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
NRC INSPECTION MANUAL HHFB
INSPECTION PROCEDURE 41500
TRAINING AND QUALIFICATION EFFECTIVENESS
PROGRAM APPLICABILITY: 2515 SALP FUNCTIONAL AREA: OTHER /g50
41500-01 INSPECTION OBJECTIVES 01.01 To ensure that a training inspection is an appropriate /g50 response to identified performance problems. /g50/g50 01.02 To ensure that the training and qualification programs for /g50 nuclear power plant personnel are develop ed, implemented, /g50 evaluated, documented, and maintained as required by 10 CFR 50.120 /g50 and allowed by 10 CFR 55. /g50/g50
41500-02 INSPECTION REQUIREMENTS 02.01 Response. Verify that a training inspection is the /g50 appropriate response to identified performance problems. /g50/g50 02.02 Training and Qualification Programs
- a. Evaluate the performance of nuclear power plant workers todetermine 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 devi ce, 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 thesystems approach to training.
41500-03 INSPECTION GUIDANCE General Guidance
Issue Date: 06/13/95 41500 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
41500 Issue Date: 06/13/95 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 ada ptations in the training and /g50 qualification programs. SECY-93-021, "Amendments to 10 CFR Parts /g50 50 and 52 on Training and Qualifi cation of Nuclear Power Plant /g50 Personnel," indicates that the staff will monitor the effectiveness /g50 of the SAT process through licensed operator requalification /g50 program reviews conducted using IP 71001, "Licensed Operator /g50 Requalification Program Reviews," and through review activities /g50 associated with 10 CFR 50.65, "Requirements for Monitoring the /g50 Effectiveness of Maintenance at Nuclear Power Plants." SECY /g50 021 further stated that training inspections will be conducted only /g50 for cause using the guidance in this inspection procedure. /g50/g50 Consistent with the SAT process, each applicant and lic ensee 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 /g50 supported by NUREG-1220, "Training Review Criteria and Procedures," /g50 may also be used in conjunction with NRC Management Directive 8.8, /g50 "Management of Allegations," to examine elements of the licensee's /g50 training and qualification prog rams as appropriate in order to /g50 follow up on allegations concerning the programs. /g50/g50
Specific Guidance 03.01 Response. When training related concerns are identified, /g50 the information provided in Attachment 1, "NRC Staff Guidance for /g50 Monitoring the Effectiveness of Training of Nuclear Power Plant /g50 Personnel," must be used to determine the appropriate response. If /g50 an inspection of the training programs is determined to be /g50 appropriate, the inspection is conducted in accordance with the /g50 remainder of this procedure. /g50/g50 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 /g50 performance-related operational events involving any non-operations /g50 personnel covered by 10 CFR 50.120 and operations personnel covered /g50 by 10 CFR Part 55 with training as a cause as well as /g50
Issue Date: 06/13/95 41500
/g50 increase in the failure rate on initial examinations.unsatisfactory requalification program inspection results or an
/g50
/g50 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."
/g50
Attachment:
END
/g50 NRC Staff Guidance for Monitoring
/g50 the Effectiveness of Training of Nuclear Power
/g50 Plant Personnel
/g50
41500 Issue Date: 06/13/95
/g50
Issue Date: 06/13/95 41500 Attachment /g50/g50 NRC STAFF GUIDANCE FOR MONITORING /g50THE EFFECTIVENESS OF /g50 TRAINING OF NUCLEAR POWER PLANT PERSONNEL /g50/g50
/g50 Purpose /g50 The NRC is issuing this guidance to inform the staff of appropriate /g50/g50 actions for monitoring the effectiveness of training of nuclear /g50 power plant personnel. /g50/g50
/g50 Background /g50 In November 1993, 10 CFR Part 50.120, "Training and Qualification /g50/g50 of Nuclear Power Plant Personnel," became effective. This rule /g50 requires licensees to establish, implement, and maintain training /g50 programs based on a systems approach to training (SAT). The /g50 personnel covered by this regulation are (1) non-licensed operator, /g50 (2) shift technical advisor, (3) shift supervisor, (4) instrument /g50 and control technician, (5) electrical maintenance personnel, (6) /g50 mechanical maintenance personnel, (7) radiation protection /g50 technician, (8) chemistry technician, and (9) engineering support /g50 personnel (formerly technical staff and managers). /g50/g50 In March 1994, NRC revised the regulations in 10 CFR Part 55 to /g50 delete the requirement that each licensed operator pass a /g50 comprehensive requalification written examination and operating /g50 test administered by the NRC during the term of the operator's 6- /g50 year license as a prerequisite for license renewal. This /g50 regulation, which affects r eactor operators and senior reactor /g50 operators, allows training programs for licensed operators to be /g50 developed using SAT. /g50/g50 Through the Policy Statement on Training and Qualification of /g50 Nuclear Power Plant Personnel, NRC endorsed the training /g50 accreditation process managed by the Institute for Nuclear Power /g50 Operations (INPO) and 11 accredited training programs. In issuing /g50 10 CFR 50.120 and revising 10 CFR Part 55, the Commission /g50 reaffirmed its conclusion that currently accredited training /g50 programs can meet the requirements of 10 CFR Part 55 for training /g50 licensed operators and 10 CFR Part 50.120 for training those other /g50 than licensed operators. The staff recognizes that training /g50 programs developed in accordance with INPO guidelines and /g50 accredited by the National Nuclear Accrediting Board (the Board) /g50 are based on SAT; therefore, accredited programs are considered to /g50 be consistent with the regulations. The September 27, 1993, /g50 Memorandum of Agreement between the NRC and INPO documents NRC and /g50 INPO training-related activities. /g50/g50 The Board accredits utility training programs, while INPO manages /g50 and implements the accreditation process. Utility training /g50 programs are initially accredited for 4 years, and accreditation is /g50 renewed every 4 years thereafter. The Board can (1) grant initial /g50 accreditation or renew accreditation of a program, (2) place a /g50
Issue Date: 06/13/95 A-1 41500, Attachment
/g50 (3) withdraw accreditation of a program. The utility resolvesprogram on probation for a specified period of time, or
/g50 minor training program weaknesses by preparing corrective action
/g50 plans that are monitored by INPO. Individual program weaknesses or
/g50 SAT process problems are usually the bases for a program being
/g50 placed on probation.
/g50
/g50 NRC is confident that programs accredited under the INPO-managed
/g50 accreditation process will continue to meet the requirements of 10
/g50 CFR part 55 and 10 CFR 50.120. Notwithstanding this confidence,
/g50 the NRC is responsible for monitoring utility training programs and
/g50 assuring that they are effective. The means by which this is
/g50 accomplished is discussed below.
/g50
/g50
/g50 Discussion
/g50
/g50 The NRC staff uses two primary methods of evaluating the
/g50 effectiveness of training programs in the industry. The first is
/g50 to monitor human performance. The second method is to monitor the
/g50 industry's training program accreditation process.
/g50
/g50
/g50 NRC Evaluation of Training Program Effectiveness by Monitoring
/g50 Human Performance
/g50
/g50 NRC monitors human performance at nuclear power plants as a means
/g50 to evaluate the effectiveness of utility training programs.
/g50 Declining human performance can indicate training deficien cies;
/g50 therefore, NRC looks for evidence of tra ining problems when
/g50 reviewing information
/g50 sites. This information includes resident in spector insights;regularly collected and documented at nuclear
/g50 trends in licensee event reports; and results of operator initial
/g50 examinations, requalification examinations and inspections, and
/g50 other team inspections. The NRC developed the "Training Program
/g50 Inspection Protocol" (protocol attached) as a systematic approach
/g50 for determining what actions to take when the staff finds that
/g50 declining performance may be a result of ineffective or omitted
/g50 training.
/g50
/g50 The protocol assists NRC in determining the appropriate response to
/g50 each instance of declining human performance. Each decision step
/g50 requires site-specific insights. The protocol prescribes
/g50 alternative levels of follow-up action based on an assessment of a
/g50 licensee's performance. The initial assessment of licensee
/g50 performance using the protocol may indicate the need to (1) address
/g50 an immediate safety concern, (2) conduct an operator
/g50 requalification examination, (3) inspect all training programs, or
/g50 (4) review a specific aspect of a limited number of training
/g50 programs. Rather than stating rigid decision standards that may
/g50 not be appropriate in every case, the protocol enables NRC to
/g50 tailor a response to the specific situation. Each decision to
/g50 conduct a training inspection is made after careful consideration
/g50 of plant specific performance information and discussion between
/g50 NRC headquarters and regional staff.
/g50
/g50
/g50
41500, Attachment A-2 Issue Date: 06/13/95 NRC Evaluation of Training Program Effectiveness by Monitoring the /g50 Training Accreditation Process /g50 NRC monitors INPO accreditation activities by observing /g50/g50 accreditation team visits and attending Board meetings as a part of /g50 NRC's assessment of the industry's training and qualification /g50 programs. The purpose of these visits is to monitor the health of /g50 industry training programs and to observe the implementation of /g50 programmatic aspects of the accreditation process. /g50/g50 Although the Board's action of placing a training program on /g50 probation or withdrawing accreditation indicates a Board concern, /g50 it does not necessarily place a training program in noncompliance /g50 with either 10 C FR Part 55 or 10 CFR Part 50.120 since training /g50 programs are accredited to a "standard of excellence" rather than /g50 a minimum level of regulatory compliance. However, NRC reviews the /g50 circumstances leading to the withdrawal or probation to ensure safe /g50 operations and continued compliance with regulations. /g50/g50
/g50
/g50 Accreditation Probation /g50 Before determining its response to the issues that resulted in /g50/g50 training program probation for a specific program, the NRC reviews /g50 the concerns raised by the Board. In doing the review, the senior /g50 resident inspector, appropriate regional personnel, or both, would /g50 read INPO's accreditation report and discuss the issues with the /g50 licensee and NRR's Division of Reactor Controls and Human Factors /g50 (DRCH) to determine the safety significance of the training /g50 deficiencies. If the NRC determines that compliance with the /g50 regulations is not affected and finds that the probationary status /g50 is not safety sig nificant, it may not need to act further. NRC /g50 would document the results of this safety review in the resident /g50 inspector's monthly inspection report by stating that the /g50 accreditation report was reviewed, discussing any s afety /g50 significant issues, and discussing any follow-up actions taken or /g50 planned to resolve safety-significant issues. However, NRC would /g50 not address the status of the training program accreditation. /g50/g50 If the staff finds safety-significant issues, it may request the /g50 licensee to provide a basis for con tinued operation, schedule a /g50 licensed operator requalification examination, schedule an /g50 inspection of the training program, or meet with licensee managers, /g50 as necessary, to discuss the safety significance of the concerns /g50 and the corrective actions taken or planned. Safety-significant /g50 concerns may also prompt the region to request that the licensee /g50 describe, in writing, the concerns found and the plan for /g50 corrective actions. The licensee should be asked to describe each /g50 concern in detail, its safety significance, its relationship to /g50 regulatory requirements, and whether the licensee continues to meet /g50 regulatory requirements. This request for information is /g50 consistent with NRC authority under 10 CFR 50.54(f). /g50/g50 If the staff finds no safety-significant issues, it may conduct a /g50 training inspection in accordance with Inspection Procedure (IP) /g50 41500 if declining human performance that may be the result of /g50
Issue Date: 06/13/95 A-3 41500, Attachment
/g50 inspection is to be conducted, it will not normally be scheduled toineffec tive or omitted training is identified. If a training
/g50 start until after the training prog ram has been removed from
/g50 probation. If the Board extends probation, the region and NRR/DRCH
/g50 will determine the appropriate action for the NRC on a case-by-case
/g50 basis. NRC conducted training inspections after the probationary
/g50 period are intended to determine if the l icensee's training
/g50 programs support safe o peration and continue to comply with
/g50 regulations, not to verify the licensee's corrective actions in
/g50 response to probation, which may go beyond the requirements of the
/g50 regulations.
/g50
/g50 Licensed operator requalification program evaluations will be
/g50 conducted as scheduled, even if a licensee's training programs have
/g50 been placed on probation. NRC Inspection Pr ocedure (IP) 71001,
/g50 "Licensed Operator Requalification
/g50 to be completed during each systematic assessment of licenseeProgram Evaluation," is intended
/g50 performance (SALP) cycle and should be conducted while annual
/g50 examinations are being conducted. However, in response to a
/g50 licensee's operator training programs being placed on probation,
/g50 the scope of the inspection may be limited to objectives directly
/g50 related to assessing the operator requalification examination
/g50 process. These objectives include determining the adequacy of the
/g50 written examinations, operating tests, and remedial training and
/g50 assessing the licensee's effectiveness in conducting examinations.
/g50
/g50
/g50 Accreditation Withdrawal
/g50
/g50 The Board may withdraw accreditation in response to major
/g50 deficiencies in a utility's accredited training program. It is not
/g50 known what action INPO will take to assist the facility in
/g50 regaining accreditation. Currently, the only facilities that do
/g50 not have accredited training programs are those that are no longer
/g50 members of INPO and are permanently shut down.
/g50
/g50 While the Board action of withdrawing a ccreditation has not yet
/g50 occurred, it would result in a situation where the NRC can no
/g50 longer be assured that the licensee is in compliance with the
/g50 regulations based on accreditation. Therefore, if accreditation is
/g50 withdrawn, the licensee should be requested to report the
/g50 circumstances of the withdrawal to the NRC in order for the staff
/g50 to determine the significance of the issues related to the
/g50 withdrawal. If the NRC determines that compliance with the
/g50 regulations is not affected it may not need to act further. If the
/g50 withdrawal relates to a breakdown in the SAT process or a safety-
/g50 significant issue, an immediate inspection focused on the process
/g50 problem or safety issue(s) shall be conducted. Further action,
/g50 such as Confirmatory Action Letters or orders, shall be taken, as
/g50 appropriate.
/g50
/g50
/g50
/g50
/g50
41500, Attachment A-4 Issue Date: 06/13/95 Training Program Inspection Protocol /g50 (Page 1) /g50/g50
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/g50 This page left intentionally blank. /g50/g50 For a hard copy of this page please contact /g50the Human Factors Assessment Branch. /g50
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Issue Date: 06/13/95 A-5 41500, Attachment
/g50 Training Program Inspection Protocol
/g50 (Page 2)
/g50
/g50
/g50
/g50 This page left intentionally blank.
/g50 For a hard copy of this page please contact
/g50 the Human Factors Assessment Branch.
/g50
/g50
41500, Attachment A-6 Issue Date: 06/13/95