ML23338A186

Charter - IMC 1248 Revision Working Group

ML23338A186
Person / Time
Issue date:	12/01/2023
From:	Leira Cuadrado NRC/NMSS/DMSST/MSLB
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Download: ML23338A186 (1)

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CHARTER Inspection Manual Chapter 1248 - NMSS Qualification Programs Revision PURPOSE To revise and update the Office of Nuclear Material Safety and Safeguards (NMSS) qualification guidance for Materials License Reviewer, Inspector, Exempt Distribution License Reviewers, and Byproduct Material Sealed Source and Device Reviewers (IMC 1248 and Appendix A, B, C and D).

SCOPE Inspection guidance is subject to routine revisions as stipulated in IMC 0040. Since the materials qualification programs were last revised in 2013, the agency has experienced many changes such as an increase in hiring, higher turnover of qualified staff, and changes to training offerings, with internal staff feedback received for potential enhancement in efficiencies. As such, the guidance needs to be revised and updated such that individuals getting qualified have up to date guidance to complete qualifications effectively. With the agency dynamics of needs to onboard and train many external hires, coupled with staff feedback on qualification experience, it is imperative to shape the materials training approach to clarify existing authorities in the near term, to enable predictability, efficiency, and consistency in decision-making for cognizant supervisors and managers.

Since staff qualification program in IMC 1248 is a matter of compatibility to the Agreement States, a working group (WG) and steering committee will be established, that will operate as an NRC/Agreement State working group as described in Management Directive 5.3, Agreement State Participation in Working Groups. The WG may be subdivided to dedicate resources and expertise to specific qualification journal(s). It is possible that the revision to IMC 1248 Appendix C, Training Requirements and Qualification Journal for Materials Exempt Distribution License Reviewers, may not be in the purview of the WGs, as the scope of its revision is expected to be narrower, with applicability to reviewers in NMSS.

The scope of this effort includes the revision of the following Inspection Manual Chapters (IMCs).

IMC 1248 Qualifications Programs for Federal and State Materials and Environmental Management Programs IMC 1248 App A Materials Health Physics License Reviewer Qualification Journal IMC 1248 App B Materials Health Physics Inspector Qualification Journal IMC 1248 App C Training Requirements and Qualification Journal for Materials Exempt Distribution License Reviewers

IMC 1248 App D Training Requirements and Qualification Journal for Byproduct Material Sealed Source Device Reviewers OBJECTIVES Employees, supervisors, and managers have in recent years increasingly expressed the need for a revision to training and qualification guidance both for initial qualification and cross-qualification for new roles. Although current policies afford supervisors and managers substantial discretion on how best to implement training and qualifications, the existing authorities may be underutilized due to uncertainties in the process. The objectives of this IMC update effort are: (1) In the near term, clarify existing authorities and provide models or examples of how these authorities can be efficiently and consistently implemented, and (2) In the longer term, develop recommendations to clarify, standardize, or where appropriate, change current policies and procedures to better integrate feedback and perceptions from staff experience of the training program. This would enable broad alignment on the underlying philosophy and objectives of the training program and promote consistent implementation of the qualification programs.

Near Term:

• Clarify the appropriate use of existing approval authorities within IMC 1248 so that supervisors are adequately equipped to credit prior experience and apply waivers or exceptions consistently.

• Clarify existing authorities to enable the use of interim qualifications once an individual has demonstrated adequate proficiency in a particular set of job functions or program codes.

Longer Term:

Revise IMC 1248 and Appendices within the scope of this effort addressing the following.

• Incorporate feedback from employees and supervisors (both new and experienced) to enable more rapid and effective qualification.

• Eliminate redundancy and overlap within/among qualification programs (to include review of other NMSS qualification programs such as 1246, 1247, and reactor qualification program IMC 1245, as appropriate)

• Focus on the practical application of knowledge/skills required to perform the job, versus memorization of information in the evaluation of staff proficiency.

• Emphasize the importance of a continuous and supportive learning environment for newly qualified employees with access to information resources and support from teams and subject matter experts in the area they are qualifying in.

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• Empower and enable supervisors to make consistent and predictable decisions with minimal administrative burden.

• Leverage proposed improvements using data and information from other agency sources (e.g., NRAN, TTC, IdeaScale information on the topic)

• Consider other efforts in NMSS related to improving qualification process in IMC updates, as appropriate. 1 WORKING GROUP AND STEERING COMMITTEE MEMBERSHIP The working group and steering committee will operate as an NRC/Agreement State working group as described in Management Directive 5.3, Agreement State Participation in Working Groups. The working group and steering committee will be co-chaired by an NRC staff member and an Agreement State representative from the Organization of Agreement States.

Organization Working Group Office of Nuclear Leira Cuadrado, Chair Material Safety and Sherrie Flaherty Safeguards (NMSS) Danielle Williams Lymari Sepulveda Regional Offices Netra Patel, Region I Steve Shaffer, Region I Erin Kennedy, Region III Jennifer Dalzell, Region III Kyle Bischoff, Region IV Mohanned Kawasmi, Region IV Linda Howell, Senior Advisor, Region IV Agreement States Auggie Ong, New Hampshire Tawny Morgan, North Carolina Technical Training Support will be requested as needed.

Center Steering Committee Tammy Bloomer, Division Director, Division of Radiological Safety and Security Jared Heck, Deputy Division Director, Division of Radiological Safety and Security Theresa Clark, Deputy Division Director, Divisions of Material Safety, Security, State, and Tribal Programs Other NRC and Agreement State staff may serve as resources to the Working Group at the request of the Co-Chairs and with the support of their management. Administrative support for the working group will be provided by the Division of Material Safety, Security, State, and Tribal Programs (MSST) in NMSS.

1 When additional scope is identified, evaluate the impact on the original effort, for scope, resources, and schedule, and align with the steering committee on how best to incorporate the additional scope.

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PRELIMINARY MILESTONES The working group will at least take on the following major milestones. A more detailed project plan will be developed once the working group is formed.

Milestones Estimated Completion Activity 1: Kickoff Meeting March 2023 Working group to meet members, discuss and understand the Status: Completed on scope of this effort, discuss expectations and project activities. March 9, 2023.

Activity 2: Finalization of project plan and task assignments. March 2023 Members are expected to work in teams and at times Status: Ongoing. Initial independently in certain tasks, as determined by the working tasking assigned in group. March 2023.

Additional taskings assigned in October 2023.

Activity 3: Interim tasking December 2023

• Clarify the appropriate use of existing approval Status: Memorandum authorities within IMC 1248 so that supervisors are is under review.

adequately equipped to credit prior experience and apply waivers or exceptions consistently.

• Clarify existing authorities to enable the use of interim qualifications once an individual has demonstrated adequate proficiency in a particular set of job functions or program codes.

The working group will communicate the results of this tasking via memorandum.

Activity 4: Develop and provide draft guidance for comments March 2024 to the regions and the Agreement States and perform comment resolution. Status: Working group drafting guidance.

In revising IMC 1248 and applicable appendices, the working group will address the considerations described in the longer-term objective above, as well as consider the results and best practices of recent updates to other qualification journals in the agency to increase consistency and effectiveness of the qualification programs (e.g., IMC 1245, 1246).

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Milestones Estimated Completion Comment period will be negotiated with the Organization of Agreement States Activity 5: Outreach activities.

August 2024 Throughout the duration of the project, the working group will solicit feedback through communication and outreach efforts Status: Ongoing. The from NRC regional and headquarters offices and the working group Agreement States, as needed. Also, working group will keep conducted initial stakeholders informed on the project taking advantage of outreach in June 2023 regional and Agreement State meetings to ensure awareness by issuing a survey to and understanding of any changes. Communication activities NRC staff. The could include participation in public meetings, regional working group lead meetings, or government to government meetings; such as: had been providing presentations at

• CRCPD Annual Meeting various events and

• OAS Annual Meeting soliciting feedback.

• NMP Monthly Teleconferences (informational only) Additional focused

• NMP Champions Chat (informational only) outreach anticipated

• Regional Spring Seminars throughout the duration of this effort.

Activity 6: Finalize and publish IMC 1248 and revised September 2024 appendices The working group will determine if they would provide recommendations to enhance any aspects of the qualification programs that are beyond the scope of this project and provide a memorandum with those recommendations.

LEVEL OF EFFORT EXPECTED OF PARTICIPANTS To support the schedule and activities listed above, the focused attention is needed with an approximate level of effort below from the working group participants:

1. Attendance at weekly meetings (1 to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> per week);

2. Attendance at stakeholder outreach events (approximately 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> total);

3. Development and/or review of working group products, such as analyses and drafting guidance (5 to 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> per week);

4. Attendance at 2 to 3 Steering Committee meetings (1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> per meeting);

5. Periodic briefings with interested managers on the working group activities to solicit feedback and comments (1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> per briefing).

NRC members should charge time associated with working group activities identified in this charter to Charge Accounting Code: EPID V-2023-IMC-0000 IMC 1248 Revision Working Group 5

MEETINGS Meetings are pre-decisional and will be closed to the public.

Working group members may delegate an alternative representative for a specific meeting. The working group may also invite individual(s) to a meeting to participate as a resource to assist the working group with a particular issue. However, at least one of the named Co-Chairs must be present during any working group meetings.

Available technology will be used to facilitate interaction with the working group members. Most meetings will be held virtually via MS Teams. Face-to-face meetings, if necessary, will generally be held in the Washington, D.C., area unless alternate locations are agreed upon by working group members. If travel is necessary, travel and per diem expenses for Agreement State members of the working group will be covered by MSST. Regions are responsible for the travel expenses of their staff.

APPROVED Kevin Williams Digitally signed by Kevin Williams Date: 2023.12.01 16:53:24 -05'00' Kevin Williams, Division Director, U.S. Nuclear Regulatory Commission Date

_______________________________________________________________________ 12/1/23 Keisha Cornelius, Chair, Organization of Agreement States Date 6