemented.

i li-2a: Use position-level LOs to develop prerequisite 6r training.

l.

See response for Recommendation 1-1c.

. ~

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11-3: Use valid alternatives to classroom training to mitigate time and travel demands on trainees. Self-paced instruction, evaluated by the Technical Training Center, is one possibility. OJT is only acceptable if it is understood to be formal, supervised, and evaluated.

Agree. The structure and content of current IMC 1245 self-study and OJT elements of IMC 1245 are not consistent with generally-accepted training standards. Since self-study and OJT are simply alternate training methods, the same standards and controls that apply to formal classroom training (i.e. learning objectives, lesson plans, standards for successful course completion, etc.) should be implemented for self-study and OJT as well. TTD strongly agrees with the JTA recommendation that "OJT ngt be pursued as an avenue for providing training for these positions unless and until managers and students understand and exhibit willingness to live by the requirements that OJT be formal. supervised. and evaluatecl.'(emphasis theirs).

l These same standards apply to self-study activities as well.

TTD recommendsjhut,@the self-study and OJT requirements be redesigned to more effe and efficiently pr60ldbit fntended l<SAs. Self-study and OJT re"uirkinents must include the objective of each rbgijirer6est;sthe specific actions required by tfie stlidentispecific requirements for m'drliagemVritiinvolvement and oversight, and.easurabid standards acceptable compleiibirPof eadfequirement consistent with trainiijg stariTa'rds. The resulting self-study and OJTiaMlvities dK6uld be structured (i.efformal)[gviddl5fEfanagement i

oversight (i.e. supeWishd), ariU provide for pedorm^5ncs[eyaluation.

k

$$ N.& h h ll-4: Training analysts should work:with' management to de&

g termine:c ar expectations for task performance IAorde'r to'sst crit $ria fdr$irainiddiA, measurable y

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g Agree. This should tie'a fundani} ental part of redesigning,the training and;qu;al W;

11-5: As changes are made to jobs ahd'positionidescri tions%hrain h

66 W

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be re-interpreted inIllght of fh6he chaAges.

D W

Agree. The inspect 6rdraininggrygranp&snnot beirjvised based on JT agency initiatives rsla1Ad to thehssessInent process, enforcuent policy, risk-informed content of training.pp)j of th"eTnspectiytijirogram have major impacts regulation, and rev(sisi addi changes to the organization of the regions and position descriptions for thepR, impact the training program. As these issues are being resolved, existing training will;tSe ed or new training activities will be developed to cover the identified gaps initially at adirI9'nhigh level and the details will be integrated as they are developed and communicated 18the training providers. Training providers must be involved early in the process of developing'new policy or procedures so that training resources and priorities can be managcd appropriately and developed training is tituely and effective.

11-6: The office at HQ charged with responsibility for training should be tasked with setting and enforcing training program requirements. Regions must ensure implementation of the policy set by HQ.

Agree. The formal training and qualification requirements for regional ar.d HQ positions that support the reactor program should be developed, standardized, and consistently implemented - 8

across regions and within HQ. Methods for management verification of effective program implementation should be developed. Training activities should be planned, managed and evaluated using it i Planning, Budgeting, and Performance Management System processes.

Also see Recomm : ndation 11-4.

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):,+ - 9

. - Review of NRR DRP JTA Recommendation The job task analysis (JTA) report for NRR Division of Reactor Projects (DRP) positions of licensing assistant, project manager, and project director includes a recommendation developed by the contractor relative to training needed for these positions. As requested in the July 16,1998 memo from the Director, NRR to the Director, AEOD, the Technical Training Division (TTD) reviewed the contractor's recommendation and developed actions to address the recommendation. It should be recognized that the contractor's recommendation was developed within the context of standard systems approach to training methodology which is consistent with TTD's usual practice for development and implementation of technical training. Therefore, the recommendation is valid and similar training issues have been raised in other forums. For example, OlG Report 97A-21 "3eview of the Project Manager Position in the Office of Nuclear Reactor Regulation" dated July 13,1998 states: "PMs are expected to perform certain job tasl<s without receiving formal training in how to accomplish thos s." TTD reviewed the OlG report and IEc'8rpdr'5ted insights from this report into the JTA y_. g ew w 3:n y The TTD review fobNd pNr i?rily on the JTA results for the Pr$ t Man er position. The review was limited i6' allow aht!3ns to be developed that are envisioned to%roduce the highest payoff. The JTA rehdits indiddidithat the majority of project men $se'r ta'sls require formal training. Of 197 tas6 The Task Ratings fEq,1156 rQUire inj/5"jExNtilt 2[pagEs#tial training and 1 rojectMEnage F-9 triiGF-17 j r5sults ofldetailedTrial'ysis 6fdhis lisa are'UEcful f6[of the JTA repo also reviewed. Thd[diding actisities a6d'rbsobrces.VOhihil, tashsfrated'i hdesigning training and for prioritizing tr development, and irnplementstion' of training activities.!!-6r ex consequence, high7 difficulty,5 Irid /or loys'atisfactidh typiEAlly ar$, priority in design, ple, task (with a combination of high frequency /6ihh'difficulj /high c~oisequence75tirids'are hTyhest pri6My for initial training because these tasks ~ aire thosuhat th's$roject mi6agdrs%o m6st[often, are the most difficult, and have the highes,t consequshces i($ ]d6neimpyrlplhjjf jV M bbf @ For example, the t 1en tas this gory argy i Maintain int ace wi Ian jion; Perform basin $ pr mana erduties; Review insMitiorypUSl per lead project manager; ports; Process MK(GSI, ) Take actigfdrhRR with respect to operability determinations, etc.; Process amendments; Provide site coverage; Perform general focal point activities; Perform routine project manager duties; and Evaluate licensee performance. Tasks considered for periodic refresher training include the tasks rated as having the highest consequences if performed improperly and/or rated as being the most difficult. The top project manager tasks in these categories are: i - 1 High consequence: Participate in hearing process; Manage improved TS conversion; Manage power uprates; Take action for NRR with respect to operability determinations, etc.; ) Process orders; Process NOED requests; Process 2.206 petitions; i Support iricident respc.se; Manage decommissioning and license terminations; and Review events and issues. High difficulty: Manage power uprates; Manage improved TS conversion; Participate in hearing process; Take actiHisi6r5NRR;with respect to operability determina i Conduct 50 59 reviews,; $ Et a h j' Process 2.206 petitions;_ pi, 5 ~ Support,ncider3t respons,e; i Participate iMinspectioniteam; , p;g gf i Participate in%bRS m'eetings; and 4 4f 3 i a Review event {and issuas. 't9! ]g ( , -]~ g Training for these and)other highbriority' tasks sh@ould J@se,perf /h W A W ance. ed learning methods and empl6yji'gorous,evaluatioscriteria to'egsTife mas %h of k" ledge and skiffs .iecessary fer task perjormance', Further, analysis of;,th sk ratiYgs an data will be 'd necessary to fully address the training recommenda,tiong& &n k); In order to design and..bevelopa)n effdctive training ^iprggi, W 10 lopment of learning objectives at the KSA l'evel and W detalisd review.otgegect ic content of existing training courses, self-studyj$1) on-t@-Job tr # g (OJT)Mptivities will be required. Since the contrector did not e legrpihg obj ves for KSAs, but instead developed learning objectives at the ta, d will tie a resource intensive, but essential process. vel, a and OJT activities, OE The following parapr$p$ provide actions to address the contractor recommendation made in the JTA. It shouldtietecognized, however, that ongoing agency initiatives currently being designed in accordance with the EDO's tasking memo such as changes to organizations and positions, licensee assessment process, enforcement policy, risk-informed regulation, and revision of the inspection program must be we!! underway and communicated to the training staff before appropriate training can be designed and developed. - 2 JTA Contractor Recommendation Finding: Formal training programs for these positions do not meet the needs of all job incumbents. Discussion: Training should be available to cover a broad variety of subjects ranging from general training on sof tware tools used to maintain information systems to specific training on reactor concepts and applicable laws, regulations, and related issues. Recommendation: Use the lists of required knowledge, skills, and abilities and the related learning objectives to develop training programs focused on job requirements. Because of the process-and procedures-orientation of many of the tasks, much of the training should cover finding and using appropriate reference / guidance material. TTD Response: m yvn Agree. TTD agrees witti.,the contractor that a formal training anif 4 lification program should be developed using.the JTA results and job requirements. Althoug itie JTA analyzed and provided results for NRR DRP4 Project Directors (PDs), Project klahagerm Ms), and Licensing Assistants (LAs), thejTTD review focused on the Project Manakrj&@alibQ ltion since that ( position has the creater number"of staff. The review was limilpd t Yic'tions to be developed that ar{env;isioned tofprod ce the highesfpa ff. administrative in nature, it is not considered an efficient use of agency r% lar Because there are so'few Licending Assistant positions, a,nd thhiirjasks esources to develop a special trMning program for Lic'ensing Assistants. It is rec' mmsoded, tidshd,on JTA results for o this position, that applicable podions of the project manag'er traInidg andyDalification program, as well as existing nontechnical ltrainin.g' courses be ~lmplementddi;for Lice' ns'ing Assistants. With and qualification program requirements not previously' bsse as for project managers is needed. This suggests that neIWly assigned PDs sh'oul mpf promoted from the gr;oject mankger rink's and previ$usly complet9d the project manager training and qualificabdn proh(YMn, up6Massignment to the PD p 3sitio of supervisory /marld emenhKSAs).F I s 'dtn JTA results, that a formal training and qualification program for TTD recommends,ddribe developed and consistently implemented. From TTD's p e NRR project manf since the region $l and NRR DRP JTAs indicate that PMs and inspectors have many common { KSAs and interfacing tasks, the most effective and efficient means of meeting the training j needs of both regional and NRR DRP staff is to construct a parallel qualification path where eSme training would be attended jointly and some training would be position specific. The NRR DRP JTA report inriicated that NRR project managers feel undervalued and would like greater opportunity for profePional growth. One likely reason for this observation is the lack of a comparable level of training required between project managers and their regional counterparts even though the level of knowledge and skills is similar for these positions, instituting a comparable formal training and qualification program for project managers would - 3 1 i tend to raise their stature and attending some of the same courses would increase the appreciation these positions have tar one another's role in the regulatory process. This also { would provide for greater consistency in implementation of joint and interf acing responsibilities { since both positions would get the same message (i.e., same training on policy and processes.) Similar parallel training programs could facilitate movement between inspector and project manager positions and potentially enhance the ability of staff to move to supervisory positions in either the region or NRR DRP organizations. Therefore TTD recommends that the project manager training and qualification program more or less parallel the IMC 1245 program for inspectors and cover high priority tasks and KSAs identified by the NRR DRP JTA. The actions necessary to address the JTA contractor's recommendation are discussed in the following paragraphs. Recommended Formal Classroom Trainina JTA results indicate that formal classroom training is appropriate for4PMs in a number of areas. A number of exisilnT66Uihes currently required for inspectors, wii$ rhlhor modifications, could also be effective iriprovidirig{equisite KSAs for oroject manageisiElisting' reactor technology courses and the Effe6tive Conimunications for NRC Inspectors ldo0rse cphld be adjusted to I for development to}p@projedt}$ianagers. In addition, several n8vEcour meet the needs of tiisi ide khowledge and skills fordhe highest piiNityjii JTAs. New cpurse's;thht need to be.deyelop5b spjciiically fof Pys a ? prking titles) i Fundamentals of Lice'n" sing, Cicbnsii1%actI&hs aqd Pi8ceduresha PMiP,RA course and a refresher course fo'r!PMs. Tv6 a$ditis$ alm @dmekt'als o} co'Uises d

NRR DRP JJMCrosswalk to Gr@evious J "hd f.ReguldS6h and]j egrated Regulatory j

inspectors. These aM (working jtles ' Assessment Process.jAppendix li of Analysis" will be used to furtherfrefine ~ M/ inspector: Joint coursesiand couise content during 6 g @$, D course design and 'deYelopment:W (i gW Nb A detailed discussion of the recornme{(d formy@@ %9 PN l 3 WN

1. All current and futu're projectrmana@pefs shoul&c)mplete a full course o

training course;folidwingpothpietiy#(Management should make use of e design for which3h'ey are: assigned examinations foMperiddded staffTs appropriate.) The need for detailed technical knowledge of plaht syMis, structures, and components is listed for 11 project manager l i duties / tasks. Alsdjisted are detailed knowledge of: radiation / reactor accidents and incidents at assIgr$d' sites; abnormal conditions in power reactors; omergency and containment featurec; plant licensing basis, FSAR, and technical specificctions anC how they are applied; licensee definition of operability as presented in the plant's technical specifications; and working level knowledge of: plant conditions and associated rulel and regulatinns; instruments and equipment; generic reactor operating problems; safety aspects of the design and operation of reactors; and safety aspects of the design and int".ded operation of reactor systems. This indicates a strong need for all project managers _to successfully complete vendor-specific reactor technology traininc *;.iuch is specifically designed to address this subject matter. Since the large majority of tha stude.nt population for reactor achnology training has been regional inspectors, the regulatory skills covered in the course are ;,mily weighted toward - 4 e E inspectors. While most of these skills would also be beneficial for project managers, there may be some adjustments that could be made in these courses to specifically provide project manager job skill requirements. Therefore, it is recommended that TTD work with project managers that have been both inspectors and project managers, and have , completed reactor technology training, to identify adjustments that would meet the needs of both inspectors and project managers.

2. A significant number of high priority project manager tasks require effective oral and written communication skills. Examples include:

Maintain interface with RI and region; Perform backup project manager duties; Process licensing actions; Provide site coverage; Perform general focal point activities; . Perform routinegroject manager duties; dm Participat'e?iiiTeiririg process; and

l %

Participateinf d$Sction team. d O [l i dM NA b3 Mk Therefore, it is redommended that the current course titled Effective ~ Communications for NRC Inspectors b'e*retitidd Effective Communications for NRC Regill'at6rs and adjustments be made in the 56krss coriteht to addresshpplicable communication'And includ'idsrforyric%6as'e[dh ~~ o incidde~both[ofil and written concepts, proceddjes, andjskills tope jo6 ennrfnrise/studidsf tb facillis e .nt. Examples of project manager KSAs that should be covered in the: revised coursdLinclude:p& !4 ilhd W cf % +. the sensitivityMf the re;gtle'stedYd;fbr handling media inquiries, to include: Detailed knowledge of guidanc.e aterial; media kelstions; treatment of pre-decisional information; aid interaction wiStbe Officeif PUblidAffdif5; Working level knowledg^of teI*iques f6r ed&dination of review / comment resolution /coNhrrence, tech' Iinforrk$tiEn;* dge of re for wilting inspection reports in NRC IMC 0610, Detailed kni orts"$lt e pro < " Inspection s Working leveIl ' owlsdge of o ganizationalinterfaces and functions among NRC e technical staff t%) groups, and other external organizations; Working level) edge of the process for handling public meetings as contained in NRC Manadpment Directive 3.5, Public Attendance at Certain Meetings involving the NRC Stafffand NRR Office Letter 903, Meetings with Applicants / Licensee, interveners, Vendors, and Other Members of tne Public; Working level knowledge of the process for responding to media inquiries as contained in NRC Management Directive 5.5, Public Affairs Program; and Working level knowledge of key issues for coordination of meetings, visits, and public interaction (preparation of meeting minutes; guidance to control and conduct a meeting; and criteria for handling proprietary information and preparation of non-proprietary summary). Oral and written comprehension and expression Media interaction skills Ability to convey technical information in laymen's terms

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c O, e l l Testifying skills Skillin communicating with licensees as a representative of the NRC. Minimize interference with licensee activities when obtaining information. Group interaction skills Personalinteraction skills i Presentation skills Interviewing skills - l-l

3. The JTA did not identify any PRA-related tasks or KSAs. However, it is assumed that project managers would require a knowledge and skill level approximately equal to inspectors (i.e., PRA Technology and Regulatory Perspectives (P-111) course). Therefore, a place-holder for PRA training for PMs is recommended. NRR should define the roles and responsibilities for a PM acting on risk-informed licensing activities, and in particular the i

PM's authority to act without assistance from the NRR PRA Branch and expected interfaces with the NRR PPA Branch. Based on these roles and responsibilities, TTD and NRR I l subject matter ex ris can then develop appropriate PRA-rel SAs for PMs and determine og training can be used or whether cifip training is needed. if PM-specific tr'ni peeded, portions of P-111 might b p riate, but certainly any case studies us#dlor Pgjwould have to be newly develop ase '~ risk-informed licensing activitiisid Coured(development and instruction w be A through the existing 3 TTD contractor *(INEEL) Wnjunction with NRR subject Ax" i g!"Ql, M -a unda Is%yf LicerisingGou oF mentals of

4. Development ofjag)lis rec @end%T6ipcMse, par 4

Inspection Courijg ld c proj anager tasks and associated KSAsYelated to policy,-principles, and sse r rea licensing activities. i@py Example tasks l@ude: $sd QM 'g 7 $d i df Process am_, men % ism p> ~g Process relieffr) ques .@[yM Process exe ions; MW") 0 Process orde [ Process N requ

9A Process 2.

titi f ( l=

- Perform le

. 'nagerflasks for MPAs, GSis and USIs; ManageIS cti r# Manageim d conversions; and Manage def..,, ioning and license terminations. j

5. Developmen a Reactor Licensing Practices and Procedures Course (parallel to Field Techniques and Regulatory Processes Course for inspectors) is recommended. This course would provide skills necessary for conduct of NRR project managers' high priority -

tasks. This course would cover licensing procedures and provide practical exercises for i students to demonstrate the application of routine licensing practices and procedures for the tasks listed above for the Fundamentals of Licensing Course. Case studies would be utilized to illustrate methods and practice skills required for processing licensing actions and other licensing activities. - 6 .I U t

6. Development of a new Fundamentals of Regulation course is recommended. The purpose of the course would be to establish a consistent pegulatory knowledge base for all NRC reactor program staff. Major topics would include:

Legal authority; Role of the Congress, the Chairman, the Commission, and staff in regulation; NRC Culture and Management Philosophy; Strategic Plan; NRC Planning, Budgeting, and Performance Measurement Processes; NRC organization; NRC regulatory framework; Regulatory process;- Regulatory documents; Understanding NRC regulations; Integrated regulatory assessment process; Licensing, inspection, Assessment, Enforcement Relationship and Processes; . Case studies in NRC regulations; Risk-infor]me'd5iforrnance-based regulation; Compliance;and safety; a Allegations;fiMi sgb i h, d Hearings; ahdd g Mi 9 M g FOIA. $7i $5 m nd n.~ t R k This course is recommended'as aj%-or.mgl requireme% d QQQ a w p nt for initi qualifi tion for project managers (andl ins ectors),put is($alsoiecom'm5nd@for oth'd(reacthprogra 2: W r, Mjf

7. Both the NRR and regional'dTAs identified a weakness regar' ding theMacipof training on the current processes for assessment!of licensee performance 16bludingystematic i

Assessment of Lic'ensee l{erformdhce, Plant PerforMdnce Rjiews,Tetiior Management Meetings, Enforcement P61 icy, andlicense review processes 4To address this weakness, development of!a new Int $ grated F$gulatory Assechent Pr6Eass course is recommended ectors.iThis%r'sehould cover the JTA tasks and for project managers (as Well'as i@see pe)rformancs. Development of this ~ KSAs related to assessmsnt of licen begin immediathollow%approbi f the new assessment process. The course would cover policy, processes,jarid proc tes as well as include practical exercises to provide the skills neces55$ forin$lement Ion of the process including licensing, inspection, assessment, ageigr6e~ ment activities.

8. JTA results indiha&W'that response to events and incidents is a high consequence Qte difficulty taslii6r project managers. This strongly indicates a need for initial and periodic training. This training is currently provided by incident Response Division of AEOD. It is recommended that this training be formalized and included in the formal training and

. qualification program. Recommended Structured Self-Study and On-the-job Training Most project manager tasks require a detailed level of knowledge or working level knowledge of policy, procedures, processes, and concepts. In order to provide the necessary detailed or working level knowledge, self-study and on-the-job training (OJT) activities must be an essential part of the project manager training and qualification program. Self-study is necessary to attain - 7 T l l s 1 a detailed level of knowledge of policy and procedures. OJT is required to facilitate the 4 transition of learning in a classroom environment to application in the job environment for high priority tasks. However, since self-study and OJT are simply alternate training methods, the same standards and controls that apply to formal classroom training (i.e. learning objectives, lesson plans, standards for successful course completion, etc.) should be implemented for self-study and OJT as well. As noted in the JTA,"...OJT means more than learning by doing the job. OJT, to really be called training, must be formal, supervised and evaluated." It is recommended that the self-study, on-the-job training, and formal cfassroom training j activities be integrated and sequenced such that each subsequent activity builds and expands on the previous activities. Learning methods (self-study, classroom, OJT) should be varied to maximize learning effectiveness and student interest. The program should be structured to provide the student formal training in regulatory and technical knowledge and skills culminating with the OJT activitie 1 which will allow the student to integrate, prioritize, and apply the new knowledge and skills in the real, but structured and supervised, job setting. pw A more detailed Qdyt 5?i;of the recommended self-study andgT[ elements for the project ] manager program are:descritied below. Ch 4 o YNk Qh

1. A structured se[F} study m6ddle should be developed ent for which a detailed knowledge or wo k!ng ledeI:k'nowledge is indicated by therJMi3Ea'cifliMule should include the objective ofl0je*activitp[5kecific actioIs reg [ hired by th'e$

standards for a66e) table comple'ttorifof[y %g $ ) fi- [.] in the JTA inclub8? M Jw mf w W NRC Office etter No.y90,6,, Procedural Gbidancejor Pr'eparing EnYironmantal nd ConsidgringiEnvironmental Issues; Fp -y Assessmentsp'ter No.[1[2M1; hdiy" % M $P NRR Officeillet R$, h Final Safety lArialysis Report (GSAR); ' M y / >j @ 10 CFR 50.59;4; sf gj NRC IMC 0610;" Inspection Regorts; y hy a 10 CFR 51,tCategorical.Excep@ tion; 10 CFR 50.5jh; M f 10 CFR 50.9jn M NNly NRR Office:lletter 500; V NRR OfficelEstlerp03 and NRC guidance in A Prioritization of Generic Safety Issues (NUREG-Op3);)F NRC Management Directive 3.5, Public Attendance at Certain Meetings Involving the NRC Staff NRR Office Letter 903, Meetings with Applicants / Licensee, interveners, Vendors, and Other Members of the Public; Inspection Procedure 37001, 10 CFR 50.59 Safety Evaluation Program; and NRC Management Directive 8.13, Evaluating the Safety Performance of Nuclear Power Reactor Licensees; etc.-

2. A structured OJT module should be developed for high priority tasks such as those listed for the Fundamentals of Licensing course in Item 4 above. Each module would lead the qualifying project manager through the steps necessary for task completion in the actual job - 8

r O I setting. Each module would include the objective of each requirement, spec *c actions required by the student, specific requirements for management oversight, ant. measurable standards for acceptable completion of each requirement. For example, for Task 1.1 Process Amendments, the module would cover performance and verificatior, of the major { steps necessary to successfully complete the task, for example: obtain a Technical Assignment Control (TAC) through the Workload Information and Scheduling Program (WISP), make an Environmental Assessment (EA) determination, prepare an Environmental Assessment, coordinate a technical review, and prepare and issue a license amendment. Other OJT activities would include observation of or participation in, for example, routine licensing activities, SERs, public hearings, review of operating reports, interactions with licensee, region, technical review, OGC, etc., Commission meetings, etc. I A significant number of high priority tasks require knowledge of interfacing processes and i effective communication skills between project managers, inspectors, other regional and l HO staff, and licensee staff. Therefore, the qualification program should include OJT activities involving rotational assignments in the region with appgrienced PE and at a site with an experienced SRI or RI. These OJT activities should provide the qualifying individual with KSAs and experisncds such as those listed on page 5.pTheTsgiohal rotation would include observation or paEticipation in such activities as processing allegations, enforcement conferences, event follokup/ response, and routine commudI65tions$ th-licensees and HQs organizations, etc. The onfite assignment at a plant will pr$id8pishtlsfecific KSAs such { s as those listed under item'3 beloyv.rSelffstudyAf 3TA\\ide Mified NRRplicensee, and region 11 { documents and procedure's would6ejrdqUYred$s lim W C J3 3. identified weakness for NRR proje"chanagerfasfileil as inWpector#QThe JTAs indicate that a detailed level of kndwledge MSlant specific d6Samerits and p'oc'edures; structures, r systems, and components; licensdEdrganizatidN; aElIlicensing and *rdd0!atory history are responsibilities. Therefore!it is rec (orpmended'jf p@tru.ctured,* plant s needed for effective and efficient driormance that s training activities for newly, assign 5$roject ria5%epian"d inspectors) be developed and implemented. dach of these activifies would have a detailed guide outlining the objective of I ~ acceptable completion and 'verificatio{n)the activity, the' specific ecti6ns rek g y A module contaihin'g stN6tured self-study and OJT activities'should be developed to provide project managers.w.ith)lant-specific KSAs that would bo completed as part of initial qualification anid'sub'sequently each time they are assigned to a new facility. This module would provide'KSAs such as: i Detailed knowledge of plant specific systems, structures, and components; Detailed knowledge of site specific procedures, and emergency response actions; Detailed knowledge of local area and surrounding environment; Detailed knowledge of the plant Final Safety Analysis Report (FSAR); Detailed knowledge of plant licensing basis, FSAR, and technical specifications and how they are applied; Detailed knowledge of licensee definition of operability as presented in the plant's technical specifications; Detailed knowledge of radiation / reactor accidents and incidents at assigned sites.

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7 1 Recommended Post-Oualification Trainina l The project manager training and qualification program must provide opportunities for refresher and continuing training to maintain and enhance the knowledge and skill level of the project management function. Subsequent to completion of the formalinitial training and qualification program outlined above, approximately two weeks of refresher / continuing training per year are recommended to maintain PM qualification as follows:

1. A yearly continuing training course should be instituted that would provide a consistent periodic formal update on new policies and procedures for reactor projects staff. Subject matter for this course would be determined by NRR management and would be developed and presented by NRR subject matter orperts in conjunction with agency training staff. Any

" required" training that is identified :iuring the year would be included in this course, such that the need for ad hoc training beyond this course should be rare. The length of the training would be determined by the number of topics necessarygthe content, and the depth of information%iieW9ered. Potential subject matter may have,to'be prioritized to only include the highestjpriopt,$rnaterialin order to maintain the efficiency and effectiveness of the training. % qa y "g }$M M Hq y sd covering high difficulty /high

2. A refresher coursefor projedt managers should be: develop $lude processing certa actions such asjoWer up~ rates add i$ pro [exarpleitssks in consequence tdsks identifind}by the1JTAf ved technical specifidations c6nversions; participating in thehearingbrocess[(condlctird10 CFR 503i9.revieNs{ taking action for NRR as necessarylto assist in reshlltion'df issues regardin6 operabili,t// nonconforming i

I conditions (e.g. pop,erability(determ.i6ations); performing technical reviews and preparing I safety evaluations;jdentifying. safety; issues related to the current lic0nsing basis and items that might requirs. licensing: action!drithat have'an effect on h licensingiction in process; processing notice (6f enforcEnient dishretion (NOEDyequejts;! participating in licensee assessment process; perf6rming IdSd PM tasks'for MPAsgGSis, and USIs; managing ~ decommissioningland license temikiitions. Tlielc6Urse would cover a review of important licensing procedur6s and'piocessd$ snd casbistiidie's of real-life successes and problem j areas. The cou$diwould lid requfr8d once ede#ry three years after completion of initial qualification req'dirementij hp {6f j:l V

3. A reactor technologyjefresher course in the appropriate reactor technology is also recommended for$'rojsct managers. The need for detailed technical knowledge of plant systems, struct.ures, and components is listed for 11 project manager duties / tasks.

Completion of dne of the following courses once every three years would fulfil this requirement: Westinghouse Technology (R-104P), GE BWR/4 Technology (R-104B), a Technology Review course (R-90x seriesi or EOP simulator refresher course (R-70x series) in the appropriate reactor technology.

4. A continuing training requirement of one course every three years af ter completion of initial qualification requirements is also recommended for project managers. A focused selection of regulatory, technical, and nontechnical courses should be established and periodically reviewed and updated to provide continuing training on high priority tasks and KSAs considering the needs of the individual and the direction of the program. Example courses - 10 I

L E j ) 3 1 include: Root Cause/ Incident Investigation, NRC and its Environment, Perspectives on Reactor Safety, Problem Solving and Decision Making.

5. As discussed previously, the lack of training and qualification requirements covering plant-specific KSAs is a weakness in the training and qualificatiop of project managers.

Therefore, to provide the appropriate vendor-and plant-specific KSAs each time a project manager is reassigned to a new plant, a continuing training requirement is recommended consisting of: (1) completion of site specific self study and OJT modules and (2) completion of the appropriate reactor technology training as follows: for a new technology, completion of the full course series and/or cross training course would be required, or for a site for which the appropriate technology full course series or cross training course was previously completed, completion of the appropriate technology review course and EOP simulator refresher course would be required (unless completed within the last three years to meet the reactor technology refresher requirement for item 2 above). Project managers would then nominally attend two weeks of refresher / continuing training per year including th@y?rAFe'$P(ogram Update once each year and $iiliefthe TcT8 ~ a reactor technolog stier course, or a designated regulatory,itdchnical or nontechnical ~g course (i.e., one ofgajh on'es every three years). Additionally,jph time la project manager is assigned to a new alant, the;p Ent specific requirements must be completed rj r;Gf0 bt> ' 6,$ W' as h Y;,qj O'I s[e Mg g $$ M

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