ML25198A150
| ML25198A150 | |
| Person / Time | |
|---|---|
| Issue date: | 12/16/2025 |
| From: | Office of Nuclear Material Safety and Safeguards |
| To: | |
| References | |
| Download: ML25198A150 (8) | |
Text
Issue Date: xx/xx/25 1
1248 Att 1 NRC INSPECTION MANUAL MSLB INSPECTION MANUAL CHAPTER 1248 ATTACHMENT 1 OVERVIEW AND ADDITIONAL GUIDANCE FOR TRAINING AND QUALIFICATION PROGRAM Effective Date: TBD The Office of Nuclear Material Safety and Safeguards restructured its qualification program into a two-step, basic-level qualification program and a technical proficiency qualification program.
This attachment describes the revised qualification framework.
Qualifying individuals are expected to actively engage with their assigned mentor/sponsor(s) and immediate supervisor in their qualification journey as well as keeping track of their training status and the training offerings to support timely completion the requirements of the basic-level and technical proficiency qualification cards.
1.0 THE BASIC-LEVEL PROGRAM The qualification process begins with the basic qualification program. The basic qualification program involves structured self-paced and self-directed individual study, onthe-job activities, and training courses.
Individuals who complete the basic qualification program will develop an awareness of the role of the agency. At the basic-level, staff work on activities that will introduce them to the regulatory framework, the U.S. Nuclear Regulatory Commissions (NRCs) role in regulating nuclear materials communication with licensees and the public. This overview approach establishes a foundation for indepth training at the next level and serves as the basis for granting individuals some independence in performing limited job-related activities while they are in the qualification process. Upon completion of basic qualification, the staff may be eligible for interim qualification (see Inspection Manual Chapter (IMC) 124809 and Section 3 of this attachment). This basic qualification provides a pathway for staff to perform limited-scope activities, as assigned, under an appropriate degree of supervision.
2.0 THE TECHNICAL PROFICIENCY-LEVEL PROGRAM Technical proficiency focuses on developing the appropriate depth of knowledge in a specific technical area. Upon completion of the basic qualification program, the qualifying individual then focuses on fulfilling the requirements in the technical proficiency qualification journals. With the acknowledgment of their supervisor, qualifying individuals may start working on the technical proficiency requirements while completing the basic qualification program or awaiting their basic qualification certification.
As stated in IMC 124807, the immediate supervisors may designate one or more qualified staff members to sign qualification cards for the training activities completed by the candidate. If no qualified staff members are available, senior staff members with expertise in a particular area can be utilized. Only the supervisor can certify the completion of a qualification journal.
Issue Date: xx/xx/25 2
1248 Att 1 3.0 INTERIM QUALIFICATIONS In accordance with IMC 124809, a candidate who has not completed all the requirements for final certification in their qualification program may obtain interim qualification to independently perform certain specific work activities in the discipline for which prescribed training has been completed. Therefore, the supervisor may grant interim qualification and/or limited signature authority to a candidate during the qualification process.
Interim qualification should be granted for specific activities (i.e., program codes, category, or complexity) for which the individual has demonstrated adequate proficiency. The supervisor may expand the scope of the interim qualification as the individual acquires additional training, experience, and proficiency during the qualification process. The supervisor, and/or designated staff member, should perform an accompaniment inspection or technical analysis of the candidates work prior to recommending them for interim qualification. Reviews performed by the senior technical staff member(s) of the candidates work/inspections should be documented and evaluated by the supervisor to support an interim qualification decision. Interim qualification shall be recommended by the candidates supervisor and approved by the division director.
To obtain an interim qualification, the candidate should have completed the basic qualification requirements and additional onthe-job training assignments, as determined by the supervisor, for the specific work activities for which they are receiving interim qualification. The individuals supervisor may adjust this list based on the role and the scope of the interim qualification.
3.1 Documentation and Recordkeeping Documentation granting interim qualification must be prepared by the supervisor and approved by division director. Records of all interim qualifications granted shall be documented via memorandum and be accessible to the individual, their management, and retrievable for future program reviews. Memoranda granting interim qualifications to a candidate should be placed in the agency official record management system, Agencywide Documents Access and Management System (ADAMS), as non-public, internal information. It is recommended that each qualifying individual has a folder in ADAMS containing all documentation related to the individuals fulfillment of qualification requirements, including any applicable customization or equivalency justifications.
Package of Qualification Document Templates: ML25XXXAXXX 4.0 CUSTOMIZATION OR EQUIVALENCY OF THE QUALIFICATION REQUIREMENTS In accordance with IMC 1248, Section 05.01, 05.02, and 124811, the supervisor may customize the basic-level and the technical proficiency qualification journals by adding training activities or granting equivalency to certain requirements based on the qualifying individuals knowledge needs or prior experience and/or training.
Supervisors have the authority to grant equivalency for any of the requirements in IMC 1248 and its appendices, including being evaluated by a qualification board. The qualifying individual may be given credit for equivalent training courses already taken, for relevant work experience, or for completed college courses that directly relate to the discipline in which they are qualifying.
Certain requirements (ISA and OJT items) may be granted equivalency at the discretion of the supervisor based on the scope of the work the candidate will be assigned.
Commented [JD1]: Create ADAMS package to add templates for qual memos
Issue Date: xx/xx/25 3
1248 Att 1 If a candidate is qualified under a different IMC 1248 appendix or another IMC qualification journal, there is no need to complete similar or common requirements between the qualification journals. In this situation, a qualifying individual may also receive a new qualification without the evaluation of a qualification board. However, the office director, administrator, or their designee may require the qualifying individual be evaluated by a qualification board if deemed necessary.
Supervisors must inform the qualifying individual, then justify and document any equivalency afforded to them. Any equivalency given to the candidate must be documented in the corresponding Form 1 and be included with the respective qualification journal signature card when certifying the completion of the qualification. The following table contains examples for equivalent qualification requirements.
Table 2: Illustrative examples for equivalent training requirements in IMC 1248 The candidate was hired to the NRC as a Materials Health Physicist Inspector and was formerly employed as a materials inspector with an Agreement State Program. The supervisor completed a Form 1 providing justification of equivalent training and/or experience completed while working as a qualified license reviewer or inspector in an Agreement State.
The candidate graduated with a bachelors degree in health physics from an accredited university and has worked in the radiation protection field for the past 3 years. The supervisor determined that the qualifying individual had sufficient formal education and experience to grant equivalency to Fundamental Health Physics (H122S) and Advanced Health Physics (H201). The supervisor completed a Form 1 providing justification of formal education and/or experience completed while working in private industry.
If a candidate works in a branch not performing reviews or inspections of a particular program code areas (e.g., medical area), certain ISA and OJT items may be waived to facilitate more rapid qualification. Similarly, if the region has very few, or no licenses of a particular program code, the supervisor may deem it unnecessary to complete those ISAs or OJT items to support branch work, those items may be waived as well. However, if the candidate changes branches, or is expected to work on a program code or discipline not covered by their qualification, the supervisor needs to ensure the qualifying individual completes the applicable training and qualification activities relevant to the new program codes/disciplines. Completion of the additional training, OJTs, and ISAs shall be documented as a supplement to the standing qualification.
The candidate is qualified under a different Manual Chapter. The supervisor compares the completed training, ISAs, and OJTs from the other program with the requirements in IMC 1248 qualification journals. The supervisor also considers individuals prior experience and identifies a number of training activities that are equivalent, in addition to certain training courses not included in the qualification card. The supervisor will use the applicable Form 1 to document the equivalency and the addition of training.
All equivalencies shall be approved, disapproved, or partially approved in writing by division
Issue Date: xx/xx/25 4
1248 Att 1 management. If the qualifying individual is deemed to be fully qualified, the qualification journal shall be certified by the division director with the corresponding delegated authority. To facilitate consistent documentation of equivalencies to requirements in the qualification journal(s), the supervisor should use the appropriate Form 1, Equivalency Justification. Record of certification of qualification completion shall be documented via memorandum and be accessible to the qualifying individual, their management, and for future reviews of the program.
In such instances, the immediate supervisor needs to document any customization to the qualification journals by using the corresponding Form 1, Equivalency Justification. This documentation will be part of the certification package, along with the corresponding qualification cards demonstrating completion of the assigned training activities.
5.0 SIGNATURE AUTHORITY PROCESS FOR LICENSE REVIEWERS QUALIFICATION (IMC 1248 APPENDIX A)
Part of the qualification process for a license reviewer qualifying under IMC 1248, Appendix A involves obtaining signature authority to independently review licensing actions (new applications, amendments, renewals, and terminations). Appendix A of IMC 1248 contains the signature authority process to be followed by the qualifying individual. The immediate supervisor, in consultation with the mentor(s), will regularly evaluate the candidates licensing reviews (casework) under the supervision of a qualified reviewer and grant the signature authority for the program codes the qualifying individual has demonstrated competency.
During qualification period - The qualifying individual must be assigned and complete the necessary casework to obtain core signature authority before being evaluated by the qualification board. The supervisor may tailor the core signature authority by assigning one or two additional groupings called, discretionary signature authority, during the qualification period.
Any groups in the discretionary signature authority grouping not completed during the qualification period will be assigned to be completed within a year of qualification, together with other post-qualification groups identified by the supervisor.
Post-qualification - The rest of the program codes not covered in the core or discretionary signature authority groups are divided into the post-qualification signature authority groups. It is expected that the supervisor and the qualifying individual will implement a yearly plan which specifies the post-qualification signature authority to be achieved during that period. As the reviewer continues to gain signature authority, the supervisor and license reviewer will revise the yearly plan and continue to identify the post-qualification signature authority groups to be achieved.
It is not necessary nor expected that each license reviewer obtains signature authority in all the groups or program codes. However, the supervisor must ensure it has the needed qualified staff, with the needed signature authorities, to process licensing casework in their organization.
5.1 Documentation and Recordkeeping It is the responsibility of the supervisor to clearly document via memorandum the signature authority granted to the individual undergoing qualification or expanding its signature authority. As the qualifying individual increases their scope of the signature authority, the documentation needs to reflect all the program codes or categories they are authorized to independently review and sign. The memoranda granting signature authority are an agency official record and should be processed as such. It is also the responsibility of the license
Issue Date: xx/xx/25 5
1248 Att 1 reviewer to review the documentation and ensure it is upto-date with the authorities provided thus far.
The qualifying individuals final certification package should include or reference the signature authority memoranda issued to the qualifying individual. The supervisor is expected to keep track of the signature authorities of their staff and identify additional authorities to be achieved in order to support the workload of the branch.
6.0 QUALIFICATION BOARD The qualification board is the culminating evaluation activity in the training and qualification process. Upon successfully completing the technical proficiency qualification cards, the qualifying individuals supervisor will recommend they be evaluated by a qualification board.
The Qualification Board evaluates the ability of an individual to integrate and apply the knowledge, skills, and attitudes they have learned to field situations and licensing reviews.
Training and qualification records for individuals who have successfully completed the Qualification Board will be sent to the Regional Administrator/Office Director or their designee for certification. An individual who is certified as fully qualified can be assigned to independently perform inspections and licensing related activities for which signature authority have been granted, with routine oversight and supervision. IMC 124808 provides additional guidance on the qualification board.
If the candidate has been already evaluated by a qualification board, either under another qualification program of the agency or earlier in the qualification process of IMC 1248, the supervisor will document the completion of the applicable qualification requirements and request the Regional Administrator/Office Director, or their designee (typically division director) to certify the qualification via memorandum.
7.0 REFRESHER TRAINING Qualified personnel are expected to maintain their qualifications by completing refresher training during the established triennial requalification cycle in accordance with the requirements outlined in this appendix.
7.1 Training Requirements Qualified personnel must complete 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> of refresher training within the established triennial requalification cycle. Approval from the individuals immediate supervisor is required prior to taking refresher training. Supervisors must consider the objectives of the training and specific qualifications of the staff member.
Examples of refresher training options include:
Instructor-led and online courses related to health physics: i.e. Health Physics Topics (H401, etc.)
NRC technical training courses.
External training courses.
Directed self-study courses related to health and safety or security.
Conference attendance (i.e., CRCPD, OAS, etc.)
Issue Date: xx/xx/25 6
1248 Att 1 Professional society meetings (i.e., HPS, AAPM, etc.)
Counterpart meetings.
Technical inspection/licensing discussions (i.e., Monthly Part 35 call; Commercial, Industrial, R&D call; Government to Government (G2G) meetings; Champions Chats, etc.)
Other supervisor approved trainings.
Qualified staff may retake previously completed courses for refresher training if the supervisor considers retaking the course is beneficial based on changes in technology, regulations, or course content. To receive credit for previously completed courses, the course must be completed and passed, including exams.
7.2 Equivalencies, Extensions and Special Cases Division management can waive or extend the refresher training requirements under special circumstances up to 1 year past the due date. Any extension needed beyond 1 year would require program office approval. Request for waivers should be made through memorandum and should be submitted by the immediate supervisor of the qualified individual to the regional division management. The documentation should include a reason for extension/waiver.
Qualified personnel should return to their original training schedule when waiver or extensions expires.
Qualified personnel who do not maintain the refresher training requirements may participate as a member of a team inspection under the supervision of the team leader. Independent inspection can be conducted if the personnel complete the required refresher training and any other training specified by the applicable program office.
7.3 Documentation and Record Keeping Supervisors and qualified personnel should maintain comprehensive records of all refresher training completed by qualified staff, including documentation of approvals, waivers, extensions, and any deviations granted.
END
Issue Date: xx/xx/24 Exh1-1 1248 Att 1 Basic Level Qualification Technical Proficiency Qualification Final Qualification Activities Exhibit 1: Overview of the Material Health Physics License Reviewer and Inspector Qualification Program Complete Appendix J
Training Courses
Independent Self-Study Activities
On-the-job Activities Candidate works with supervisor and with mentor to complete training and qualification activities.
Complete Appendix A, B, C, D, or M
Training Courses
Independent Self-Study Activities
On-the-job Activities Candidate is eligible for interim qualification in specified areas.
Candidate works with supervisor and with to continue gaining proficiency for areas outside of the scope of the interim qualifications theyve received.
Signature Authority for License Reviewer - Candidates under Appendix A completes significant casework requirements to obtain signature authority (1248 Att. 1 Section 5).
Qualification Board
Supervisor certifies completion of requirements in the qualification journals and recommends the individual be evaluated by a Qualification Board.
Upon successful evaluation by the qualification board, the individual qualification is certified by Regional Administrator/Office Director or their designee.
Final Certification of Completion
If individual has already been evaluated by a qualification board, the supervisor certifies completion of applicable qualification requirements, and individual qualification is certified by Regional Administrator/Office Director or their designee.
Issue Date: xx/xx/xx Att1-1 1248 Att 1 : Revision History for IMC 1248 Attachment 1 Commitment Tracking Number Accession Number Issue Date Change Notice Description of Change Description of Training Required and Completion Date Comment Resolution and Closed Feedback Form Accession Number (Pre-Decisional, Non-Public Information)
N/A ML24xxxxx DATE CN 24-xxx Created attachment 1 to describe the stepped qualification process.
TBD N/A