ML22224A067

Request Approval to Implement a Pilot Alternate Training Program for Resident Inspectors

ML22224A067
Person / Time
Issue date:	08/23/2022
From:	Philip Mckenna NRC/NRR/DRO/IRAB
To:	Chris Miller NRC/NRR/DRO
Kenneth Kolaczyk, NRR/DRO/IRAB, 58577389
References
Download: ML22224A067 (10)

Text

UNITED STATES NUCLE AR REGULATORY COMMISSION WASHINGTON , D.C. 20555-0001 August 23, 2022 MEMOR ANDUM TO : Christop her G. Miller, Director Division of Reactor Oversigh t Office of Nuclear Reactor Regulati on FROM: ~.d2_ Signed by McKenna, Philip Philip J. McKenn a, Chief on 08/23/22 Reactor Assessm ent Branch Division of Reactor Oversigh t Office of Nuclear Reactor Regulati on SUBJEC T: APPRO VAL TO IMPLEM ENT A PILOT ALTERN ATE TRAININ G PROGR AM FOR RESIDE NT INSPEC TORS The purpose of this memo is to docume nt impleme ntation of the enhance d compete ncy-bas ed qualifica tion (CBQ) resident inspecto r training program describe d in Enclosu re (1) of this memo on a pilot/trial basis. NRC Inspectio n Manual Chapter 1245, "Qualification Program for Reactor Inspectors," allows the Director of the Division of Reactor Oversigh t (DRO) to designa te an alternate training approac h via memora ndum to achieve inspecto r qualifica tion provided the alternate approac h ensures the compete ncies outlined in IMC 1245 Attachm ent 2 "Inspect or Compete ncies" are satisfied.

The overall goals of the enhance d CBQ program are to improve inspecto r capabilit y and reduce the length of the resident inspecto r training program . The CBQ program is designe d to model an apprenti ceship style program that is focused on gaining on-the-jo b experien ce in the field that will enable inspecto r assignm ents to the field much earlier than the existing process

. The program is flexible and consider s the candidat es' existing experien ces and learning preferences. Progress ion will be based on demons tration of capabilit ies rather than completi on of training activities, with an emphas is on gaining experien ce and building confiden ce through practice and feedbac k from certified mentors /on the job training instructors.

As backgro und, the enhance d CBQ training program was develope d, in part, to close several of the potential inspecto r training gaps identified in a Septemb er 8, 2014, "Training Needs Analysis Report" (Agency wide Docume nts Access and Manage ment System (ADAMS

) Accessio n No.

ML14280A186), that was commiss ioned as part of the NRC Learning Transfor mative Initiative .

Contact:

Kolaczy k Kenneth , NRR/DR O/IRAB (585) 773-891 7

P. McKenna 2 Plans to examine and possibly revise the resident inspector training program that is described in Inspection Manual Chapter (IMC) 1245, Appendix C1 "Reactor Operations Inspecto r Technical Proficiency Training and Qualification Journal" were previously discussed in an October 19, 2019, Commissioners' Assistants Note "Phase One Closure Notification for Review of Training and Qualification Programs in Response to SRM-CM SY17-00 24 - Proposed Agency Reform and Workforce Reduction Plans" (ADAMS Accession No. ML19273C019) and updated in an May 18, 2022 , Commissioners' Assistants Note "Initiation of Pilot Resident Inspecto r Training Program " (ADAMS Accession No. ML22111A269).

The enhanced CBQ program was developed over a two-year period by the staff of the Technical Training Center (TTC) , Office of Chief Human Capital Officer, in close coordination with a working group that included experienced former resident and senior resident inspecto rs and operating reactors inspection branch chiefs . As the program was developed , multiple touch points and meetings were held with internal stakeholders to obtain input regardin g program structure and curriculum. To ensure the enhanced CBQ program provided an equivale nt level of training to the current resident inspector training program that is outlined in IMC 1245, "Inspector Competencies," the working group compared the CBQ program curriculum to the competencies outlined in Attachment 2.

The enhanced CBQ program commenced in January 2022 using a Region II resident inspector candidate and was expanded in 2022 to a select group of resident inspector candida tes from other regions. Participation in the program by candidates is voluntary . If the working group and other stakeholders determine the training program approach is meeting the establish ed goals, it will be expanded to include other resident inspector candidates in 2023 and possibly other inspector types such as engineering inspectors.

Accordingly, based upon a review of the attached program document and the recomm endation of the CBQ working group, I request that you authorize , by your signature on this memo, the use of the enhanced CBQ program on a piloUtrail basis for the qualification of resident inspectors.

The piloUtrial program is expected to last 18 months, at which time the TTC staff in close coordination with the CBQ working group will recommend to DRO next steps regardin g program utilization .

Enclosures:

( 1)

Competency-Based Qualification Program for Resident Inspectors Overview and Instruction for Completion Division Directo@ isapproval/Comments: _ _ _ _ _ _ _ _ _ _ __

Division Director: Christoph er G. Mill er ~:.:'.:::,*.::,~,":,<;;~\'~oo~M,11~ Date:

Christopher G. Miller, Director Division of Reactor Oversight Office of Nuclear Reactor Regulation

P. McKenna 3 COMPETENCY- BASED QUALIFICATION PROGRAM FOR RESIDENT INSPECTORS OVERVIEW AND INSTRUCTIONS FOR COMPLETION RI _CBQ-01 PURPOSE 01.01 To define performance and qualification standards for Resident Inspectors equivalent to the process defined by Inspection Manual Chapter 1245.

01.02 To establish the requirements instructions for assessment and recording successful completion of each performance requirement.

01 .03 To establish the requ irements and define the process for evaluating the effectiveness of the inspector training and qualification process.

RI _CBQ-02 OBJECTIVES 02.01 To ensure Resident Inspectors have the necessary skills, knowledge , and experience to successfully implement the Reactor Oversight Process (ROP).

02 .02 To ensure the Resident Inspector training and qualification program remains effective in preparing inspectors to implement the inspection program .

RI_CBQ-03 DEF INITIONS 03.01 Assessment. The process of determining whether the trainee can adequately complete each performance requirement as compared to the performance standard . The mentor determines whether the performance standard is met or if the trainee is not yet prepared to conduct the task on their own . For each assessment, the mentor will provide feedback to the trainee by documenting the acceptable performance observed or skills requiring more practice.

03.02 Assessment Criteria. The performance standard against which the trainee's performance is measured. Further guidance for assessment may be provided to mentors/assessors in the "mentor notes" tab to ensure consistency and fairness in the assessment process.

03.03 Basic Resident Inspector. A trainee in the RI-CBQ program who has completed all the performance requirements in both the Fundamental and Basic phases of the program and the Site Readiness Review. This designation is equivalent to the Basic Qualified Inspector in the IMC-1245 process, making the inspector available to conduct inspections under the supervision of a qualified inspector and for temporary or permanent site assignment.

03.04 Collaborative Learning Environment (CLE). An NRC learning and development platform developed using the Open-Source software known as Moodie. This system is used to house and track completion of assessments in the RI-CBQ program.

03.05 Critical Task. An activity identified through a job-task analysis and represents an essential job task or fundamental component of the Resident Inspector job. Each critical task is defined by the processes involved with completing the task and related cognitive or intellectual concepts. Task related processes have been translated into performance requirements and related concepts and are addressed by knowledge resources and mentor instruction in the RI -

CBQ program .

P. McKenna 4 03.06 Evaluation . The process of determining effectiveness of an activity or program by examining selected data, performance results, and feedback from participants.

03 .07 Final Qualification Practical. An assessment used to determine the trainee's capability to complete selected performance criteria from certain critical tasks successfully in a simulated environment. The Final Qualification Practical is used to make a final determination of Full Qualification for inspector candidates.

03.08 Fundamental Inspector. A trainee in the RI-CBQ program who has completed all the performance requirements in the Fundamental phase of the resident inspector training program.

03 .09 KSA (Knowledge, Skill. and Abilities). A combination of the essential knowledge, skills, and abilities to successfully perform a job or a task. KSAs are derived from Critical Tasks, Performance Standards, and their related cognitive concepts referenced in Knowledge Resources. KSAs were compared to previously documented KSAs in IMC-1245, "Qualification Program for Reactor Inspectors" to justify equivalency of completing the RI-CBQ in lieu of the former standard program .

03 .1O Mentoring . The process where an experienced performer teaches, coaches, or assists a trainee who is learning a process or task, through the performance of a task. This is the primary method of knowledge transfer and skill development utilized in the CBQ program .

03.11 On-the-Job Training (OJT). A method of instruction that uses structured hands-on activities to develop the required job-related knowledge and skills.

03 .12 OJT Instructor/mentor. An experienced inspector who provides training , guidance, and support to the trainee and conducts assessments to ensure the trainee satisfies the performance standards. Provides appropriate feedback to guide the trainee in further development.

03 .13 Performance Requirement. The specific individual task that a trainee must perform and be assessed against to demonstrate their ability to successfully perform a critical task.

03.14 Qualification Phase. The separate portions of the CBQ program for which critical tasks were identified . There are three phases in the RI-CBQ program, Fundamental, Basic, and Apprentice. The phases were identified to represent three levels of capability. The Fundamental Phase is a preparatory period, where trainees complete requirements to work at a reactor site. In the Basic Phase, trainees learn the basic duties of Resident Inspectors under direct supervision of a mentor. During the Apprentice Phase, the trainee performs the day-to-day functions of a Resident Inspector, while learning the more complex portions of the job under the instruction and guidance of a Senior Resident Inspector.

03.15 Site Readiness Review. An assessment completed by the trainee's Branch Chief, or designee, to determine readiness of the individual to move from the Basic to the Apprentice Phase.

03.16 Supporting Knowledge. References and resources where knowledge related to the critical task may be found . Items may include policy documents, procedures, knowledge management, training resources, etc. Supporting knowledge resources will be utilized to supplement instruction from mentors and provide background information that may be needed during the performance of required tasks.

RI _CBQ-04 RESPONS IBILITIES AND AUTHOR ITIES 04 .01 Associate Director for Training and Development. Office of the Chief Human Capital

P. McKenna 5 Officer (ADHRTD ) . Administe rs and maintains the RI-CBQ program in the CLE . Ensures candidate s and mentors have proper access to the program . Maintains supportin g knowledg e

resources including active links and the mentor notes sections of the program in the CLE.

Administe rs and implemen ts the formal training programs reference d in CLE. Assesses training course effectiven ess and identifies areas where the course content or delivery methods need to be revised.

04.02 Director, Office of Nuclear Reactor Regulation. Maintains the Resident Inspector Standards Documen t (performa nce requireme nts) on which the RI-CBQ program is based Notifies the ADHRTD of any changes to the performan ce standards that need to be reflected in the RI-CBQ program .

04.03 Regional Administr ator. Ensures that the regional staff achieves and maintains qualificati ons in accordan ce with the guidelines in the RI-CBQ program . Certifies inspector achievem ent of full qualificati on . May develop procedure s for implemen ting this program for regional staff, including providing for adequate qualified mentors.

04.04 Division Directors, NRR and Regions. Assists the Office of the Chief Human Capital Officer in developin g , monitorin g , and reviewing the RI-CBQ program implemen tation and any related formal training courses that support the program.

04 .05 Chiefs, NRR Program Branches . Develops and maintains in conjunctio n with the Associate Director Human Resource s Training and Developm ent and the regions, the qualificati on standards and RI-CBQ program requireme nts and assessme nts . Evaluate proposed changes to NRR programs for impacts on performan ce standards .

04.06 Immediat e Superviso r of Trainees. Identifies the trainee's previous experienc e and training and provides guidance or recomme ndations on which formal training activities the trainee should complete . Assesses the ability of the trainee and provides appropria te levels of supervision based on the trainee's level of proficienc y. Ensures trainees are ready to independ ently perform job responsib ilities at the proficienc y level. Recomme nds trainees are ready for site-assig nment and transition to the Apprentic e Phase of qualificati on, and readiness for the Final Qualificat ion Practical Assessme nt.

RI_CBQ-05 REQU IREMENT S Staff implemen ting NRR programs must understan d the facilities , equipmen t, processe s, and activities of those programs , as well as the criteria , technique s, and mechanic s of implemen ting the programs . This qualificati on process is intended to provide staff with sufficient practice, experienc e, and resources to perform program activities that are technicall y correct and in accordan ce with NRC regulation s , policies, and procedure s .

Attachme nt 1, "Resident Inspector Performa nce Standards, " is a complete descriptio n of the critical tasks, performan ce requireme nts , and related concepts for the Resident Inspector role.

Each phase of the program contains a link to a Visual Journey Map which provides a visual represent ation of the critical tasks for each phase, and their associate d processe s and concepts. The RI-CBQ Program requireme nts , assessme nts, and instruction s for completio n

are all contained in the Collabora tive Learning Environm ent (CLE) .

Attachme nt 2, "KSA Comparis on Between IMC 1245 and RI-CBQ ," is a compariso n of the required competen cies identified in Attachme nt 2 of IMC 1245, "Inspecto r Competen cies" and the competen cies/skills demonstr ated by completin g the RI-CBQ program. This attachme nt is

P. McKenna 6 included to show functional equivalency between the two programs to allow individua ls who complete the RI-CBQ program pilot to be granted equivalent "full qualification" as Resident Inspectors via an NRR/DR O memorandum referencing the KSA Comparison .

05.01 Performance and Qualification Requirements . Staff assigned to perform in the role of Resident Inspector must have successfully completed the requirements of the RI-CBQ program .

Each inspector must complete all the required tasks for each phase of the RI-CBQ program, the Site Readiness Review and Final Qualification Practical Assessm ent as describe d in the program. Except for Site Access Training, no specific formal training requirements must be completed, but formal training may be utilized as a method to acquire the knowled ge necessary to complete the performance tasks.

05.02 Completing and Recording Program Requirements. Each critical task contains a list of performance requirements and associated assessm ent criteria . Each trainee will complete the required tasks under the instruction individually or with the support of an assigned OJT Instructor/mentor. Some required tasks may not occur frequently, and the OJT Instructor/mentor may need to provide a scenario or simulation for the trainee to demonstrate the required performance. When the trainee believes they can successfully perform a task independently, they will request an assessment from an OJT Instructor/mentor.

The mentor will observe the trainee's performance and provide assessment feedback for each performance requirement. The feedback will be in the form of "met standards" or "not ready yet" . For each assessm ent, the mentor will docume nt what was observed and why or why not the performance met or did not meet the standard. There is no alternative way to complete the required tasks, but the amount of preparation and practice required will be depende nt upon the qualifying individual's prior knowledge and experience.

05.03 Site Readiness Review. After the qualifying individual completes all the performance requirements for the Fundamental and Basic Phases of the RI-CBQ program , the trainee's Branch Chief, or qualified designee , if necessary, will conduct the Site Readine ss Review (SRR). The SRR performance and assessment standards are maintained in the CLE. The assessment consists of individual performance requirements from various critical tasks from the Basic Phase of the RI -CBQ program. The Branch Chief (or designee) will observe the qualifying individual's performance conducting routine inspector activities and determin e

whether they are ready to be assigned to a site to perform these tasks under the guidance of the Senior Resident Inspector, while completing the requirements of the Apprent ice Phase.

05.04 Final Qualification Practical Assessment. An inspector must be recomm ended by the Resident Inspector qualification practical assessment panel and certified by the Regional Administrator or Division Director to be fully qualified . While the assessment contains only performance requirements previously completed by the trainee, opportunities to practice prior to the final qualification practical assessment should be afforded .

a. Resident Inspector Qualification Practical Assessm ent Panel. The Resident Inspecto r

qualification practical assessment panel is used to evaluate how well a trainee can integrate and apply inspector competencies to simulated field situations. Upon an individual's completion of all required performance activities and critical task assessments, a Resident Inspector qualification practical assessm ent panel will confirm that an individual has the necessary capabilities to independently perform the Residen t

Inspector assigned duties and responsibilities. The individual's direct supervisor will determine when they are ready for the final qualification practical assessment based on personal observation and input from senior inspectors and mentors who have assesse d

the individual's performance throughout the qualification process .

1. Members. A final qualification practical assessm ent panel will consist of at least

P. McKen na 7 three memb ers . The panel should contain a cross- section of knowle dgeab le staff includi ng Reside nt Inspec tors, Senior Reside nt Inspec tors, Projec t Engine ers, and Branch Chiefs . Each panel will include and be chaired by someo ne at the Branch Chief level. The board chairm an cannot be the individ ual's immed iate superv isor. Howev er, whene ver practical, the immed iate superv isor of the individ ual seekin g qualific ation , or a design ee should observ e the assess ment panel.

2. Asses sment Panel Condu ct.

(a) The assess ment proces s consis ts of three portion s. Two are presen tation/ discus sion interac tions and the third an observ ation of perform ance during a simula ted respon se to a plant event. Final qualific ation practic al assess ment standa rds have been establi shed from those presen t in the qualific ation progra m in variou s critical tasks.

Asses sment panel memb ers will prepar e by review ing the standa rds and the scenar ios/tas ks assign ed to the candid ate.

(b) Ideally, Final Qualifi cation Practical Asses sment Panels will be schedu led at the TTC betwee n 60 and 90 days, or more, in advan ce to ensure simula tor availab ility and allow for all particip ants to make necess ary travel arrang ement . Final Asses sment panels for inspec tors from all four region s will be conduc ted on the same week and panel memb ers may include senior inspec tors or Branch Chiefs from the candid ate's own

, or other regions . While the immed iate superv isor for one candid ate may not particip ate in his/her assess ment, he/she may perform the duties of the panel chair for anothe r candid ate during the week. (As an alterna tive if qualific ation is essent ial or urgent and canno t be coordi nated throug h this proces s at the TTC ,

the presen tation portion s may be comple ted in the Region al Office and a license e's exercis e/drill or simula tor may be used for the observ ation portion of the assess ment panel.)

(c) For the presen tation/ disciss ion portion of the Asses sment

, the HRTD Progra m Manag er will provid e the trainee with scenar ios/iss ues/ins tructio ns and necess ary resour ces 30

- 45 days in advan ce of the planned final assess ment panel.

The candid ate will perform actions necess ary to resolve and dispos ition the issue or gather the required data and prepar e presen tations for each simula tion/sc enario .

(d) Asses sment panel memb ers will be provid ed a copy of the assign ed issue/t ask/sc enario two weeks prior to the planne d assess ment panel to plan and develo p questio ns related to the issue/s cenari o and assess the candid ate's perform ance related to the establi shed standa rds .

(e) For the perform ance observ ation portion of the final qualific ation assess ment panel , the candid ate will not be made aware of the scenar io prior to the start of the simulation.

The assess ment panel memb ers will be given the scenar io two weeks prior to the planne d assess ment panel along with the other prepar ation materi als

. During the simula tion , panel memb ers will observ e and listen to the candid ate's perform ance and interac tions but will not interfe re with any actions . At the conclu sion of the simula tion

, the candid ate will prepar e and deliver either a verbal or written summa ry of the event to the panel memb ers , and they may ask any questio ns at that time specifi c to the scenar io or the candid ate's perform ance related to the establi shed standa rds.

(f) The Final Qualifi cation Practical Asses sment Panel activiti es typical ly will require betwee n two and three hours to comple te for each candid ate, but do not have to be comple ted all at once or in any specifi ed order. Sched ules for all assess ment activiti es will be develo ped based on the numbe r of candid ates for a given assess ment week and memb ership of each assess ment panel. The schedu le will be provide d to candid ates and panel memb ers by the RI-CBQ Progra m Manag er prior to their arrival at TTC to comple te assess ment activities.

P. McKenna 8

3. Assessment Panel Recommendations and Documentation.

(a) Assessment panel members will each independently assess the candidate's performance against the established standards and document their assessment results and observation comments.

(b) Assessment panel members will then discuss their observations and reach a collective recommendation for Full Qualification if all the standa rds are met, or for further practice as an Apprentice Resident Inspector with specific areas of needed improvement identified. The candidate's immediate supervisor may be presen t for this panel discussion and provide insights or answer questions as necessary to assist the panel in making its decision if necessary.

(c) Assessment panel members will provide their documented assessment results and any related observation comments to the RI-CBQ Program Manager, who will upload these documents and complete the assessment in CLE based on the panel's recommendation.

These assessment notes will accompany the candidates trainin g and qualification record in CLE.

4. Re-assessment Panels .

If a candidate is assessed as "Not Ready Yet" at the initial Final Qualification Practical Assessment, they will be given the opportunity for more practice in the specific areas identified by the panel. Once the candidate, a Senior Resident Inspector, and the candidate's immediate supervisor believes they are ready for final assessment, they may be scheduled for re-assessment. Scheduling requirements and assessment panel memb ership will be dependent upon the portion of the final qualification practical that needs to be re-assessed . After the completion of the re-assessment, the candidate's immediate superv isor or a designated OJT Instructor will update the assessment status and upload the approp riate assessment results documents into the CLE.

05.05 Other Administrative Requirements.

a. Formal Training Requirements and Expectations.

1. With exception of Site Access Training, no formal training is require d to complete this program . However, formal training courses are available and listed as "resources" in the appropriate Critical Task area . If a candidate chooses to attend formal training courses, all attendance and exam performance expectations for those course s will apply.

2. This is a self-driven, performance-based program, but a candid ate's immediate supervisor or OJT Instructor/Mentor may recommend, or require

, attendance in a training course where they believe it is essential to close a knowledge gap.

b. OJT Instructors/Mentors .

1. The RI-CBQ Program is designed as a Structured OJT development highly dependent upon OJT Instructors/Mentors for both instruc process and tion and assessment. Regional management should ensure that an adequate number of mento rs are available to support all the candidates in the Region . This support will require both virtual and in-person instruction at any location and including travel with the inspector candidate to reacto r sites.

2. OJT Instructors/Mentors should be highly skilled inspectors with a desire to support the development of others. Mentors may be volunteers or appointed , but in either case

P. McKen na 9 must be given adequate time away from their normal inspection duties to provide suppor t to candidates.

3. Once an OJT Instructor/Mentor is identified , they must complete the OJT Instructor assess ment process in TMS and utilize the Skills-Based Mentor Develo pment program , also available in TMS to develop their mentoring skills.

4. To ensure consistency in instruction and assessment, a "mento r notes" tab is provided for each critical task in the CLE . These notes provide mentor s with guidanc e, resources , scenarios, or ideas about how to teach certain skills, and notes or guidelines specific to the assessment. This is intended to ensure fairness and equity in the program across all regions and all OJT Instructors.

05 .06 Deviations .

This program was built with maximu m flexibility in mind. The require ments for each assess ment in each critical task must be completed and documented. Although the phases were sequenced based on expected experience level and skill develop ment capabilities, they do not need to be completed in order. A critical task from any phase can be completed by a candidate with the assistance of an OJT Instructor/mentor, but in general , the phases will normally be completed in order. Site assignm ents , tempor ary or perman ent, should not be made until the candidate successfully comple tes the Site Readiness Assessment. However, if an opportunity arises to complete a critical task in the Apprentice phase while visiting a site during the Basic Phase, and the mentor believes the candidate is capable , completion of that activity is acceptable.

Because the requirements of this program are compet ency-ba sed , deviatio ns will not normally be required . If the candidate can demons trate proficiency of a task through the assess ment process , it should be docume nted as a completed assessment. If formal training is selected as a method for knowledge acquisition , any normal course prerequisite sequencing policy, practice ,

or guidanc e should be followed .

RI _CBQ-06 POST-QUALIFICATION TRAIN ING Post qualification training will continue following the guidanc e contain ed in section 1245-06 "Post-Qualification Training" of IMC 1245. If the decision is made to fully implem ent the RI-CBQ program , adjustm ents will be made to the manual chapter to addres s any modifications in post-qualification training requirements.

RI _CBQ-07 ASSESSING PROGRAM EFFECT IVENESS RI _CBQ-08 PROGRAM REVISIONS END Attachments:

Attachm ent 1: Resident Inspector Performance Standa rds Attachm ent 2: KSA Comparison between IMC 1245 and CBQ

P. McKenna 10

SUBJECT:

REQUEST APPROVAL TO IMPLEMENT A PILOT ALTERNATE TRAINI NG PROGRAM FOR RESIDENT INSPECTORS DATED AUGUST 23, 2022 DISTRIBUTION CMiller, NRR PMcKenna, NRR KKolaczyk, NRR ADAMS Accession No.: ML22224A067 Concurrence via e-mail IOFFICE NRR/DRO/IRAB/PM* NRR/DRO/IRAB/BC*

NAME KKolaczyk PMcKenna IDATE 07/29/2022 8/23/22 OFFICIA L RECORD COPY