ML24005A319
| ML24005A319 | |
| Person / Time | |
|---|---|
| Issue date: | 06/13/1995 |
| From: | NRC/NRR/DRO/IOLB, NRC/NRR/DRO/IRIB |
| To: | |
| References | |
| CN 95-007 | |
| Download: ML24005A319 (1) | |
Text
Issue Date: 06/13/95 41500 NRC INSPECTION MANUAL HHFB INSPECTION PROCEDURE 41500 TRAINING AND QUALIFICATION EFFECTIVENESS PROGRAM APPLICABILITY: 2515 SALP FUNCTIONAL AREA: OTHER
41500-01 INSPECTION OBJECTIVES 01.01 To ensure that a training inspection is an appropriate
response to identified performance problems.
01.02 To ensure that the training and qualification programs for
nuclear power plant personnel are developed, implemented,
evaluated, documented, and maintained as required by 10 CFR 50.120
and allowed by 10 CFR 55.
41500-02 INSPECTION REQUIREMENTS 02.01 Response. Verify that a training inspection is the
appropriate response to identified performance problems.
02.02 Training and Qualification Programs a.
Evaluate the performance of nuclear power plant workers to determine if they have been trained and qualified commensurate with the performance requirements of their jobs.
b.
Evaluate the methods of licensee training and qualification (classroom, laboratory, simulation device, on-the-job) to determine if the training and qualification program has been developed, implemented and evaluated using a systems approach to training.
c.
Evaluate the effectiveness of the implementation of the systems approach to training.
41500-03 INSPECTION GUIDANCE General Guidance
41500 Issue Date: 06/13/95 The safety of nuclear power plant operations and the assurance of general public health and safety depend on personnel performing at adequate levels. The systematic determination of qualifications and the provision of effective initial training and periodic retraining will enhance confidence that workers can perform
Issue Date: 06/13/95 41500 adequately. The approach the Commission has taken in 10 CFR 50.120 and 10 CFR 55 is to specify the systems approach to training (SAT) by which applicants and licensees shall develop, implement, and evaluate personnel training programs. This approach provides for flexibility and site-specific adaptations in the training and
qualification programs. SECY-93-021, "Amendments to 10 CFR Parts
50 and 52 on Training and Qualification of Nuclear Power Plant
Personnel," indicates that the staff will monitor the effectiveness
of the SAT process through licensed operator requalification
program reviews conducted using IP 71001, "Licensed Operator
Requalification Program Reviews," and through review activities
associated with 10 CFR 50.65, "Requirements for Monitoring the
Effectiveness of Maintenance at Nuclear Power Plants." SECY
021 further stated that training inspections will be conducted only
for cause using the guidance in this inspection procedure.
Consistent with the SAT process, each applicant and licensee is required to include the following key elements in its training programs: (1) analysis of job performance requirements and training needs, (2) derivation of learning objectives based upon the preceding analysis, (3) design and implementation of the training program based upon the learning objectives, (4) trainee evaluation, and (5) program evaluation and revision based upon the preceding evaluations.
The training program review criteria outlined in this procedure and
supported by NUREG-1220, "Training Review Criteria and Procedures,"
may also be used in conjunction with NRC Management Directive 8.8,
"Management of Allegations," to examine elements of the licensee's
training and qualification programs as appropriate in order to
follow up on allegations concerning the programs.
Specific Guidance 03.01 Response. When training related concerns are identified,
the information provided in Attachment 1, "NRC Staff Guidance for
Monitoring the Effectiveness of Training of Nuclear Power Plant
Personnel," must be used to determine the appropriate response. If
an inspection of the training programs is determined to be
appropriate, the inspection is conducted in accordance with the
remainder of this procedure.
03.02 Training and Qualification Programs. The inspector must use NUREG-1220, Revision 1, "Training Review Criteria and Procedures,"
to evaluate the effectiveness of the licensee's training and qualification programs. NUREG-1220 is used to determine the success of training and qualification programs in meeting and maintaining job performance needs, and to evaluate the licensee's SAT process for developing, implementing, evaluating, and documenting training and qualification programs where a particular training related human performance problem has been identified or is suspected. Events which may initiate an assessment include
performance-related operational events involving any non-operations
personnel covered by 10 CFR 50.120 and operations personnel covered
by 10 CFR Part 55 with training as a cause as well as
41500 Issue Date: 06/13/95 unsatisfactory requalification program inspection results or an
increase in the failure rate on initial examinations.
41500-04 RESOURCE ESTIMATES For planning purposes, the direct inspection effort to accomplish this procedure should be estimated by the regional office, consistent with the scope of the planned regional initiative(s) or reactive inspection to be performed. Typically a full inspection that inspects two unrelated training programs will require four individuals: one team leader, one training and assessment specialist, and two subject matter experts (SME). At least one training and assessment specialist should be assigned to each team.
A SME should be assigned for each unrelated program being inspected. For inspections of operations training and/or requalification programs, an operator licensing examiner should act as a SME. A partial inspection will require a team leader to act as SME for the program under inspection and one training and assessment specialist. NRR is prepared to assist the regions as necessary. Direct inspection effort for Reactive Inspections or Regional Initiatives should be recorded on RITS against Procedure 41500. Where the procedure is used for allegation follow-up in conjunction with NRC Management Directive 8.8, the actual time expended should be recorded against IPE code AF.
41500-05 REFERENCES 10 CFR 50.120.
10 CFR Part 50, Appendix B, Criteria II.
Site Specific Technical Specifications, Training.
ANSI/ANS 3.1, 1981, "Selection, Qualification, and Training of Personnel for Nuclear Power Plants."
Regulatory Guide 1.8, Rev. 2, "Qualification and Training of Personnel for Nuclear Power Plants."
NUREG-1220, Revision 1, "Training Review Criteria and Procedures."
IP 40500, "Effectiveness of Licensee Control in Identifying, Resolving, and Preventing Problems."
IP 71001, "Licensed Operator Requalification Program Evaluation."
END
Attachment:
NRC Staff Guidance for Monitoring
the Effectiveness of Training of Nuclear Power
Plant Personnel
Issue Date: 06/13/95 41500
Issue Date: 06/13/95 A-1 41500, Attachment Attachment
NRC STAFF GUIDANCE FOR MONITORING
THE EFFECTIVENESS OF
TRAINING OF NUCLEAR POWER PLANT PERSONNEL
Purpose
The NRC is issuing this guidance to inform the staff of appropriate
actions for monitoring the effectiveness of training of nuclear
power plant personnel.
Background
In November 1993, 10 CFR Part 50.120, "Training and Qualification
of Nuclear Power Plant Personnel," became effective. This rule
requires licensees to establish, implement, and maintain training
programs based on a systems approach to training (SAT). The
personnel covered by this regulation are (1) non-licensed operator,
(2) shift technical advisor, (3) shift supervisor, (4) instrument
and control technician, (5) electrical maintenance personnel, (6)
mechanical maintenance personnel, (7) radiation protection
technician, (8) chemistry technician, and (9) engineering support
personnel (formerly technical staff and managers).
In March 1994, NRC revised the regulations in 10 CFR Part 55 to
delete the requirement that each licensed operator pass a
comprehensive requalification written examination and operating
test administered by the NRC during the term of the operator's 6-
year license as a prerequisite for license renewal. This
regulation, which affects reactor operators and senior reactor
operators, allows training programs for licensed operators to be
developed using SAT.
Through the Policy Statement on Training and Qualification of
Nuclear Power Plant Personnel, NRC endorsed the training
accreditation process managed by the Institute for Nuclear Power
Operations (INPO) and 11 accredited training programs. In issuing
10 CFR 50.120 and revising 10 CFR Part 55, the Commission
reaffirmed its conclusion that currently accredited training
programs can meet the requirements of 10 CFR Part 55 for training
licensed operators and 10 CFR Part 50.120 for training those other
than licensed operators. The staff recognizes that training
programs developed in accordance with INPO guidelines and
accredited by the National Nuclear Accrediting Board (the Board)
are based on SAT; therefore, accredited programs are considered to
be consistent with the regulations. The September 27, 1993,
Memorandum of Agreement between the NRC and INPO documents NRC and
INPO training-related activities.
The Board accredits utility training programs, while INPO manages
and implements the accreditation process. Utility training
programs are initially accredited for 4 years, and accreditation is
renewed every 4 years thereafter. The Board can (1) grant initial
accreditation or renew accreditation of a program, (2) place a
41500, Attachment A-2 Issue Date: 06/13/95 program on probation for a specified period of time, or
(3) withdraw accreditation of a program. The utility resolves
minor training program weaknesses by preparing corrective action
plans that are monitored by INPO. Individual program weaknesses or
SAT process problems are usually the bases for a program being
placed on probation.
NRC is confident that programs accredited under the INPO-managed
accreditation process will continue to meet the requirements of 10
CFR part 55 and 10 CFR 50.120. Notwithstanding this confidence,
the NRC is responsible for monitoring utility training programs and
assuring that they are effective. The means by which this is
accomplished is discussed below.
Discussion
The NRC staff uses two primary methods of evaluating the
effectiveness of training programs in the industry. The first is
to monitor human performance. The second method is to monitor the
industry's training program accreditation process.
NRC Evaluation of Training Program Effectiveness by Monitoring
Human Performance
NRC monitors human performance at nuclear power plants as a means
to evaluate the effectiveness of utility training programs.
Declining human performance can indicate training deficiencies;
therefore, NRC looks for evidence of training problems when
reviewing information regularly collected and documented at nuclear
sites. This information includes resident inspector insights;
trends in licensee event reports; and results of operator initial
examinations, requalification examinations and inspections, and
other team inspections. The NRC developed the "Training Program
Inspection Protocol" (protocol attached) as a systematic approach
for determining what actions to take when the staff finds that
declining performance may be a result of ineffective or omitted
training.
The protocol assists NRC in determining the appropriate response to
each instance of declining human performance. Each decision step
requires site-specific insights. The protocol prescribes
alternative levels of follow-up action based on an assessment of a
licensee's performance. The initial assessment of licensee
performance using the protocol may indicate the need to (1) address
an immediate safety
- concern, (2) conduct an operator
requalification examination, (3) inspect all training programs, or
(4) review a specific aspect of a limited number of training
programs. Rather than stating rigid decision standards that may
not be appropriate in every case, the protocol enables NRC to
tailor a response to the specific situation. Each decision to
conduct a training inspection is made after careful consideration
of plant specific performance information and discussion between
NRC headquarters and regional staff.
Issue Date: 06/13/95 A-3 41500, Attachment NRC Evaluation of Training Program Effectiveness by Monitoring the
Training Accreditation Process
NRC monitors INPO accreditation activities by observing
accreditation team visits and attending Board meetings as a part of
NRC's assessment of the industry's training and qualification
programs. The purpose of these visits is to monitor the health of
industry training programs and to observe the implementation of
programmatic aspects of the accreditation process.
Although the Board's action of placing a training program on
probation or withdrawing accreditation indicates a Board concern,
it does not necessarily place a training program in noncompliance
with either 10 CFR Part 55 or 10 CFR Part 50.120 since training
programs are accredited to a "standard of excellence" rather than
a minimum level of regulatory compliance. However, NRC reviews the
circumstances leading to the withdrawal or probation to ensure safe
operations and continued compliance with regulations.
Accreditation Probation
Before determining its response to the issues that resulted in
training program probation for a specific program, the NRC reviews
the concerns raised by the Board. In doing the review, the senior
resident inspector, appropriate regional personnel, or both, would
read INPO's accreditation report and discuss the issues with the
licensee and NRR's Division of Reactor Controls and Human Factors
(DRCH) to determine the safety significance of the training
deficiencies. If the NRC determines that compliance with the
regulations is not affected and finds that the probationary status
is not safety significant, it may not need to act further. NRC
would document the results of this safety review in the resident
inspector's monthly inspection report by stating that the
accreditation report was reviewed, discussing any safety
significant issues, and discussing any follow-up actions taken or
planned to resolve safety-significant issues. However, NRC would
not address the status of the training program accreditation.
If the staff finds safety-significant issues, it may request the
licensee to provide a basis for continued operation, schedule a
licensed operator requalification examination, schedule an
inspection of the training program, or meet with licensee managers,
as necessary, to discuss the safety significance of the concerns
and the corrective actions taken or planned. Safety-significant
concerns may also prompt the region to request that the licensee
describe, in writing, the concerns found and the plan for
corrective actions. The licensee should be asked to describe each
concern in detail, its safety significance, its relationship to
regulatory requirements, and whether the licensee continues to meet
regulatory requirements. This request for information is
consistent with NRC authority under 10 CFR 50.54(f).
If the staff finds no safety-significant issues, it may conduct a
training inspection in accordance with Inspection Procedure (IP)
41500 if declining human performance that may be the result of
41500, Attachment A-4 Issue Date: 06/13/95 ineffective or omitted training is identified. If a training
inspection is to be conducted, it will not normally be scheduled to
start until after the training program has been removed from
probation. If the Board extends probation, the region and NRR/DRCH
will determine the appropriate action for the NRC on a case-by-case
basis. NRC conducted training inspections after the probationary
period are intended to determine if the licensee's training
programs support safe operation and continue to comply with
regulations, not to verify the licensee's corrective actions in
response to probation, which may go beyond the requirements of the
regulations.
Licensed operator requalification program evaluations will be
conducted as scheduled, even if a licensee's training programs have
been placed on probation. NRC Inspection Procedure (IP) 71001,
"Licensed Operator Requalification Program Evaluation," is intended
to be completed during each systematic assessment of licensee
performance (SALP) cycle and should be conducted while annual
examinations are being conducted. However, in response to a
licensee's operator training programs being placed on probation,
the scope of the inspection may be limited to objectives directly
related to assessing the operator requalification examination
process. These objectives include determining the adequacy of the
written examinations, operating tests, and remedial training and
assessing the licensee's effectiveness in conducting examinations.
Accreditation Withdrawal
The Board may withdraw accreditation in response to major
deficiencies in a utility's accredited training program. It is not
known what action INPO will take to assist the facility in
regaining accreditation. Currently, the only facilities that do
not have accredited training programs are those that are no longer
members of INPO and are permanently shut down.
While the Board action of withdrawing accreditation has not yet
occurred, it would result in a situation where the NRC can no
longer be assured that the licensee is in compliance with the
regulations based on accreditation. Therefore, if accreditation is
withdrawn, the licensee should be requested to report the
circumstances of the withdrawal to the NRC in order for the staff
to determine the significance of the issues related to the
withdrawal. If the NRC determines that compliance with the
regulations is not affected it may not need to act further. If the
withdrawal relates to a breakdown in the SAT process or a safety-
significant issue, an immediate inspection focused on the process
problem or safety issue(s) shall be conducted. Further action,
such as Confirmatory Action Letters or orders, shall be taken, as
appropriate.
Issue Date: 06/13/95 A-5 41500, Attachment Training Program Inspection Protocol
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the Human Factors Assessment Branch.
41500, Attachment A-6 Issue Date: 06/13/95 Training Program Inspection Protocol
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For a hard copy of this page please contact
the Human Factors Assessment Branch.