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Inspection Manual Chapter 1248 Appendix M Draft for Comment
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NRC INSPECTION MANUAL NMSS INSPECTION MANUAL CHAPTER 1248 APPENDIX M TECHNICAL PROFICIENCY-LEVEL CERTIFICATION REQUIREMENTS FOR DIVISION OF DECOMMISSIONING URANIUM RECOVERY AND WASTE PROGRAMS RISK ANALYSTS, PROJECT MANAGERS, AND TECHNICAL REVIEWERS Effective Date: TBD

Issue Date: TBD i

1248 App M TABLE OF CONTENTS INTRODUCTION.......................................................................................................................... 1 TECHNICAL PROFICIENCY-LEVEL PROGRAM ORGANIZATION............................................ 1 QUALIFICATION JOURNAL ORGANIZATION............................................................................ 2 REQUIRED AND OPTIONAL TECHNICAL PROFICIENCY-LEVEL TRAINING COURSES....... 2 TABLE 1: TECHNICAL PROFICIENCY-LEVEL TRAINING COURSES...................................... 3 TECHNICAL PROFICIENCY-LEVEL INDIVIDUAL STUDY ACTIVITIES..................................... 7 (ISA-1) Navigating the NRC Internal and External Websites.................................................... 9 (ISA-2) Major Industry Events and Regulatory Implications (Lessons Learned)..................... 13 (ISA-3) IMC, Inspection Procedures (IP), and Other References........................................... 15 (ISA-4) The Federal Register (FR).......................................................................................... 17 (ISA-5) Orders......................................................................................................................... 19 (ISA-6) Controlled Correspondence........................................................................................ 21 (ISA-7) Security Requirements for Nuclear Power Plants and Materials Sites....................... 22 (ISA8) Hearings..................................................................................................................... 24 (ISA9) Proprietary Information and Determinations............................................................... 25 (ISA10) 10 CFR 2.206 Petitions............................................................................................ 27 (ISA11) NUREG-1757........................................................................................................... 29 (ISA12) Decommissioning Material and Fuel Cycle Facilities................................................ 31 (ISA13) Decommissioning Uranium Recovery Facilities....................................................... 33 (ISA14) Decommissioning Reactors...................................................................................... 36 (ISA15) Solid Radwaste Management and Processing......................................................... 38 (ISA16) Environmental Reviews............................................................................................ 41 (ISA17) Radioactive Material Transportation (OPTIONAL)................................................... 43 (ISA18) Fire Protection Program (OPTIONAL)...................................................................... 48 (ISA19) Financial Assurance (OPTIONAL)............................................................................ 50 TECHNICAL PROFICIENCY-LEVEL ON THE JOB ACTIVITIES............................................... 54 (OJT-1) Readings (Supervisor to select readings).................................................................. 55 (OJT2) Licensing and Concurrence Processes..................................................................... 58 (OJT3) Writing Correspondence, Report, and other Document Ensuring Work Product Quality and Consistency......................................................................................................... 61 (OJT4) Emergency Drill/Exercise Observation (OPTIONAL)................................................. 63 Form A1: Technical Proficiency-Level Requirements Signature Card............................... 66 Form A2: Technical Proficiency-Level Equivalency Justification....................................... 69 Form A-3: Detailed Waiver for Certification Requirement: Equivalency Justification.......... 73 : Revision History IMC 1248, Appendix M............................................................... 1

Issue Date: TBD 1

1248 App M INTRODUCTION The U.S. Nuclear Regulatory Commission (NRC) Division of Decommissioning, Uranium Recovery, and Waste Programs (DUWP) Project Manager and Technical Reviewer qualification program requires that you, the project manager or technical reviewer candidate, complete a variety of activities, each of which is designed to help you learn information or practice a skill that will be important to performing your job independently. You will have demonstrated each of the competencies that describe a successful Project Manager or Technical Reviewer when you complete the entire qualification process, including Appendix J, Basic Level Certification Requirements for Division of Decommissioning, Uranium Recovery, and Waste Programs Project Managers and Technical Reviewers and Appendix M, Technical Proficiency-Level Certification Requirements for Division of Decommissioning, Uranium Recovery, and Waste Programs Project Managers and Technical Reviewers of Inspection Manual Chapter (IMC) 1248, Qualification Program for Federal and State Materials and Environmental Management Programs. The training courses and activities listed in this IMC are required to qualify as a DUWP Project Manager or Technical Reviewer.

A competent project manager and technical reviewer should:

a.

Understand the legal basis and the processes used for achieving the NRCs regulatory objectives.

b.

Acquire a fundamental understanding of the NRCs organizational structure, mission, goals, and objectives.

c.

Understand the basis for the authority of the agency.

d.

Understand the processes established to achieve the regulatory objectives.

e.

Master the techniques and skills needed to collect, analyze, and integrate information using a safety and security focus to develop a supportable regulatory conclusion.

f.

Have the personal and interpersonal skills to carry out assigned regulatory activities either individually or as a member of a team.

TECHNICAL PROFICIENCY-LEVEL PROGRAM ORGANIZATION The qualification process provides you with sufficient information on appropriate technologies to allow you to carry out your responsibilities in accordance with the NRC regulations, policies, and procedures. As described in IMC 1248 Appendix J, the DUWP staff qualification process is divided into two levels: (1) Basic-Level and (2) Technical Proficiency-Level. This IMC covers item (2).

If you are assigned to a position that requires specific discipline qualifications, you must successfully complete the appropriate technical proficiency-level training. In addition to the technical proficiency-level training in this IMC, other training may be necessary to supplement or enhance your development, as determined by your immediate supervisor. Your immediate

Issue Date: TBD 2

1248 App M supervisor may assign qualified or senior staff to work with you on the activities (e.g.,

discussions, seminars, guidance). This IMC specifies the minimum qualification requirements.

Your immediate supervisor and/or division management are expected to customize your training course assignments based on your formal education, other formal training, experience, and on-the-job training. Before customizing, your immediate supervisor must consider whether the changes are necessary for you to perform your assigned functions. Any customization must be documented to include the reason for the change. Division management will resolve any disagreement between you and your immediate supervisor resulting from the customization.

Where appropriate, your immediate supervisor should use the Individual Development Plan (IDP) NRC Form 321 to document the training course assignments.

Successful completion of the basic-level requirements can be a prerequisite to beginning the technical proficiency-level training unless specifically noted. The proficiency-level focuses on further developing the teamwork and interpersonal skills needed to function either independently or as part of a team to implement the DUWP program and focuses on developing the appropriate depth of knowledge in a specific technical area. Technical proficiency-level training activities are unique to each program area within DUWP.

QUALIFICATION JOURNAL ORGANIZATION The qualification journal identifies the training courses, the Independent Study Activities (ISA) and On the Job Training (OJT) activities you must complete. Document your progress on the signature cards and certifications as you move through the qualification process. Sign-offs by your supervisor or designee are required and equate to a certification that you successfully demonstrated knowledge of this material. Your supervisor or their designee reviews the evaluation criteria and, in the form of questions, determines if you have read and understood the required materials.

The signature card (Form A-1) provides suggested completion times for ISAs and OJTs to keep you on track toward completion. The two ISAs should be done first. However, ISAs and OJTs may be completed in any order approved by your supervisor.

The journal also contains a form to document the justification for accepting equivalent training or experience as a way to meet qualification requirements. The signature cards, certification, and equivalency justification pages form the permanent record of completing the technical proficiency-level qualification program.

Upon certification, the qualification memorandum will be placed into the Agencywide Document Access and Management System (ADAMS), and the qualification information will be entered into the Talent Management System (TMS) by sending a request to TrainingSupport.Resource@nrc.gov. The request to the TMS support group shall include your name, qualification achieved, date qualified, and the accession number of the ADAMS entry.

The certification document that was placed into ADAMS and recorded in TMS shall serve as proof of qualification. You may retain your qualification signature and equivalency card(s).

REQUIRED AND OPTIONAL TECHNICAL PROFICIENCY-LEVEL TRAINING COURSES The technical proficiency-level required training (PR) courses listed below can be taken in any order. The technical proficiency-level optional training (PO) courses listed below are not

Issue Date: TBD 3

1248 App M required and can be taken at any time. Successful completion of any of the following courses should be documented on the signature card (see Form A-1 below).

Budget reductions, delays in establishing replacement contracts, or the unavailability of critical instructors might result in the long-term unavailability of NRC-controlled courses required for certification. In this case, the supervisor should coordinate with Office of the Chief Human Capital Officer regarding an alternative. This does not remove the need for you to attend the required course, or a suitable alternative, if one can be found. It is expected that your schedule will be adjusted as necessary to allow and require you to attend the required training when it is made available.

TABLE 1: TECHNICAL PROFICIENCY-LEVEL TRAINING COURSES1 TMS Course RTAB Risk Analysts RDB PM/TR (HP/GWH)

URMDB PM/TR (HP/GWH)

LLWPB Project Managers Integrating Risk into Regulatory Reviews2 PR PR PR PR Leading through Problem Solving and Decision-Making PR PR PR PR Introduction to NEPA and Environmental Reviews at the NRC PR PR PR PR Tribal Interactions: Staff Support &

Other Resources PR PR for PMs, PO for Technical Reviewers PR PR Introductory Health Physics (H-117S), Fundamental HP (H-122S),

HP for Uranium Recovery (F-104)3 PO H-117S PR H-122S PO F-104 PR H-117S PO H-122S PO F-104 PR H-117S PO H-122S PR F-104 PO H-117S PR H-122S PO F-104 Fundamental Health Physics Labs (H122)

PO PO for PMs, PR for HPs PO for PMs, PR for HPs PO Advanced Health Physics (H201)

PO PO for PMs, PR for HPs PO for PMs, PR for HPs PO MARSSIM: Multi-Agency Radiation Survey and Site Investigation PO PO for PMs, PO for PMs, PO 1 (PR) - Proficiency-level Required; (PO) - Proficiency-level Optional; LLWPB - Low-Level Waste and Projects Branch, RTAB - Risk and Technical Analysis Branch, RDB - Reactor Decommissioning Branch, and URMDB -

Uranium Recovery and Material Decommissioning Branch. All activities/courses are in (TMS) - Talent Management System.

2 Integrating Risk into Regulatory Reviews or Introduction to Risk Assessment for Materials Safety & Waste Management 3 Introductory Health Physics (H-117S) and Fundamental Health Physics (H-122S) are both online self-study courses.

Health Physics for Uranium Recovery (F-104) is a weeklong instructor-led course with a trip to a uranium recovery facility. Introductory Health Physics (H-117S) may be assigned to candidates with little or no HP experience as a precursor to completing H-122S and/or F-104 respectively.

Issue Date: TBD 4

1248 App M TMS Course RTAB Risk Analysts RDB PM/TR (HP/GWH)

URMDB PM/TR (HP/GWH)

LLWPB Project Managers Manual Instructor-Led (H-121) or Self-Study Course (H121S)

PR for Technical Reviewers PR for Technical Reviewers MARSAME: Multi-Agency Radiation Survey and Assessment of Materials and Equipment Manual (H120S)

PO PO for PMs, PR for HPs PO for PMs, PR for HPs PO Facility Decommissioning (H-112)

PO PR PR PO Characterization and Planning for Decommissioning (H-115S)

PR PR PR PO Fundamentals of Operating Reactor Licensing Series (G-120A,B, and C)

PO PR PO PO RESRAD Overview (H-408)

PR PO for PMs, PR for Technical Reviewers PO PO Advanced RESRAD Training Workshop (H412)

PO PO for PMs, PR for Technical Reviewers PO for PMs, PR for Technical Reviewers PO MILDOS - Area Training Workshop (H413)

PO PO for PMs, PR for Technical Reviewers PO for PMs, PR for Technical Reviewers PO Visual Sampling Plan (H-500)

PO PO for PMs, PR for Technical Reviewers PO for PMs, PR for Technical Reviewers PO Low-Level Waste: Ask SME and Learn: Principles into Practice -

Low-Level Waste Regulation, (4 Lectures)

PO PR PO PR 10 CFR Part 61 Low Level Waste Training (TMS Curriculum)

PR PO PO PR Evaluation of Dose Modeling for Compliance with Radiological Criteria for License Termination PR PR PR PO Advanced Evaluation of Dose Modeling Course PR PO PO PO

Issue Date: TBD 5

1248 App M TMS Course RTAB Risk Analysts RDB PM/TR (HP/GWH)

URMDB PM/TR (HP/GWH)

LLWPB Project Managers Environmental Monitoring and Air Sampling for Radioactivity Lab Course H130 L or Environmental Monitoring and Air Sampling for Radioactivity Self-Study Course (H130S)

PR PR PR PO Grove Engineering Microshield Code (External)

PR PO for PMs, PR for Technical Reviewers PO PO Root Cause/Incident Investigation Workshop (G205)

PR PO PO PO Training in Goldsim (External)

PR PO PO PO Fuel Cycle Processes (F-201)

PO PO PR PO Transportation of Radioactive Materials (H-308)

PO PO PO PR EnergySolutions: NRC/DOT Waste Packaging, Transportation, &

Disposal (External) or Transportation of Radioactive Materials (H-308)

PO PO PO PR Dade Moeller:

Low-Level Radioactive & Mixed Waste Management (3rd day only, if already taken EnergySolutions course above) (External)

PO PO PO PO Project Management Principles PO PO PO PO Reactor Concepts (R-100)

PO PO PO PO Licensing Practices and Procedures (G-109)

PO PO PO PO Inspection Procedures (G-108)

PO PO PO PO Air Sampling for Radioactive Materials (H-119)

PO PO PO PO NRC Materials Control & Security System & Principles (S201)

PO PO PO PO Radioactive Waste Technology Self-Study Course (H202S)

PO PO PO PO

Issue Date: TBD 6

1248 App M TMS Course RTAB Risk Analysts RDB PM/TR (HP/GWH)

URMDB PM/TR (HP/GWH)

LLWPB Project Managers Respiratory Protection (H-311)

PO PO PO PO Internal Dosimetry Self-Study Course (H312S)

PO PO PO PO Health Physics Statistics (H-301S)

PO PO PO PO RAMP4 PO PO PO PO Advanced Rulemaking Courses5 PO PO PO PO Princeton Groundwater Pollution and Hydrology Course (External)

PO PO PO PO Modeling of Contaminant Migration through Multimedia Systems for Disposal Sites (External)

PO PO PO PO 4RAMP_Varskin, RAMP_Phantom with Moving Arms and Legs (PiMAL), RAMP_RADionuclide, Transport, Removal, and Dose Estimation (RADTRAD) code, RAMP_Radiological Assessment Systems for Consequence AnaLysis (Rascal), RAMP_Decontamination and Decommissioning (DandD) software, RAMP_Gaseous and Liquid Effluent (GALE) code, RAMP_MCNP, RAMP_RESRAD 6.0 code, RAMP_RESRAD-BUILD 3.0 code 5Advanced Rulemaking Courses include the following: Advanced Rulemaking at NRC, Specific Topics in Rulemaking, Advanced Specific Topics in Rulemaking: Writing Amendatory Language and Regulatory Text, Advanced Training for Responding to Public Comments in Rulemaking

Issue Date: TBD 7

1248 App M TECHNICAL PROFICIENCY-LEVEL INDIVIDUAL STUDY ACTIVITIES The ISAs are designed to direct and focus your efforts as you begin reviewing documents important to your job performance. Each study activity begins with a purpose statement informing you of why the activity is important and how it relates to your job. The level of effort has been noted so that you have an idea of how much effort should be expended in completing the activity. (Of course, the times are estimates. You may need a little more or a little less time.)

The evaluation criteria are listed up front so that you will review them first and better understand what you are expected to achieve as a result of completing the activity. Use the evaluation criteria to help you focus on what is most important. The tasks outline the things you must do to successfully address the evaluation criteria.

The following general guidance applies as you complete the various study activities:

The two ISAs should be done first. Becoming familiar the internal and external websites and the regulatory impacts of major events in your overall role as a project manager or technical reviewer is important for successfully completing the remaining activities. You should also become familiar with the content of the remaining ISAs so that you can complete the ISAs as opportunities arise.

Complete all assigned parts of each activity.

You should meet frequently with your immediate supervisor, who will act as a resource as you complete each activity. Your immediate supervisor may also designate qualified project managers or technical reviewers as mentors to work with you. You should discuss any questions you may have about the meaning of the content of the material you read with your immediate supervisor or mentor. Your supervisor has the authority to waive any of the ISA modules by completing Form A-2: Technical Proficiency-Level Equivalency Justification, found at the end of this journal.

You are responsible for keeping track of the tasks you have completed. You should complete all the assigned tasks in each activity before meeting with your immediate supervisor for evaluation. Always obtain your supervisors signature on the line item for Technical Proficiency-Level Certification Signature Card (see Form A-1).

Issue Date: TBD 8

1248 App M Technical Proficiency-Level Individual Study Activity

Issue Date: TBD 9

1248 App M (ISA-1) Navigating the NRC Internal and External Websites PURPOSE:

The purpose of this activity is to familiarize you with the NRCs internal and external websites and SharePoint site and to acquaint you with the important information available. NRC staff must routinely review a variety of documents to support their activities. Almost all of these documents are available electronically. This activity will familiarize you with the locations of documents and information vital to your job. Thus, you will begin to build the knowledge you will need later to successfully perform your assigned responsibilities.

COMPETENCY AREA:

INFORMATION TECHNOLOGY LEVEL OF EFFORT:

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months

REFERENCES:

1. NRC internal and external websites and internal SharePoint site EVALUATION CRITERIA:

There are no specific evaluation criteria for this activity. Use your supervisor or other agency personnel as a resource as you complete this activity.

TASKS:

Open your internet browser and do the following:

1. Explore the NRCs internal homepage:

a. Locate the Ethics area:

i.

Review the information available.

ii.

Note the various sources of ethics advice and the location of the Ethics Gateway for submitting questions to the NRC ethics team.

b. Locate the Library Services area (NRC Technical Library):

NOTE: Circumstances may result in some parts of the sites being unavailable at times. Also, be aware that some of the titles or content of the sites may change. Please review the most recent versions of the sites and complete as much as possible. There are often several ways to reach a particular piece of information. As you navigate the various sites, you may want to bookmark specific information that you will need to access later to complete other activities.

Issue Date: TBD 10 1248 App M

i.

Review the information available.

c. Locate each of the four NRC Regional Offices homepages and SharePoint sites:

i.

Review the functions of each of the NRC Regional Offices ii.

Identify each of the four Regional Administrators.

d. Locate the Office of Nuclear Materials Safety and Security (NMSS) homepage and SharePoint site:

i.

Review the functions of NMSS ii.

Identify the Director, NMSS.

iii.

Find and review the NMSS organization down to your branch.

iv.

Find and review the NMSS Policy & Procedure documents (NMSS P&Ps).

e. Locate the following Offices homepages and SharePoint sites and review the functions of the office:

i.

Office of Nuclear Reactor Regulation (NRR) ii.

Office of Nuclear Regulatory Research (RES) iii.

Office of Nuclear Security and Incident Response (NSIR) iv.

Office of Enforcement (OE)

v.

Office of International Programs (OIP) vi.

Office of the General Counsel (OGC)

f.

Location the Office of the Executive Director for Operations (OEDO) homepage and SharePoint site:

i.

Review the OEDOs Communications website.

ii.

Review guidance on Communication Tools and Plans.

iii.

Review the Public Meeting Policy.

iv.

Review the OEDO Procedures.

g. Locate the Office of the Secretary (SECY) homepage and SharePoint site:

i.

Review the functions of the office.

ii.

Review the purpose of a SECY Paper (both Notation Vote and Information).

iii.

Review the purpose of Staff Requirement Memoranda (SRM).

h. Locate the NRC Management Directive (MD) website:

Issue Date: TBD 11 1248 App M

i.

Find the MD dealing with the NRC Incident Investigation Program and review the purpose of the program.

ii.

Find the MD dealing with the Management of Allegations and review the general policy on disclosure of the identity of an alleger.

i.

Locate the NRC TMS website:

i.

Locate the course schedule/catalog and browse the offerings for course availability.

ii.

Review how to enroll in a course, both internal and external (SF-182).

iii.

Review the list of available web-based learning opportunities.

iv.

Review the list of other available self-paced learning opportunities.

2. Explore the NRCs external (public) website:

a. Find the Glossary (Basic References).

b. Find the NRC Inspection Manual and bookmark it.

c. Find Regulatory Guides (RGs) and read about the purpose of an RG.

d. Locate Generic Communications documents and review the purpose of each of the types of generic communications documents.

e. Find NUREGs, read about the different types of NUREGs, and determine how to tell the difference between the different types.

f.

Find the NRC regulations contained in Title 10 of the Code of Federal Regulations (10 CFR).

i.

How many volumes comprise 10 CFR? What parts are applicable to the NRC?

ii.

Use the search feature and search on change in CFR and view one of the documents to read about what a recent change to the CFR involved.

iii.

View a part of the CFR and look for the information that indicates when the regulation was issued and amended.

g. Find and review the general purposes and procedures associated with the Privacy Act and the Freedom of Information Act (FOIA).

h. Locate and review the rulemaking process.

Issue Date: TBD 12 1248 App M DOCUMENTATION:

Obtain your supervisors (or their designees) signature in the line item for Form A1: Technical Proficiency-Level Requirements Signature Card for ISA-1.

Issue Date: TBD 13 1248 App M (ISA-2) Major Industry Events and Regulatory Implications (Lessons Learned)

PURPOSE:

The purpose of this activity is to familiarize the employee with some of the lessons learned from selected major nuclear operating events and resulting changes that were made to NRC regulations or regulatory practices.

COMPETENCY AREAS: REGULATORY FRAMEWORK LEVEL OF EFFORT:

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months

REFERENCES:

1. NUREG/BR-0175, A Short History of Nuclear Regulation, 1946-2009 (ML102980443)

2. Three Mile Island Accident

a. Fact Sheet on the Three Mile Island Accident (ML040280573)

b. Three Mile Island: A Nuclear Crisis in Historical Perspective by Samuel J. Walker, Berkeley: University of California Press, 2004. (Book available in NRC Technical Library)

c. NUREG-0737, Clarification of TMI Action Plan Requirements

3. Chernobyl Accident and its Effects:

a. https://www.nrc.gov/reading-rm/doc-collections/fact-sheets/chernobyl-bg.html

b. https://www.iaea.org/newscenter/focus/chernobyl/faqs

c. https://world-nuclear.org/information-library/safety-and-security/safety-of-plants/chernobyl-accident.aspx

d. https://www.who.int/news/item/05-09-2005-chernobyl-the-true-scale-of-the-accident

4. Fukushima Dai-ichi Accident (2011)

a. Japan Lessons Learned on the NRC public website:

https://www.nrc.gov/reactors/operating/ops-experience/japan-dashboard.html

b. Near Term Task Force Review of Insights from the Fukushima Dai-ichi Accident (ML112510271)

c. NUREG-1350 NRC Information Digest, section on Japan Lessons Learned:

https://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1350/

Issue Date: TBD 14 1248 App M

5. Goiana Accident (Sealed Source) (ML110030911)

a. Historical summary: https://www-pub.iaea.org/MTCD/Publications/PDF/Pub815_web.pdf

6. Transportation accident with fresh fuel

a. IN 92-62, Emergency Response Information Requirements for Radioactive Material Shipments (ML031200035)

b. IN 93-07, Classification of Transportation Emergencies (ML031080028)

EVALUATION CRITERIA:

1. Describe some of the major changes in NRC regulations and practices due to lessons learned from four of the six incidents.

TASKS:

1. Review the references.

DOCUMENTATION:

Obtain your supervisors (or their designees) signature in the line item for Form A1: Technical Proficiency-Level Requirements Signature Card for ISA-2.

Issue Date: TBD 15 1248 App M (ISA-3) IMC, Inspection Procedures (IP), and Other References PURPOSE:

The purpose of this activity is to help you to familiarize yourself with the IMCs and IPs that have been developed and are available that relate to inspections. Your immediate supervisor will identify those references that you will focus on. This activity is meant to give you an overview of the inspection program. You will review specific IPs during training in the Technical Proficiency-Level.

COMPETENCY AREA:

INSPECTION LEVEL OF EFFORT:

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months

REFERENCES:

1. IMC 0610, Nuclear Material Safety and Safeguards Inspection Reports

2. IMC 0620, Inspection Documents and Records

3. IMC 2401, Near-Surface Low-Level Radioactive Waste Disposal Facility Inspection Program

4. IMC 2561, Decommissioning Power Reactor Inspection Program

5. IMC 2565, Regional Inspection Activities for Naval Reactors/Naval Vessels undergoing Decommissioning

6. IMC 2600, Fuel Cycle Operational Safety and Safeguards Inspection Program

7. IMC 2602, Decommissioning Fuel Cycle, Uranium Recovery and Materials Inspection Program

8. IMC 2800, Materials Inspection Program

9. IMC 2801, Uranium Recovery and 11e(2) Byproduct Material Facility Inspection Program

10. IMC 2810, Master Material License Oversight and Inspection Program

11. Other IMCs or IPs identified for review by your immediate supervisor.

12. NUREG-1757, Consolidated Decommissioning Guidance, Volume 1 EVALUATION CRITERIA:

Upon completion of this activity, you will be asked to demonstrate your understanding of the purpose of the IMCs and IPs as well as the type of information contained in them.

Issue Date: TBD 16 1248 App M

1. Discuss the IMCs and IPs you have reviewed and the purpose of the IMCs and IPs.

2. Discuss inspection documentation for different types of inspections.

3. Discuss the inspection program from one or more IMCs identified by your supervisor.

4. Describe how the IPs are used during inspection.

TASKS:

1. Locate electronic versions of the IMCs and IPs at: https://www.nrc.gov/reading-rm/doc-collections/insp-manual/.

2. Review the IMCs and IPs.

DOCUMENTATION:

Obtain your supervisors (or their designees) signature in the line item for Form A1: Technical Proficiency-Level Requirements Signature Card for ISA-3.

Issue Date: TBD 17 1248 App M (ISA-4) The Federal Register (FR)

PURPOSE:

The purpose of this activity is to understand the relationship between the FR and the CFR.

COMPETENCY AREAS: REGULATORY FRAMEWORK LEVEL OF EFFORT:

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months

REFERENCES:

1. FR Tutorial: What it is and How to Use It: https://www.archives.gov/federal-register/tutorial

2. NRC internal web site: The NRC Rulemaker, specifically Federal Register Notice (FRN) and Rulemaking Tracking links (https://usnrc.sharepoint.com/teams/NMSS-The-NRC-Rulemaker)

3. Office of the Federal Register Document Drafting and Incorporation by Reference Handbooks: https://www.archives.gov/federal-register/write/handbook

4. Public website: HeinOnline database: http://home.heinonline.org EVALUATION CRITERIA:

1. Explain the difference and the relationship between a FRN and the CFRs.

2. Describe the different FRN document categories.

3. Identify several headings in a proposed and a final rule FRN and their purpose.

4. Identify who, within the NRC, liaisons with the OFR and when.

5. Describe who maintains the FRN templates and where these can be found.

6. Describe who reviews and who concurs on the FRN for a proposed rule, final rule, regulatory basis (draft and final), petition for rulemaking (PRM) docketing, PRM closure, advanced notice of proposed rule, meeting notice, supplemental proposed rule, availability of documents for public comment (guidance, RG, NUREG, regulatory basis, etc.).

TASKS:

1. Review the references to understand the principles discussed in the evaluation criteria.

Issue Date: TBD 18 1248 App M

2. Complete the Federal Register tutorial.

3. Review FRN for a final rule and the corresponding change in the CFRs.

4. Explore the HeinOnline database.

DOCUMENTATION:

Obtain your supervisors (or their designees) signature in the line item for Form A1: Technical Proficiency-Level Requirements Signature Card for ISA-4.

Issue Date: TBD 19 1248 App M (ISA-5) Orders PURPOSE:

The purpose of this activity is to become familiar with regulations regarding Orders COMPETENCY AREAS: REGULATORY FRAMEWORK LEVEL OF EFFORT:

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months

REFERENCES:

1. DORL Handbook:

https://usnrc.sharepoint.com/teams/NRRDORLHandbook/SitePages/Home.aspx

2. 10 CFR 2.202, Orders

3. 10 CFR 2.204, Demand for Information

4. 10 CRF 2.205, Civil Penalties

5. 10 CFR 50.54(f), Conditions of Licenses

6. LIC-106, Issuance of Safety Orders

7. NRC Enforcement Manual (most current revision)

EVALUATION CRITERIA:

At the completion of this activity, you should be able to:

1. Describe situations for which the Commission may decide to issue an Order.

2. Describe and discuss alternative actions the Commission may take to ensure safety (Confirmatory Action Letter, 50.54(f) letter, Demand for Information, etc.).

3. Describe the different types of Orders.

4. Describe the internal and external communications requirements in support of the issuance of an Order.

5. Describe the response requirements for the recipient of an Order.

6. Describe who has the authority to revise an Order and the process for the revision of an Order.

Issue Date: TBD 20 1248 App M TASKS:

1. Review the references to meet the evaluation criteria.

2. Review a recent compliance/safety Order.

DOCUMENTATION:

Obtain your supervisors (or their designees) signature in the line item for Form A1: Technical Proficiency-Level Requirements Signature Card for ISA-5.

Issue Date: TBD 21 1248 App M (ISA-6) Controlled Correspondence PURPOSE:

The purpose of this activity is to become familiar with the systems that OEDO and NMSS use to assign and track action items, and to become familiar with MD 3.57, Correspondence Management.

COMPETENCY AREAS: REGULATORY FRAMEWORK LEVEL OF EFFORT:

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months

REFERENCES:

1. MD 3.57, Correspondence Management

2. OEDO Procedure 0357, Correspondence Management (most current version)

EVALUATION CRITERIA:

Use the reference above to answer the evaluation criteria. At the completion of this activity, you should have a clear understanding of the following:

1. The distribution process for OEDO and NMSS tracked actions.

2. The process for ticket assignment and tracking.

3. The process for extending due dates on tickets.

4. The responsibilities of a Correspondence Author (also known as the originator) (Section III of MD 3.57).

TASKS:

1. Review the references to understand the principles discussed in the evaluation criteria.

2. Identify and review a selection of recent controlled correspondence for the branchs area with your supervisor or the person designated to be your resource.

DOCUMENTATION:

Obtain your supervisors (or their designees) signature in the line item for Form A1: Technical Proficiency-Level Requirements Signature Card for ISA-6.

Issue Date: TBD 22 1248 App M (ISA-7) Security Requirements for Nuclear Power Plants and Materials Sites PURPOSE:

The purpose of this activity is to provide you with a general understanding of the requirements for the security program at nuclear power plants and materials sites.

COMPETENCY AREAS: REGULATORY FRAMEWORK LEVEL OF EFFORT:

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months

REFERENCES:

1. 10 CFR Part 37, Physical Protection of Category 1 and Category 2 Quantities of Material

2. 10 CFR Section 73.55, Requirements for Physical Protection of Licensed Activities in Nuclear Power Reactors against Radiological Sabotage

3. MD 12.6, NRC Controlled Unclassified Information (CUI) Program

4. SECY-04-0191, Withholding Sensitive Unclassified Information Concerning Nuclear Power Reactors from Public Disclosure

5. NUREG-2155, Implementation Guidance for 10 CFR Part 37, Physical Protection of Category 1 and Category 2 Quantities of Radioactive Material

6. NUREG-2166, Physical Security Best Practices for the Protection of Risk-Significant Radioactive Material EVALUATION CRITERIA:

Upon completion of this activity, you will be asked to demonstrate your understanding of security requirements at reactor and materials sites by successfully doing the following:

1. Discuss how a reactor site security force maintains access control of the owner-controlled, protected, and vital areas.

2. Discuss the applicability of a licensees drug testing program to the staff.

3. Explain the need for maintaining designation of certain material safeguards and the proper handling of the material.

4. Explain the purpose of 10 CFR Part 37 and the definitions of Category 1 and 2 materials.

Issue Date: TBD 23 1248 App M TASKS:

1. Complete all three modules of the Information Security (INFOSEC) Awareness Training that is in TMS.

2. Review the reference material to gain an understanding of the principles discussed in the evaluation criteria.

3. Discuss responsibilities related to site security and safeguards with your supervisor or the person designated as a resource or a Physical Security Inspector. Your discussion should include practical circumstances that you may encounter, such as loss of security badge, identification of an inattentive security officer, receipt of suspicious package, or receipt of a bomb threat, including actions to be taken by the licensee and you, as appropriate.

DOCUMENTATION:

Obtain your supervisors (or their designees) signature in the line item for Form A1: Technical Proficiency-Level Requirements Signature Card for ISA-7.

Issue Date: TBD 24 1248 App M (ISA8) Hearings PURPOSE:

The purpose of this activity is to become familiar with the hearing process that you may become involved in at this point of the qualification program.

COMPETENCY AREA:

REGULATORY FRAMEWORK LEVEL OF EFFORT:

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months

REFERENCES:

1. 10 CFR Part 2, Subpart C, Rules of General Applicability: Hearing Requests, Petitions to Intervene, Availability of Documents, Selection of Specific Hearing Procedures, Presiding Officer Powers, and General Hearing Management for NRC Adjudicatory Hearings

2. NRC Adjudicatory website: https://www.nrc.gov/about-nrc/regulatory/adjudicatory.html EVALUATION CRITERIA:

Upon completion of this activity, you will have a general understanding of the types of hearings, public involvement, and the hearing process.

1. Understand the types of hearings.

2. Describe public involvement in hearings.

3. Describe the hearing process.

4. Understand the types of Office activities/processes that have hearings.

TASKS:

1. Review references to understand the principles discussed in the evaluation criteria.

2. Attend Atomic Safety and Licensing Board proceedings, if possible.

DOCUMENTATION:

Obtain your supervisors (or their designees) signature in the line item for Form A1: Technical Proficiency-Level Requirements Signature Card for ISA8.

Issue Date: TBD 25 1248 App M (ISA9) Proprietary Information and Determinations PURPOSE:

The purpose of this activity is to become familiar with requirements and procedures for withholding proprietary information from public disclosure. All NRC employees need to know how to handle proprietary information.

COMPETENCY AREA:

LICENSING OVERSIGHT ACTIVITIES REGULATORY FRAMEWORK LEVEL OF EFFORT:

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months

REFERENCES:

1.

10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding

2.

MD 3.4, Release of Information to the Public

3.

MD 3.5, Attendance at NRC Staff-Sponsored Meetings

4.

MD 12.6, NRC Controlled Unclassified Information (CUI) Program

5.

NMSS Policy and Procedure 704, Handling Request to Withhold Proprietary Information from Public Disclosure EVALUATION CRITERIA:

Upon completion of this activity, you will have a general understanding of proprietary information with exceptions for withholding information and understanding of NRC CUI requirements, including the following.

1.

Understand how to handle proprietary material in accordance with agency requirements and procedures.

2.

Describe the process for handling an incoming request to withhold materials stated to be proprietary from public disclosure.

3.

Describe the process by which an entity may request to meet privately with the NRC staff to discuss proprietary matters.

4.

Understand the requirements on timeliness for making a proprietary determination.

5.

Describe the actions required in the event of an inadvertent release of proprietary information.

TASKS:

1.

Review references to understand the principles discussed in the evaluation criteria.

Issue Date: TBD 26 1248 App M DOCUMENTATION:

Obtain your supervisors (or their designees) signature in the line item for Form A1: Technical Proficiency-Level Requirements Signature Card for ISA9.

Issue Date: TBD 27 1248 App M (ISA10) 10 CFR 2.206 Petitions PURPOSE:

The purpose of this activity is to become familiar with the purpose and use of 10 CFR 2.206 and its regulatory history.

COMPETENCY AREA:

REGULATORY FRAMEWORK LEVEL OF EFFORT:

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months

REFERENCES:

1. DORL Knowledge Management Portal (Internal Use Only including licensing procedures):

https://usnrc.sharepoint.com/teams/NRRKnowledgeManagementKnowledgeTransfer

2. 10 CFR 2.202, Orders

3. 10 CFR 2.206, Requests for action under this subpart

4. NMSS Policy and Procedure 1004, Office of Nuclear Material Safety and Safeguards Delegation of Signature Authority (Official Use Only)

5. Enforcement Program Overview:

https://www.nrc.gov/about-nrc/regulatory/enforcement/program-overview.html

6. MD 8.11, Review Process for 10 CFR 2.206 Petitions

7. NUREG0750, Nuclear Regulatory Commission Issuances, Current Issuances EVALUATION CRITERIA:

At the completion of this activity, you should be able to:

1. Describe the acceptance criteria and process for petitions filed pursuant to 10 CFR 2.206.

2. Describe the performance measures and targets for petitions filed pursuant to 10 CFR 2.206.

3. Identify the required members of the Petition Review Board (PRB).

4. Describe the project manager role as a member of the PRB.

5. Describe the threshold and the closeout process correspondence that should not be entered into the 10 CFR 2.206 process.

6. Describe the signature authority for the petition-related correspondence.

Issue Date: TBD 28 1248 App M TASKS:

1. Review references.

2. Review all the documentation associated with a recently completed petition.

3. Review the documentation for correspondence that was not accepted into the 10 CFR 2.206 process.

4. Attend a PRB Meeting and if possible, attend a meeting with the petitioner.

DOCUMENTATION:

Obtain your supervisors (or their designees) signature in the line item for Form A1: Technical Proficiency-Level Requirements Signature Card for ISA10.

Issue Date: TBD 29 1248 App M (ISA11) NUREG-1757 PURPOSE:

The purpose of this activity is to expand your knowledge of NUREG-1757 Consolidated Decommissioning Guidance. Use the most recent revision of the documents and find the equivalent section if the activities listed below reference specific sections.

COMPETENCY AREA:

REGULATORY FRAMEWORK LEVEL OF EFFORT:

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months

REFERENCES:

1.

NUREG1757, Volume 1, Decommissioning Process for Materials Licensees, (ML063000243)

2.

NUREG1757, Volume 2, Characterization, Survey, and Determination of Radiological Criteria, (ML22194A859)

3.

NUREG1757, Volume 3, Financial Assurance, Recordkeeping, and Timeliness, (ML12048A683)

EVALUATION CRITERIA:

Upon completion of the tasks, you should be able to do the following:

1.

Understand the Decommissioning Process and the applicable timeline involved in Decommissioning (See, Figure 5.1Do I need to Decommission in NUREG 1757 Volume 1, The Decommission Timeliness Rule).

2.

Identify and briefly describe each of the different decommissioning groups, examples of sites that fall into each, and the changes. Understand which decommissioning group would require a Decommissioning Plan (DP) (Figure 7.1 Determining the Appropriate Decommissioning Group, NUREG1757, Volume 1).

3.

Understand the different Radiological Criteria for Decommissioning such as Unrestricted Use, Restricted Conditions, and Alternate Criteria.

4.

Understand the Decision Framework in NUREG1757, Volume 2 (Figure 1.2) and the Subsequent Section 1.4.1 and 1.4.2 of Volume 2.

5.

Describe the scoping and characterization process and how we inspect this part of the decommissioning process.

6.

Understanding the different type of Methodologies Licensee Used to demonstrate compliance to 10 CFR Part 20 (such as final status survey [FSS] and Derived Concentration Guideline Level [DCGL], Dose Modeling Approach).

Issue Date: TBD 30 1248 App M TASKS:

1.

Understanding and discuss the Decommissioning Timeliness Rule as stated above.

2.

Review the seven Decommissioning Groups and the regulatory requirements regarding each such as which group might need a DP.

3.

Read NUREG1757 Volume 2 Section 1.4, Iterative Nature of the Compliance Demonstration Process: A Decision-Making Framework.

4.

Review the Scoping and Characterization process in in NUREG1757 Volume 2 Section 4.2.

5.

Describe what kinds of surveys would be expected at various facilities and also the location of the surveys.

6.

Review the differences between simple and complex sites and some characteristics of complex sites (NUREG1757 Volume 2 Section 1).

7.

What is the National Environmental Policy Act? (NUREG1757 Volume 1 Section 15).

8.

Describe the purpose of major parts of DPs (NUREG1757 Volume 1, Part II). (ISA5)

Decommissioning Material and Fuel Cycle Facilities.

DOCUMENTATION:

Obtain your supervisors (or their designees) signature in the line item for Form A1: Technical Proficiency-Level Requirements Signature Card for ISA11.

Issue Date: TBD 31 1248 App M (ISA12) Decommissioning Material and Fuel Cycle Facilities PURPOSE:

The purpose of this activity is to provide you with an overview of the decommissioning process for material and fuel cycle facilities.

COMPETENCY AREA:

REGULATORY FRAMEWORK TECHNICAL AREA EXPERTISE LEVEL OF EFFORT:

10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months

REFERENCES:

1.

10 CFR (specific sections in tasks/evaluation criteria below)

2.

MD 5.6, Integrated Materials Performance Evaluation Program (IMPEP)

(ML19213A024)

3.

MD 5.8, Proposed Section 274b Agreements with States (ML20349A296)

4.

NUREG1575, "MARSSIM," Revision 1

5.

NUREG1757, Volumes 13, Decommissioning Process for Materials Licensees, (See ISA4)

6.

RG 3.65, Standard Format and Content of Decommissioning Plans for Materials Licensees (ML081130703)

7.

DP for a material, uranium recovery, reactor or fuel cycle facility designated by your supervisor

8.

Technical specifications and safety analysis report for a facility designated by your supervisor.

EVALUATION CRITERIA:

Upon completion of the tasks, you should be able to do the following:

1.

Discuss how to determine if the licensee met the Timeliness Rule Requirement per 10 CFR Sections 30.36(d), 40.42(d), 70.38(d), and 72.54(d).

2.

Discuss the major points in 10 CFR Part 51.

3.

Describe how the Memorandum of Understanding (MOU) with the EPA is implemented (if applicable).

4.

Generate a Safety Evaluation Report (given the opportunity).

Issue Date: TBD 32 1248 App M TASKS:

1. Read and discuss the Decommissioning Timeliness Rule.

2. Review and discuss 10 CFR Part 51.

3. Review and identify the important areas of a Safety Evaluation Report

4. Review and discuss 23 past complex materials decommissioning cases that had significant safety significance and evaluate the site the decommissioning process, safety hazards involved, lessons learned, etc.

5. Access and Navigate the Sealed Source Device Registry.

6. Access and Navigate the National Source Tracking System.

7. For fuel cycle facilities, read and discuss the criticality safety portions of 10 CFR Part 70 and the differences between inspection and licensing of criticality safety with a cognizant individual.

8. Read the DP for a facility assigned by your supervisor.

DOCUMENTION:

Obtain your supervisors (or their designees) signature in the line item for Form A1: Technical Proficiency-Level Requirements Signature Card for ISA12.

Issue Date: TBD 33 1248 App M (ISA13) Decommissioning Uranium Recovery Facilities PURPOSE:

The purpose of this activity is to provide you with an overview of the decommissioning process for uranium recovery sites.

COMPETENCY AREA:

REGULATORY FRAMEWORK TECHNICAL AREA EXPERTISE LEVEL OF EFFORT:

10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months

REFERENCES:

1. 10 CFR Part 40 and specifically 10 CFR 40 Appendix A

2. 40 CFR Part 141, National Primary Drinking Water Regulations

3. 40 CFR Part 192 Health and Environmental Protection Standards for Uranium and Thorium Mill Tailings

4. Uranium Mill Tailings Radiation Control Act (UMTRCA) of 1978, as amended.

5. RG 8.11, Applications of Bioassay for Uranium (ML15054A618)

6. RG 8.15, Acceptable Programs for Respiratory Protection (ML003739512)

7. RG 8.22, Bioassay at Uranium Mills (ML13350A638)

8. RG 8.25, Air Sampling in the Workplace (ML003739616)

9. RG 8.30, Health Physics Surveys in Uranium Recovery Facilities (ML021260524)

10. RG 8.31, Information Relevant to Ensuring that Occupational Radiation Exposures at Uranium Recovery Facilities Will Be as Low as Is Reasonably Achievable (ML021260630)

11. IMC 1230, "Quality Assurance Program for Radiological Confirmatory Measurements" (ML24079A328)

12. IMC 2801, "Uranium Mill and 11e.(2) Byproduct Material Disposal Site and Facility Inspection Program (ML21202A302)

13. IMC 1248, Appendix H, Training Requirements and Qualification Journal for Uranium Recovery Inspector (ML12240A166)

14. License for a uranium recovery site

15. NUREG1507, "Minimum Detectable Concentrations with Typical Radiation Survey Instruments for Various Contaminants and Field Conditions (ML20233A507)

Issue Date: TBD 34 1248 App M

16. NUREG1569, A Standard Review Plan for In-Situ Leach Uranium Extraction License Applications, Draft Report for Comment, Revision 1, (ML032250177)

17. NUREG1575,"Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM)," (most current revision)

18. NUREG1620, Standard Review Plan for the Review of a Reclamation Plan for Mill Tailings Sites Under Title II of the UMTRCA, Draft Report for Comment, Revision 1 (Section 5.2), (ML032250190)

19. NUREG1757, Characterization, Survey, and Determination of Radiological Criteria, Volume 2 (ML22194A859)

EVALUATION CRITERIA:

Upon completion of the tasks, you should be able to do the following:

1. Describe the different sections of the license.

2. Describe how uranium recovery fits into the fuel cycle process.

3. Describe the differences between in situ and conventional uranium recovery licensees, and how decommissioning differs at each.

4. Explain why NUREG1757 does not apply to uranium recovery decommissioning.

5. Explain how 10 CFR Section 40.42(d) applies to uranium recovery licensees and how these licensees meet the decommissioning timeliness rule.

6. Describe the difference between Title I and Title II sites as defined in the Uranium Mill Tailings Radiation Control Act (UMTRCA) of 1978, as amended.

7. Describe the relationship between the NRC and the DOE for UMTRCA Title I and II sites.

8. Describe the security controls typically necessary at a uranium recovery site and any differences expected as the site goes through decommissioning.

9. Describe what a typical soil background level of radium-226 is (a range) and why it is important for NRC licensing staff to approve a soil background value at a uranium recovery site.

10. Describe the characteristics of typical radionuclides of concern, including half-life, toxicity, soil distribution coefficient (Kd value), etc.

11. Describe the differences between a DP and a reclamation plan and when each have been used.

TASKS:

1. Review a license for a uranium recovery site identified by your supervisor

Issue Date: TBD 35 1248 App M

2. For a site identified by your supervisor, review the previous inspection history, license conditions and licensees submittals concerning decommissioning and associated Technical Evaluation Reports for related amendments.

3. Define Naturally Occurring Radioactive Material (NORM) and Technologically Enhanced Naturally Occurring Radioactive Material.

4. Define uranium tailings.

5. Identify the typical radionuclides of concern at uranium recovery sites.

6. Define cleanup level (CL).

7. Meet with a uranium recovery license reviewer and discuss the typical license review process through decommissioning.

8. Meet with a qualified uranium recovery inspector and discuss how uranium recovery is different than other material license decommissioning.

9. Review items listed in ISA on Radioactive Waste Treatment and Effluent and Environmental Monitoring and discuss with your supervisor or designated qualified inspector which items should be completed as part of this ISA.

DOCUMENTION:

Obtain your supervisors (or their designees) signature in the line item for Form A1: Technical Proficiency-Level Requirements Signature Card for ISA13.

Issue Date: TBD 36 1248 App M (ISA14) Decommissioning Reactors PURPOSE:

The purpose of this activity is to provide you with an overview of the decommissioning process for reactors from plant shutdown to license termination, including the responsibilities of NRC headquarters and the regions.

COMPETENCY AREA:

REGULATORY FRAMEWORK TECHNICAL AREA EXPERTISE LEVEL OF EFFORT:

10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months

REFERENCES:

1. 10 CFR Part 20 Subpart E, Radiological Criteria for License Termination

2. 10 CFR Section 50.82, Termination of license

3. 10 CFR Section 50.83, Release of part of a power reactor facility or site for unrestricted use

4. NUREG1575, "MARSSIM," (most current revision)

5. RG 1.179, Standard Format and Content of License Termination Plans for Nuclear Power Reactors, Revision 2 (ML19128A067)

6. RG 1.184, Decommissioning of Nuclear Power Reactors, Revision 1, (ML13144A840)

7. RG 1.185, Standard Format and Content for Post-Shutdown Decommissioning Activities Report, Revision 1 (ML13140A038)

8. NMSS Policy and Procedure 5.1, Reactor Decommissioning Program Procedure for Interfacing with the Office of Nuclear Reactor Regulation (NRR) (ML16081A259)

9. Decommissioning Lessons Learned Report (ML16085A029 and ML16302A022)

10. A post shutdown decommissioning activities report (PSDAR) of a site assigned by your supervisor

11. A license termination plan (LTP) of a site assigned by your supervisor EVALUATION CRITERIA:

Upon completion of the tasks, you should be able to do the following:

1. Discuss the process and timeline for coordinating and transferring project management responsibilities between NRR and NMSS after plant shutdown.

Issue Date: TBD 37 1248 App M

2. Discuss the steps in the decommissioning process including the following:

a. The certification requirements found in 10 CFR 50.82(a)(1)(i) and 50.82(a)(1)(ii).

b. How long a licensee has to complete decommissioning after permanent cessation of operations.

c. PSDAR purpose, contents, timeline, and associated public meeting.

d. LTP purpose, contents, timeline, and associated public meeting.

e. Requirements for non-power reactor licensees.

f.

Partial site release prior to LTP approval.

3. Explain the reduction in risks following permanent cessation of operation and how those reductions likely lead to licensees requesting a change in the licensing basis.

4. Discuss the advantages and disadvantages of the immediate dismantlement versus a period of Safe Storage (SAFSTOR).

TASKS:

1. Identify the responsibilities held by NRR and NMSS prior to and throughout the decommissioning process.

2. Review 10 CFR Section 50.82, Termination of License.

3. Review a site PSDAR and identify the decommissioning schedule and cost estimate.

4. Define the different decommissioning phases as described in RG 1.184.

5. Define major decommissioning activities.

6. Meet, as available, with the NRR and NMSS project managers and discuss an overview of the typical license amendments submitted prior to shut down and throughout the decommissioning process, including emergency preparedness, partial site releases, technical specification changes, etc.

7. Review a site LTP, identify which group is responsible for reviewing the LTP and discuss an overview of the process with an LTP reviewer.

8. Define the radiological criteria for license termination for both restricted and unrestricted use.

9. Locate the Maintenance Rule scoping and monitoring criteria for an applicable system.

DOCUMENTION:

Obtain your supervisors (or their designees) signature in the line item for Form A1: Technical Proficiency-Level Requirements Signature Card for ISA14.

Issue Date: TBD 38 1248 App M (ISA15) Solid Radwaste Management and Processing PURPOSE:

The purpose is to familiarize with the regulatory bases and historical agency positions in the area of solid radioactive waste control and processing (including control of contaminated items).

COMPETENCY AREA:

REGULATORY FRAMEWORK TECHNICAL AREA EXPERTISE LEVEL OF EFFORT:

10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months

REFERENCES:

1. 10 CFR Part 61, Licensing Requirements for Land Disposal of Radioactive Waste.

2. Radwaste system and facility description from the licensed facility designated by your supervisor

3. 10 CFR Part 20, (Subpart F, Surveys and Monitoring; 20.1501(a) and 20.1501(b)

Subpart K, Waste Disposal; 20.2002)

4. 10 CFR Part 62, Criteria and Procedures for Emergency Access to Non-Federal and Regional Low-Level Waste Disposal Facilities

5. 10 CFR Part 71, Packaging and Transportation of Radioactive Material

6. Branch Technical Position, Waste Form Technical Position, Revision 1 (ML033630746)

7. Concentration Averaging and Encapsulation Branch Technical Position, Revision 1, Volumes 1 and 2 (ML12254B065 and ML12326A611)

8. IE Circular 8107, Control of Radioactively Contaminated Material, (ML103420362)

9. IE IN 8592, Surveys of Wastes Before Disposal From Nuclear Reactor Facilities (ML031180130)

10. NUREG/BR0204, Instructions for Completing NRCs Uniform Low-level Radioactive Waste Manifest (ML20178A433)

11. IN 8620, Low-Level Radioactive Waste Scaling Factors - 10 CFR Part 61 (ML031220625)

12. Bulletin 8010, Contamination of Non-Radioactive System and Resulting Potential for Unmonitored, Uncontrolled Release to Environment (https://www.nrc.gov/reading-rm/doc-collections/gen-comm/bulletins/1980/bl80010.html)

13. NUREG/CR5569, Health Physics Positions Data Base, Revision 1 (ML093220108)

Issue Date: TBD 39 1248 App M

14. NUREG/CR6204, Questions and Answers Based on Revised 10 CFR Part 20 (ML12166A179)

15. NUREG-1736, Consolidated Guidance: 10 CFR Part 20 Standards for Protection Against Radiation (ML013330106 and ML013330154)

16. NUREG1575 "MARSSIM" (most current revision)

17. Guidance for the Reviews of Proposed Disposal Procedures and Transfers of Radioactive Material Under 10 CFR 20.2002 and 10 CFR 40.13(a) (ML18296A068)

18. Policy and Guidance Directive FC 8421, Incineration by Materials Licensees (ML060320634)

EVALUATION CRITERIA:

At the completion of this activity, you should be able to do the following:

1. Discuss and highlight the key aspects of a solid radioactive waste processing systems, and their operation at the assigned facility.

2. Discuss the purpose and principal requirements of 10 CFR Part 61 and NRC waste classification and characterization guidance.

3. Discuss NRC guidance in the area of collection of representative samples of waste for the 10 CFR Part 61 program and how changes in waste streams should be identified for purposes of waste characterization and classification.

4. Discuss the principal aspects of classification of low-level radwaste as outlined in 10 CFR Part 61.

5. Discuss and identify free release criteria for contaminated materials from Radiation Control Area (RCA) to the public domain.

6. Explain the no detectable licensed radioactive material release policy for surface contamination, volumetric contamination, and difficult to detect radionuclides.

7. Discuss the calibration technique for contamination monitors used to free release material (e.g., small article monitor (SAM), bag monitor, frisker) in order to conform to guidance in NRC Circular 8107 and IE Information Notice 8592.

8. Describe the difference between a release limit and the a no detectable criteria.

9. Describe the minimum detection sensitivity criteria that licensees must use for radiation surveys of potentially contaminated material.

TASKS:

1. Identify the purpose of each reference and what guidance the document provides.

Issue Date: TBD 40 1248 App M

2. Locate a copy of a solid radwaste section from the licensee application of a facility.

Review the design and operation of the radwaste systems. Identify the various sources of solid radioactive waste.

3. Review and highlight the key aspects and requirements for low-level radioactive waste disposal as outlined in 10 CFR Part 61 and the burial site license.

4. Review free release criteria of contaminated materials from RCA to the public domain.

5. Discuss the NRCs current policy for incineration of licensed radioactive material.

DOCUMENTION:

Obtain your supervisors (or their designees) signature in the line item for Form A1: Technical Proficiency-Level Requirements Signature Card for ISA15.

Issue Date: TBD 41 1248 App M (ISA16) Environmental Reviews PURPOSE:

The purpose of this activity is to become familiar with the purpose and requirements of environmental reviews.

COMPETENCY AREA:

REGULATORY FRAMEWORK LEVEL OF EFFORT:

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months

REFERENCES:

1. 10 CFR Part 9, Public Records

2. 10 CFR Part 51, Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions

3. MD 3.1, Freedom of Information Act

4. MD 3.2, Privacy Act

5. NUREG1748, Environmental Review Guidance for Licensing Actions Associated with NMSS Programs

6. DUWP Policy and Procedures 101, Project Management, Processing Licensing Actions, Schedules and Metric (requires Environmental Reviewer on Acceptance review team to determine whether Environmental Assessment (EA), Environmental Impact Statement (EIS) or Categorical Exclusion (Cat Ex) applies) (Internal Use only)

EVALUATION CRITERIA:

Use the references and/or sections of the references above to answer the evaluation criteria.

1. Describe the purpose of 10 CFR Part 51.

2. Describe how the environmental reviews fit into the overall review.

3. Describe the major parts (chapters) of an environmental assessment and environmental impact statement.

TASKS:

1. Review the references to understand the principles discussed in the evaluation criteria.

2. Understand the criteria for categorical exclusions and how they apply. Review previous Cat Ex documentation.

Issue Date: TBD 42 1248 App M

3. Understand the process for consultation and what is not considered consultation.

Review part of EIS or EA that discusses consultation.

4. Understand the NMSS policy to share draft EAs with State before review only if NMSS center of excellence (COE) is performing the review. Be able to explain why its not required by regulation but only policy to share EAs when performed by the NMSS COE.

5. Understand how the National Environmental Policy Act of 1969 (NEPA), National Historic Preservation Act, and Endangered Species Act impact environmental reviews.

6. Understand the terrorist analysis is required to be included in EAs for specific licensing actions for those sites located in the 9th District Court Circuit.

7. Understand the timeline for when and how to publish an EA, Safety Evaluation Report (SER), and associated licensing action.

8. Understand what content should overlap in the EA and SER to provide consistency.

9. Understand which aspects of the safety and environmental reviews are conducted and tracked separately and in unison.

10. Understand Generic Environmental Impact Statement (GEIS) scope and what site-specific information would not be covered and therefore would have to be addressed in an EA for your licensing action, as applicable.

DOCUMENTION:

Obtain your supervisors (or their designees) signature in the line item for Form A1: Technical Proficiency-Level Requirements Signature Card for ISA16.

Issue Date: TBD 43 1248 App M (ISA17) Radioactive Material Transportation (OPTIONAL)

PURPOSE:

The purpose of this activity to familiarize you with the regulatory bases and historical agency positions in the area of radioactive material transportation. The NRC requires that licensees ensure adequate protection of public health and safety from exposure to radioactive material during shipment. Licensees must comply with the requirements of 10 CFR Part 20 and 10 CFR Part 71 and DOT regulations contained in 49 CFR Parts 100189. This activity will provide you with detailed knowledge of the requirements contained in regulations and position documents.

COMPETENCY AREA:

REGULATORY FRAMEWORK LEVEL OF EFFORT:

10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months

REFERENCES:

1. 10 CFR Part 20, 37, 61 71

2. 49 CFR Parts 100189

3. NUREG1608, Categorizing and Transporting Low Specific Activity Materials and Surface Contaminated Objects (ML15336A927)

4. NUREG1660, U.S. - Specific Schedules of Requirements for Transport of Specified Types of Radioactive Material Consignments (ML21229A046)

5. DOT Emergency Response Guidebook:

https://www.phmsa.dot.gov/training/hazmat/erg/emergency-response-guidebook-erg

6. IE IN 9262, Emergency Response Information Requirements for IE Radioactive Material Shipments (ML031200035)

7. IE IN 9272, Employee Training and Shipper Registration Requirements for Transporting Radioactive Materials (ML031200366)

8. GL 9509, Monitoring and Training of Shippers and carriers of Radioactive Materials:

https://www.nrc.gov/reading-rm/doc-collections/gen-comm/gen-letters/1995/gl95009.html

9. IE Bulletin 7919, Packaging of Low-Level Radioactive Waste for Burial:

https://www.nrc.gov/reading-rm/doc-collections/gen-comm/bulletins/1979/bl79019.html

10. IE Bulletin 8010, Contamination of Nonradioactive System and Resulting Potential for Unmonitored, Uncontrolled Release of Radioactivity to Environment:

https://www.nrc.gov/reading-rm/doc-collections/gen-comm/bulletins/1980/bl80010.html

11. NUREG/CR5569, Health Physics Positions Data Base, Revision 1 (ML093220108)

Issue Date: TBD 44 1248 App M

12. NUREG/CR6204, Questions and Answers Based on Revised 10 CFR 20 (ML12166A179)

13. Branch Technical Position, Waste Form Technical Position, Revision 1 (ML033630746)

14. Concentration Averaging and Encapsulation Branch Technical Position, Revision 1, Volumes 1 and 2 (ML12254B065 and ML12326A611)

15. NUREG1608, Categorizing and Transporting Low Specific Activity Materials and Surface Contaminated Objects (ML15336A927)

16. IN 8592, Surveys of Waste Before Disposal from Nuclear Reactor, (ML031180130)

17. IN 8620, Low-Level Radioactive Waste Scaling Factors, 10 CFR Part 61, (ML031220625)

18. GL 8138, Storage of Low-Level Radioactive Wastes at Power Reactor Sites:

https://www.nrc.gov/reading-rm/doc-collections/gen-comm/gen-letters/1981/gl81038.html

19. RIS 201403, Notice of 10 CFR Part 37 Implementation Deadline for NRC Licensees:

https://www.gpo.gov/fdsys/pkg/FR-2017-04-18/pdf/2017-07825.pdf

20. Radioactive Effluent Release Report EVALUATION CRITERIA:

At the completion of this activity, you should be able to do the following:

1. Discuss the packaging, labeling and marking requirements for various types of radioactive materials packages expected to be shipped from a facility, as presented in NUREG1660 and 49 CFR parts 100-189.

2. Discuss the manifesting, labeling, and placarding requirements for non-exempt types of radioactive materials packages relative to NUREG 1660.

3. Discuss the allowable radiation dose rate and contamination limits for shipment of packages of radioactive material specified in regulatory documents 49 CFR parts 100-189 and 10 CFR 71.4. The limits include transport vehicle dose limits, cab limits, and package limits, as appropriate.

4. Discuss HAZMAT training and emergency response program requirements relative to guidance in Information Notices 9262, 9272, 9509, and 49 CFR Parts 100-189.

5. Discuss Quality Assurance Requirement for a radioactive materials shipping program, as described in 10 CFR Part 71.

6. For a reactor site, discuss the stations recent radiological effluent release report and the types and amounts of radioactive waste that the licensee has disposed in the past year.

Specifically, you should be able to identify the types of waste, quantities, and the principal radionuclides contained in the various types of waste. You should also identify those types of wastes that would require more stringent packaging and identify where in the Offsite Dose Calculation Manual (ODCM) such reports are required.

Issue Date: TBD 45 1248 App M

7. Discuss the purpose and principal requirements of 10 CFR Part 61 and NRC waste classification and characterization guidance.

8. Discuss NRC guidance in the area of collection of representative samples of waste for the 10 CFR Part 61 program and how changes in waste streams should be identified for purposes of waste characterization and classification.

9. Discuss the packaging, labeling and marking requirements for various types of radioactive materials packages expected to be shipped from the facility, as presented in NUREG1660 and 49 CFR Parts 100-189.

10. Discuss the manifesting, labeling, and placarding requirements for non-exempt types of radioactive materials packages relative to NUREG1660 requirements. Discuss the manifesting and placarding requirements for various types of radioactive materials packages you inspected. Discuss conformance with NUREG/BR0204.

11. For shipments you inspected during accompaniments, identify the allowable radiation and contamination dose limits specified in regulatory documents 49 CFR Parts 100189, and compare them with the values the licensee identified.

12. Discuss the allowable radiation dose rates (e.g., contact, 1 meter) and contamination limits for shipment of packages of radioactive material specified in regulatory documents 49 CFR Parts 100-189. The limits include transport vehicle dose limits, cab limits, and package limits, as appropriate.

13. Discuss the principal aspects of classification of low-level radioactive waste as outlined in 10 CFR Part 61. Identify and discuss the licensees 10 CFR Part 61 waste stream analysis program and the various waste streams present and compare those identified with that reported by the licensee in its annual report.

14. Discuss how the licensee ensures collection of representative samples of waste for the 10 CFR Part 61 program and how it monitors for changes in its waste streams for purposes of waste characterization and classification. Identify how the licensee ensures meeting branch technical positions and is aware of guidance in Information Notice 86-20.

15. Demonstrate and discuss how the licensee uses the 10 CFR Part 61 waste stream analysis data, and any scaling factors and calculations, 1) to account for difficult-to-measure radionuclides, and 2) to determine curie content for waste to be shipped including concentration averaging. Specifically, identify how the licensee quantifies Table 1 and Table 2 radionuclides in 10 CFR 61.55.

16. Describe the security program under Part 37 program for a site chosen by your supervisor. Describe the types of material and the controls in place and compare them to the regulations to determine their adequacy.

17. Discuss Quality Assurance (QA) Requirements for a radioactive materials shipping program, as described in 10 CFR Part 71 including the collection of representative samples and 10 CFR Part 20, Appendix J.

Issue Date: TBD 46 1248 App M TASKS:

1. Review and familiarize yourself with the documents listed in the reference list and in the list of other important references. Specifically, identify the purpose of each document and what guidance the document provides.

2. Review the requirements for the transfer and receipt of radioactive material as specified in 10 CFR Part 20 and 10 CFR Part 71, including reporting requirements for problems identified.

3. Review the requirements in the area of training and emergency response as specified in 49 CFR parts 100189. Identify minimum training requirements and minimum emergency response requirements.

4. Review and familiarize yourself with the references listed above. Specifically, identify the purpose of each document and what guidance the document provides.

5. Review the requirements for the transfer and receipt of radioactive material as specified in 10 CFR Part 20 and 10 CFR Part 71, including reporting requirements for problems identified.

6. Review and highlight the key aspects and requirements for low-level radioactive waste disposal as outlined in 10 CFR Part 61 and Part 71, and the burial site license.

7. Review the contents of either a reactor licensees Process Control Program (PCP) or equivalent procedures at a materials site, use of scaling factors for hard-to-detect nuclides, and the waste form and characteristic requirements for disposal of solid radioactive waste.

8. Review the requirements in the area of training and emergency response as specified in 49 CFR Parts 100189. Identify minimum training requirements and minimum emergency response requirements.

9. Discuss how one would verify that a licensee is checking to see if another licensee is authorized to receive a radioactive material shipment package.

10. Select at least five non-exempt radioactive materials shipments and review for compliance with all appropriate regulatory requirements including conformance with the cask certificate of compliance for the shipping casks used.

11. Observe the packaging, surveying, labeling, marking, vehicle checks, emergency instruction, disposal manifests, shipping papers, and loading of a radioactive waste shipment (a non-exempt shipment preferable). Inter-compare your findings with applicable regulatory requirements. This can be done concurrent with applicable OJTs.

12. Review corrective action reports in the area of radioactive waste processing, handling, storage, and transportation to identify problems in this area and to understand the licensees corrective action process.

13. Review the Part 37 program at a site chosen by your supervisor. Review the types of materials and controls in place.

Issue Date: TBD 47 1248 App M

14. Review the scenario provided below and discuss the questions with your supervisor or designated inspector.

15. Meet with your supervisor or a qualified inspector to discuss any questions you may have as a result of this activity. Discuss answers to the questions listed under the evaluation criteria section of this study guide with your supervisor.

DOCUMENTION:

Obtain your supervisors (or their designees) signature in the line item for Form A1: Technical Proficiency-Level Requirements Signature Card for ISA17.

Example:

On October 7, 2003, a low-level radioactive waste shipment consisting of two box containers (volume of approximately 1400 cubic foot each) was prepared by the licensee and offered to a carrier for transport to a waste processing contractor. Each of the sea-land (box) containers housed plastic bagged waste with one containing Green is Clean potentially contaminated dry waste and the other dry active waste (DAW). The sea-land containers were loaded back-to-back on an open, flatbed trailer with the DAW container loaded toward the rear of the vehicle. The shipment was consigned as exclusive use and categorized as class 7 (radioactive) materials, low specific activity, containing a total activity of about 67 millicuries of primarily mixed activation products. The shipment departed the site at approximately 2:00 p.m. on October 7, 2003, and arrived at the waste processing facility about 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months later.

On October 8, 2003, radiation measurements performed by waste processing contractor personnel on the exterior surface of the packages (the sea-land containers) identified a highly localized area of elevated radiation on the external surface of the DAW container that exceeded the Department of Transportation (DOT) limit provided in 49 CFR Section 173.441. Specifically, a coin-sized (one-inch diameter) spot measuring 250 millirem/hour was identified on the external surface of the sea-land containers rear door, about three and one-half feet up from the bottom of the package and one and one-half inches lateral to a vertical metal bar used to latch the containers door. Package and vehicle surveys performed by the licensee prior to the shipments departure on October 7, 2003, documented a maximum package surface radiation level of 33 millirem/hour on the DAW filled container that was located in the same general location as the coin-sized hot spot identified at waste processing contractor.

Issue Date: TBD 48 1248 App M (ISA18) Fire Protection Program (OPTIONAL)

PURPOSE:

The purpose of this activity is to provide you with information on decommissioning fire protection program that is maintained and implemented throughout decommissioning.

COMPETENCY AREA:

REGULATORY FRAMEWORK LEVEL OF EFFORT:

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months

REFERENCES:

1. 10 CFR Section 50.48, Fire Protection

2. RG 1.191, Fire Protection Program for Nuclear Power Plants During Decommissioning, Revision 1 (ML20287A199)

3. Licensees Fire Protection Program Procedure for a site identified by your supervisor

4. Licensees Fire Hazard Analysis for a site identified by your supervisor EVALUATION CRITERIA:

Upon completion of this activity, you will be asked to demonstrate your understanding of the fire protection program by successfully doing the following:

1. Discuss the general content of 10 CFR Section 50.48(f).

2. Discuss the general content of RG 1.191, Revision 1, Fire Protection Program for Nuclear Power Plants During Decommissioning.

3. Discuss the objectives and implementation of the Fire Protection Program at Permanently Shutdown Reactors IP.

4. Discuss, in general terms, the contents of the licensees Fire Hazard Analysis and pre-fire plan strategies.

5. Discuss the general changes expected to a sites fire protection program over the decommissioning process.

TASKS:

1. Define the following:

a. Automatic Fire Suppression Systems

b. Manual Fire Suppression Systems

Issue Date: TBD 49 1248 App M

c. Fire Detection Systems

d. Combustible Material

i. Transient ii. Fixed

e. Fire Area

f.

Fire Barrier

g. Hot work

h. Pre-Fire Plan

2. Discuss what areas of the site are most risk significant from a decommissioning fire protection viewpoint.

DOCUMENTATION:

Obtain your supervisors (or their designees) signature in the line item for Form A1: Technical Proficiency-Level Requirements Signature Card for ISA18.

Issue Date: TBD 50 1248 App M (ISA19) Financial Assurance (OPTIONAL)

PURPOSE:

The purpose of this activity is to provide you with information to be knowledgeable on financial assurance for materials decommissioning site and on the implementation of the financial assurance section of IP 71801. The objectives of IP 71801 include identifying and documenting the status, progress, and changes that potentially impact decommissioning financial assurance, to supplement information for the Financial Assurance Branch (FAB) to support and ensure a thorough financial analysis review of the annual decommissioning trust fund reported by the licensee.

COMPETENCY AREA:

REGULATORY FRAMEWORK TEAMWORK LEVEL OF EFFORT:

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months

REFERENCES:

1. 10 CFR Section 50.75, Reporting and recordkeeping for decommissioning planning and 10 CFR Section 50.82, Termination of licenses

2. 10 CFR Section 30.35, Financial assurance and recordkeeping for decommissioning, 10 CFR Section 40.36, Financial assurance and record keeping for decommissioning, and 10 CFR Section 70.25, Financial assurance and recordkeeping for decommissioning.

3. MD 8.12, Decommissioning Financial Assurance Instrument Security Program (ML120030527)

4. RG 1.159, Assuring the Availability of Funds for Decommissioning Nuclear Reactors, Revision 2 (ML013330279)

5. RG 1.185, Standard Format and Content for Post-Shutdown Decommissioning Activities Report, Revision 1 (ML13140A038)

6. RG 1.202, Standard Format and Content of Decommissioning Cost Estimates for Nuclear Power Reactors (ML050230008)

7. IP 71801 Decommissioning Performance and Status Reviews (ML20240A293)

8. NUREG1713, Standard Review Plan for Decommissioning Cost Estimates for Nuclear Power Reactors (ML043510113)

9. NUREG1757, Financial Assurance Recordkeeping and Timeliness, Volume 3 (See ISA4)

Issue Date: TBD 51 1248 App M

10. LIC205, Procedures for NRCs Independent Analysis of Decommissioning Funding Assurance for Operating Nuclear Power Reactors and Power Reactors in Decommissioning, Revision 6 (ML17075A095)

11. Reactor Decommissioning Financial Assurance Working Group Final Report (ML20120A550)

12. PSDAR for a site identified by your supervisor

13. Decommissioning funding plan for a site identified by your supervisor

14. LTP for a site identified by your supervisor (if available)

EVALUATION CRITERIA:

Upon completion of this activity, you will be asked to demonstrate your understanding of financial assurance requirements by successfully doing the following:

1. Discuss the general content of the regulations read in Task 2.

2. Discuss why is it so important for a licensee to obtain and maintain financial assurance.

3. Discuss the general timeline of when a licensee can use their decommissioning funds and restrictions on use.

4. Describe how to implement the financial assurance portions of decommissioning IPs, including the purpose and when to implement the spot check program.

5. Describe the general content of the Decommissioning Cost Estimate section of a PSDAR and/or the decommissioning funding plan for a site(s) assigned by your supervisor.

6. Describe the general content of a financial assurance report.

7. Identify the maximum amount of time a reactor and/or materials site can take to decommission a facility.

8. Describe how financial assurance licensing actions are performed for materials licensees and the NRCs storage and handling criteria for original financial instruments.

9. Describe the role of the FAB, including review of pre-notification of disbursement of funds and periodic reports from the licensee.

TASKS:

1. Read the Decommissioning Cost Estimate section of the PSDAR and/or a decommissioning funding plan for a site(s) assigned by your supervisor. Skim NUREG-1713 as necessary.

2. Read 10 CFR 50.75 and 10 CFR 50.82 and/or 10 CFR 30.35, 10 CFR 40.36, and 10 CFR 70.25 as directed by your supervisor.

Issue Date: TBD 52 1248 App M

3. Read a financial assurance report for a site assigned by your supervisor.

4. Meet with a license reviewer and discuss how financial assurance licensing reviews are performed.

5. Meet with a member of the Financial Assessment Branch in NMSS. Review their role in the organization and how you interact with them as an inspector.

DOCUMENTATION:

Obtain your supervisors (or their designees) signature in the line item for Form A1: Technical Proficiency-Level Requirements Signature Card for ISA19.

Issue Date: TBD 53 1248 App M Technical Proficiency-Level On-The-Job Activities

Issue Date: TBD 54 1248 App M TECHNICAL PROFICIENCY-LEVEL ON THE JOB ACTIVITIES The OJT activities require you to perform project manager or technical reviewer activities and site/observation visits under the supervision of a qualified or senior/experienced project manager or technical reviewer. The activities are designed to allow you to observe and perform key tasks based on your knowledge under controlled circumstances. Like the ISAs, each OJT activity describes why the activity is important and what you are expected to successfully complete during the activity.

Each activity begins with a purpose statement explaining why the activity is important and how it relates to the licensing function. The level of effort gives you an idea or estimate of how many hours could be expended in completing the activity. The evaluation criteria identify what you are expected to achieve upon completing the activity. The evaluation criteria are listed up front for you to review first. You should use the evaluation criteria to focus your completion of the activity on what is most important. The tasks outline the activities you must do to successfully address the evaluation criteria.

However, your supervisor or qualified project managers or technical reviewers who have been working with you through your certification may design the OJTs to fit your circumstances (i.e.,

require additional activities in order to demonstrate your competency).

Your supervisor has the authority to waive any of the OJT modules by completing Form A-2:

Technical Proficiency-Level Equivalency Justification, found at the end of this journal.

The following general guidance applies as you complete the various OJTs:

Complete all assigned parts of each activity.

You should meet frequently with your immediate supervisor, who will act as a resource as you complete each activity. Your immediate supervisor may also designate qualified project managers or technical reviewers as mentors to work with you. You should discuss any questions you may have about the meaning of the content of the material you read with your immediate supervisor or mentor.

One of the important tasks identified in each OJT is to meet with your immediate supervisor or the person designated to be a resource and discuss the items listed in the evaluation criteria section.

You are responsible for keeping track of the tasks you have completed. You should complete all the assigned tasks in each activity before meeting with your immediate supervisor for evaluation. Always obtain your supervisors signature on the line item for Technical Proficiency-Level Certification Signature Card (see Form A-1).

Issue Date: TBD 55 1248 App M (OJT-1) Readings (Supervisor to select readings)

PURPOSE:

The purpose of this activity is to become familiar with relevant background material used to perform your designated job function.

COMPETENCY AREA:

REGULATORY FRAMEWORK LEVEL OF EFFORT:

120 hours0.00139 days 0.0333 hours 1.984127e-4 weeks 4.566e-5 months

REFERENCES:

Multiple documents (i.e., see list under TASKS)

EVALUATION CRITERIA:

Upon completion of this activity, you will be familiar with background material (use most recent version of the document) in the areas of Decommissioning, LLW, and Waste Incidental to Reprocessing (WIR). Your immediate supervisor will assign tasks primarily in your area of responsibility. Underlined ones should be reviewed by everyone.

TASKS:

1. Decommissioning:

a. NUREG-1757, Consolidated Decommissioning Guidance, Volume 1 (most current revision)

b. GAO/RCED-00-152, Radiation Standards: Scientific Basis Inconclusive and

[Environmental Protection Agency] (EPA) and NRC Disagreement Continues:

https://www.gao.gov/products/rced-00-152

c. NUREG-1700, Standard Review Plan for Evaluating Nuclear Power Reactor License Termination Plans, Volume 1 (ML18116A124)

d. NUREG-0586, Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities (ML023470327)

e. NUREG-1748, Environmental Review Guidance for Licensing Actions Associated with NMSS Programs (ML032450279)

f.

NMSS Policy and Procedure 5.1, Reactor Decommissioning Program Procedure for Interfacing with the Office of Nuclear Reactor Regulation (NRR) (ML16081A259)

g. West Valley Demonstration Project (WVDP) documents listed below:

Issue Date: TBD 56 1248 App M

i.

Final West Valley Policy Statement on Decommissioning Criteria for WVDP (67 FR 5003, February1, 2002) ii.

Implementation Plan for the Final Policy Statement on Decommissioning Criteria for the West Valley Demonstration Project (ML0350990667) iii.

IMC 0111, Region I's monitoring program at the Department of Energy's (DOE) West Valley Demonstration Project (ML20210M356)

2. LLW:

a. NUREG/BR-0121, A Guide to the Nuclear Regulatory Commission's 10 CFR Part 61 (ML120720225)

b. NUREG/BR-0204, Instructions for Completing NRC's Uniform Low-Level Radioactive Waste Manifest (ML20178A433)

c. NUREG-1853, History and Framework of Commercial Low-Level Radioactive Waste Management in the U.S. (with focus on Parts I and II) (ML070600684)

d. NUREG-0945, Volumes 1-3, Final Environmental Impact Statement on 10 CFR Part 61, (ML052590182)

e. Concentration Averaging and Encapsulation Branch Technical Position, Volumes 1 and 2 (ML14169A380)

f.

SECY-07-0180, Strategic Assessment of Low-Level Radioactive Waste Regulatory Program (review background information on the program) (ML071350291)

g. SECY-16-0118, "Programmatic Assessment of Low-Level Radioactive Waste Regulatory Program" (ML15208A305)

h. Low-Level Radioactive Waste Management and Volume Reduction, (77 FR 25760, May 1, 2012)

i.

Statement of Principles and Policy for the Agreement State Program; Policy Statement on Adequacy and Compatibility of Agreement State Programs; (62 FR 46517, September 3, 1997)

j.

RIS 2011-09, Resources Associated with Extended Storage of Low-Level Radioactive Waste, (ML111520042)

k. SER and Environmental Assessment for a recent 20.2002 disposal authorization

l.

RAMP description of Waste Classification Table TableCalculator (https://ramp.nrc-gateway.gov/codes/tablecalculator)

3. Uranium Recovery:

a. 10 CFR Part 40, Appendix A

Issue Date: TBD 57 1248 App M

b. NUREG/CR-6870, Consideration of Geochemical Issues in Groundwater Restoration at Uranium In-Situ Leach Mining Facilities (ML070600405)

c. NUREG-1569, Standard Review Plan for In Situ Leach Uranium Extraction License Application: https://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1569/index.html

d. NUREG-1620, Standard Review Plan for the Review of a Reclamation Plan for Mill Tailings Sites Under Title II of the Uranium Mill Tailings Radiation Control Act of 1978, Revision 1 (ML032250190)

4. WIR:

a. NUREG-1854, NRC Staff Guidance for Activities Related to U.S. Department of Energy Waste Determinations - Draft Report for Interim Use (ML072360184)

b. Communication Plan for Implementation of the U.S. Nuclear Regulatory Commission's Responsibilities Regarding U.S. Department of Energy's Incidental Waste Determinations (ML060190350) (Official Use Only)

c. Review one Ronald W. Reagan National Defense Authorization Act for 2005 (NDAA)

Section 3116 WIR monitoring site, include the following: Waste Determination, Performance Assessment, Technical Evaluation Report, Monitoring Plan, recent Guidance Memo for Onsite Observation Visit, recent Onsite Observation Visit Report, and recent Technical Review Report including the recent Final WIR Periodic Monitoring Report, Revision 6: https://www.nrc.gov/waste/incidental-waste/wir-process/wir-locations.html DOCUMENTATION:

Obtain your supervisors (or their designees) signature in the line item for Form A1: Technical Proficiency-Level Requirements Signature Card for OJT-1.

Issue Date: TBD 58 1248 App M (OJT2) Licensing and Concurrence Processes PURPOSE:

The purpose of this activity is to introduce you to the standards for preparing NRC documents and to allow you to demonstrate an understanding of the applicable documentation requirements. More importantly, this training will provide you with an opportunity to perform technical reviews or other licensing/oversight activities related to decommissioning and waste management under the supervision of a qualified staff. These activities include performing acceptance reviews and developing and issuing Technical Assistance Requests (TARs) and requests for additional information (RAIs) while becoming familiar with the concurrence process for NRC documents. You should develop an understanding for the format and philosophy of writing well-focused RAIs. Lastly, NRC documents serve many important functions. In addition to serving as a vehicle to communicate results to a licensee, these documents form part of the historical record of NRC activities. To that end, it is vital for you to clearly document the results of the activities conducted. To assist in the preparation of its documents, the NRC has developed several guidance documents that outline relevant information that should be documented and how that information should be presented.

COMPETENCY AREA:

REGULATORY FRAMEWORK LICENSING/OVERSIGHT ACTIVITES SELF MANAGEMENT COMMUNICATION TEAMWORK LEVEL OF EFFORT:

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months

REFERENCES:

1. DUWP Policy and Procedures 1-01, Project Management, Processing Licensing Actions, Schedules and Metric (See ISA10) (Internal Use only)

2. MD 3.57, Correspondence Management

3. NMSS Policy and Procedure 1004, Office of Nuclear Material Safety and Safeguards Delegation of Signature Authority (See ISA2)

4. NMSS Policy and Procedure 705, NMSS Processing of Technical Assistance Request

5. LIC109, Acceptance Review Procedures

6. LIC115, Processing Requests for Additional Information

7. LIC500, Processing Requests for Reviews of Topical Reports

8. Topical Reports Web page (http://www.nrc.gov/about-nrc/regulatory/licensing/topical-reports.html)

Issue Date: TBD 59 1248 App M

9. Plain Language Initiative Website, which references NUREG1379 for editorial style guidance, the directives from the President of the United States, and other related documents: https://usnrc.sharepoint.com/sites/adm-hub/SitePages/Plain-Language_delete.aspx EVALUATION CRITERIA:

At the completion of this activity, you should be able to:

1. Describe a technical review, regulatory technical coordination, or oversight activities as a project manager or technical reviewer, including performing such activities as: initial receipt of request, acceptance review process for licensing actions (describe the importance of the acceptance review), RAIs, meetings, other deliverables/products, final documentation (e.g., Technical Evaluation Report (TER)).

2. Understand the criteria and process for issuing a RAI, including the requirements for second round RAIs and the importance of developing well-focused RAIs that will enable NRC to obtain all relevant information needed to make a decision that is fully informed, technically correct, and legally defensible.

3. Describe the importance of communicating precedent setting issues and their regulatory bases.

4. Describe a TAR and its purpose, in general terms process used to generate a TAR, process for handling a TAR, process of assessing the necessity for a TAR, and performance measures and targets for TARs.

5. Understand the NRC licensing process (i.e., what type of licenses should be issued for specific programs; discuss the internal NRC process from receiving an application, amendment, renewal, or termination; and internal metrics for issuing licensing actions including using the WBL) and distinguish between the different types of licenses issued by the NRC.

6. Search ADAMS for similar licensing actions (i.e., licensee submittal and RAI),

precedence may also be identified by the project manager; review the submittal including the associated, SER, etc. and observe the concurrence package which contains the RAI.

7. Describe the process to determine who needs to concur on any given document that a technical reviewer might originate and format of a concurrence grid and the meaning of entries on that grid.

8. Describe dos and donts for concurring on a document (MD 3.57).

9. Describe how to manage concurrence of documents (i.e., how to get timely concurrence to meet the objectives). For example, discuss parallel concurrence and how to deal with unavailability of persons designated to concur. Also, review the OGC process for how to request OGC review of documents in addition to eConcurrence.

10. Describe when and how to engage with Administrative Assistants after OGC review in order to place the document in ADAMS.

Issue Date: TBD 60 1248 App M

11. Describe the criteria used for determining whether a topical report is acceptable for review and the process and schedule for review.

12. Describe the criteria and process for granting a fee waiver for the review of a topical report.

13. For decommissioning staff, discuss the decommissioning actions that you reviewed regarding an applicant or licensees request, as well as the RAI if necessary.

14. For uranium recovery staff, discuss uranium recovery actions that you reviewed, if any, regarding the applicant or licensees request as well as the RAI if necessary.

TASKS:

1. Review the references to meet the evaluation criteria.

2. Discuss the preparation and process for the concurrence package.

3. Work with a qualified staff to review the assignment and develop review schedules. You should be responsible for reviewing the actions and drafting RAIs as necessary.

4. Verify that an NRC document was written in accordance with the applicable NRC guidance (e.g., an SER was written in accordance with a Standard Review Plan) and the final document(s) was added to ADAMS.

5. Verify all the documentation associated with the licensing decision is in the docket file are in ADAMS and staff can reach back to identify the thought processes to understand why a decision was made that is different from the other licenses.

DOCUMENTATION:

Obtain your supervisors (or their designees) signature in the line item for Form A1: Technical Proficiency-Level Requirements Signature Card for OJT2.

Issue Date: TBD 61 1248 App M (OJT3) Writing Correspondence, Report, and other Document Ensuring Work Product Quality and Consistency PURPOSE:

The purpose of this activity is to familiarize you with the NRC guidance and practices for writing correspondence, reports, and other documents, with the process used to enhance the quality and consistency of technical work products produced by staff and the objectives of this process and will ensure you understand the roles and responsibilities of implementing this process.

COMPETENCY AREA:

REGULATORY FRAMEWORK COMMUNICATION SELF MANAGEMENT LEVEL OF EFFORT:

10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months

REFERENCES:

1. Plain English web pages: https://www.plainlanguage.gov/

2. NUREG1379, "NRC Editorial Style Guide

3. MD 3.57, Correspondence Management

4. Sample Correspondence

5. Writing Templates

6. NRC internal Website: Communications

7. NRC internal SharePoint site: Publication Package Procedures:

https://usnrc.sharepoint.com/teams/NMSS-The-NRC-Rulemaker/Lists/chklist/AllItems.aspx

8. NRC Public Website: Plain Writing at the NRC: https://www.nrc.gov/public-involve/open/plain-writing.html EVALUATION CRITERIA:

1. Understand how different documents are prepared in accordance with agency guidelines.

2. Understand the importance and objectives of ensuring technical product quality and consistency.

3. Be knowledgeable about the process used to enhance technical product quality and consistency through the use of peer reviews.

Issue Date: TBD 62 1248 App M TASKS:

1. Review the references to understand the principles discussed in the evaluation criteria.

2. Apply the principles to prepare agency documents, as assigned (e.g., SECY, SER, EIS, Commissioners note, etc.).

DOCUMENTATION:

Obtain your supervisors (or their designees) signature in the line item for Form A1: Technical Proficiency-Level Requirements Signature Card for OJT3.

Issue Date: TBD 63 1248 App M (OJT4) Emergency Drill/Exercise Observation (OPTIONAL)

PURPOSE:

The conduct of an emergency drill/exercise allows the licensee to assess emergency response performance and the effective correction of previously identified weaknesses. It permits the evaluation of the level of quality of emergency response training, emergency plan implementing procedures, facility and equipment readiness, personnel performance, organizational and management changes, and communications equipment readiness. This activity will permit you, the observer, to realize the scope of involvement of your particular discipline during a declared emergency at a nuclear power facility.

COMPETENCY AREA: REGULATORY FRAMEWORK INSPECTION LEVEL OF EFFORT:

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months

REFERENCES:

1. 10 CFR Part 50, Section IV.F of Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities, and 10 CFR 50.47(b)

2. IP 71114.01, Exercise Evaluation

3. IP 71114.06, Drill Evaluation

4. IP 71114.07, Exercise Evaluation - Hostile Action (HA) Event

5. IP 71114.08, Exercise Evaluation - Scenario Review EVALUATION CRITERIA:

At the completion of this activity, you should be able to do the following:

1. Discuss the Federal guidance for drill/exercise observations as described in IPs 71114.01, 71114.06, 71114.07, and 71114.08.

2. Identify activities that will occur with regard to your discipline during the performance of an emergency drill/exercise.

3. Discuss the NRC and licensee processes for documenting and handling weaknesses and deficiencies identified during a drill/exercise.

4. Discuss the NRCs method of evaluating licensee performance during an emergency drill/exercise to determine whether it has met the planning standards of 10 CFR 50.47(b).

5. Discuss the NRCs method for evaluating licensee performance during a drill/exercise to determine whether it has demonstrated the capability of providing reasonable assurance that adequate protective measures can be taken in the event of a declared emergency.

Issue Date: TBD 64 1248 App M NOTE: Whenever possible, observe a drill or exercise at a site and focus on activities related to your technical discipline.

TASKS:

1. Review IP 71114.01, IP 71114.06, IP 71114.07, and IP 71114.08 to identify the inspection attributes provided for drill/exercise performance evaluations. Discuss any questions with a senior emergency preparedness inspector.

2. Review the regulatory requirements with regard to emergency preparedness contained in 10 CFR 50.47(b) and section IV.F of Appendix E to 10 CFR Part 50.

3. Obtain an emergency drill/exercise schedule for the applicable region. Coordinate your observation of an upcoming emergency drill/exercise with your supervisor, applicable regional senior emergency preparedness inspector, and site senior resident inspector. If possible, observe the drill at the site.

4. Become familiar with the applicable licensee emergency plan and implementing procedures. In particular, review those instructions for your disciplines activities and involvement during a declared emergency and develop an understanding of their successful implementation.

5. Review IP 71114.07 to identify the inspection attributes provided for exercise scenario reviews. Obtain and review a copy of the applicable licensees emergency drill/exercise scenario. Identify activities that will occur with regard to your discipline during the performance of the emergency drill/exercise and note the licensee expectations for success versus failure.

6. Perform an independent observation of an emergency drill/exercise. Observe activities at several of the licensee emergency response facility locations, if possible (e.g., control room, operations support center, technical support center, emergency operations facility, joint information center, field activities). (Note: Take care not to interfere with licensee performance or evaluation of the drill/exercise. Do not prompt licensee participants or evaluators or provide your observations or conclusions regarding weaknesses or deficiencies during drill/exercise performance. Findings must be held confidential until after the formal licensee critique.)

7. During performance of the drill/exercise, note any possible weaknesses and/or deficiencies you observe. To aid in future discussions, obtain documentation of licensee activities during questionable performance.

8. Based on your observations, form an opinion as to whether the licensee has still met the planning standards of 10 CFR 50.47(b) in spite of any deficiency or weakness.

9. Based on your observations, form an opinion as to whether the licensee has demonstrated the capability of providing reasonable assurance that adequate protective measures can be taken in the event of a declared emergency.

10. Discuss your emergency drill/exercise observations and opinions with the lead NRC inspector and provide your recommendation on whether licensee demonstrated the capability of providing reasonable assurance that adequate protective measures can be

Issue Date: TBD 65 1248 App M taken in the event of a declared emergency and if it has met the planning standards of 10 CFR 50.47(b).

DOCUMENTATION:

Obtain your supervisors (or their designees) signature in the line item for Form A1: Technical Proficiency-Level Requirements Signature Card for OJT4.

Issue Date: TBD 66 1248 App M Form A1: Technical Proficiency-Level Requirements Signature Card Employee Name:

Certification Requirement Employees Initials/Date Supervisors Initials/Date A. Required Training (title and course number)

Integrating Risk into Regulatory Reviews Leading through Problem Solving and Decision-Making Introduction to NEPA and Environmental Reviews at the NRC Tribal Interactions: Staff Support & Other Resources Introductory Health Physics (H-117S), Fundamental HP (H-122S),

HP for Uranium Recovery (F-104)

Fundamental Health Physics Labs (H122)

Advanced Health Physics (H201)

MARSSIM: Multi-Agency Radiation Survey and Site Investigation Manual Instructor-Led (H-121) or Self-Study Course (H121S)

MARSAME: Multi-Agency Radiation Survey and Assessment of Materials and Equipment Manual (H120S)

Facility Decommissioning (H-112)

Characterization and Planning for Decommissioning (H-115S)

Fundamentals of Operating Reactor Licensing Series (G-120A, B, and C)

RESRAD Overview (H-408)

Advanced RESRAD Training Workshop (H412)

MILDOS - Area Training Workshop (H413)

Visual Sampling Plan (H-500)

Low-Level Waste: Ask SME and Learn: Principles into Practice -

Low-Level Waste Regulation, (4 Lectures) 10 CFR Part 61 Low Level Waste Training (TMS Curriculum)

Evaluation of Dose Modeling for Compliance with Radiological Criteria for License Termination Advanced Evaluation of Dose Modeling Course

Issue Date: TBD 67 1248 App M Environmental Monitoring and Air Sampling for Radioactivity Lab Course H130 L or Environmental Monitoring and Air Sampling for Radioactivity Self-Study Course (H130S)

Grove Engineering Microshield Code (External)

Root Cause/Incident Investigation Workshop (G205)

Training in Goldsim (External)

Fuel Cycle Processes (F-201)

Transportation of Radioactive Materials (H-308)

EnergySolutions: NRC/DOT Waste Packaging, Transportation, &

Disposal (External) or Transportation of Radioactive Materials (H-308)

Training:

Certification Requirement Suggested Completion Est.

Level of Effort Employees Initials/Date Supervisors Initials/Date B. Individual Study Activities (ISA-1) Navigating the NRC Internal and External Websites 1 - Month 12 hrs (ISA-2) Major Industry Events and Regulatory Implications (Lessons Learned) 1 - Month 2 hrs (ISA-3) IMC, Inspection Procedures (IP),

and Other References 1 - Month 8 hrs (ISA-4) The Federal Register (FR) 2 - Months 4 hrs (ISA-5) Orders 3 - Months 8 hrs (ISA-6) Controlled Correspondence 4 - Months 6 hrs (ISA-7) Security Requirements for Nuclear Power Plants and Materials Sites 5 - Months 6 hrs (ISA-8) Hearings 5 - Months 8 hrs (ISA-9) Proprietary Information and Determinations 5 - Months 8 hrs (ISA-10) 10 CFR 2.206 Petitions 5 - Months 6 hrs (ISA-11) NUREG-1757 5 - Months 8 hrs

Issue Date: TBD 68 1248 App M (ISA-12) Decommissioning Material and Fuel Cycle Facilities 6 - Months 10 hrs (ISA-13) Decommissioning Uranium Recovery Facilities 6 - Months 10 hrs (ISA-14) Decommissioning Reactors 6 - Months 10 hrs (ISA-15) Solid Radwaste Management and Processing 6 - Months 10 hrs (ISA-16) Environmental Reviews 7 - Months 8 hrs (ISA-17) Radioactive Material Transportation (OPTIONAL) 7 - Months 10 hrs (ISA-18) Fire Protection Program (OPTIONAL) 7 - Months 8 hrs (ISA-19) Financial Assurance (OPTIONAL) 7 - Months 8 hrs Certification Requirement Suggested Completion Est.

Level of Effort Employees Initials/Date Supervisors Initials/Date C. On the Job Training Activities (OJT-1) Readings 4-7 Months 120 hrs (OJT-2) Licensing and Concurrence Processes 7-10 Months 24 hrs (OJT-3) Writing Correspondence, Report, and other Document Ensuring Work Product Quality and Consistency 7-10 Months 10 hrs (OJT-4) Emergency Drill/Exercise Observation (OPTIONAL) 7-12 Months 24 hrs This signature card and certification must be accompanied by the appropriate Form A2 or A3, Technical Proficiency-Level Equivalency Justification, if applicable. Record completion in TMS by sending a request to TrainingSupport.Resource@nrc.org.

Supervisors Recommendation Signature/Date______________________________

Division Directors Approval Signature/Date______________________________

Issue Date: TBD 69 1248 App M Form A2: Technical Proficiency-Level Equivalency Justification Employee Name:

Identify equivalent training and experience for which credit is being given:

A. Required Training (title and course number)

Integrating Risk into Regulatory Reviews Leading through Problem Solving and Decision-Making Introduction to NEPA and Environmental Reviews at the NRC Tribal Interactions: Staff Support & Other Resources Introductory Health Physics (H-117S), Fundamental HP (H-122S), HP for Uranium Recovery (F-104)

Fundamental Health Physics Labs (H122)

Advanced Health Physics (H201)

MARSSIM: Multi-Agency Radiation Survey and Site Investigation Manual Instructor-Led (H-121) or Self-Study Course (H121S)

MARSAME: Multi-Agency Radiation Survey and Assessment of Materials and Equipment Manual (H120S)

Facility Decommissioning (H-112)

Characterization and Planning for Decommissioning (H-115S)

Fundamentals of Operating Reactor Licensing Series (G-120A,B, and C)

RESRAD Overview (H-408)

Advanced RESRAD Training Workshop (H412)

MILDOS - Area Training Workshop (H413)

Issue Date: TBD 70 1248 App M Visual Sampling Plan (H-500)

Low-Level Waste: Ask SME and Learn: Principles into Practice - Low-Level Waste Regulation, (4 Lectures) 10 CFR Part 61 Low Level Waste Training (TMS Curriculum)

Evaluation of Dose Modeling for Compliance with Radiological Criteria for License Termination Advanced Evaluation of Dose Modeling Course Environmental Monitoring and Air Sampling for Radioactivity Lab Course H130 L or Environmental Monitoring and Air Sampling for Radioactivity Self-Study Course (H130S)

Grove Engineering Microshield Code (External)

Root Cause/Incident Investigation Workshop (G205)

Training in Goldsim (External)

Modeling of Contaminant Migration through Multimedia Systems for Disposal Sites (External)

Fuel Cycle Processes (F-201)

Transportation of Radioactive Materials (H-308)

EnergySolutions: NRC/DOT Waste Packaging, Transportation, & Disposal (External) or Transportation of Radioactive Materials (H-308)

B. Individual Study Activities (ISA-1) Navigating the NRC Internal and External Websites (ISA-2) Major Industry Events and Regulatory Implications (Lessons Learned)

(ISA-3) IMC, Inspection Procedures (IP), and Other References (ISA-4) The Federal Register (FR)

Issue Date: TBD 71 1248 App M (ISA-5) Orders (ISA-6) Controlled Correspondence (ISA-7) Security Requirements for Nuclear Power Plants and Materials Sites (ISA-8) Hearings (ISA-9) Proprietary Information and Determinations (ISA-10) 10 CFR 2.206 Petitions (ISA-11) NUREG-1757 (ISA-12) Decommissioning Material and Fuel Cycle Facilities (ISA-13) Decommissioning Uranium Recovery Facilities (ISA-14) Decommissioning Reactors (ISA-15) Solid Radwaste Management and Processing (ISA-16) Environmental Reviews (ISA-17) Radioactive Material Transportation (OPTIONAL)

(ISA-18) Fire Protection Program (OPTIONAL)

(ISA-19) Financial Assurance (OPTIONAL)

C. On the Job Training Activities (OJT-1) Readings (OJT-2) Licensing and Concurrence Processes

Issue Date: TBD 72 1248 App M (OJT-3) Writing Correspondence, Report, and other Document Ensuring Work Product Quality and Consistency (OJT-4) Emergency Drill/Exercise Observation (OPTIONAL)

Division Directors Approval:

Printed Name: _______________________________

Signature/Date: ______________________________

Issue Date: TBD 73 1248 App M Form A-3: Detailed Waiver for Certification Requirement: Equivalency Justification Employee Name:

Division/Branch:

Equivalency justification for the following (check one):

_____ General Requirement

_____ Position-specific Requirement

_____ Position:

Requirement to be waived:

Justification for waiving requirement (identify equivalent training and/or experience for which the employee is to be given credit):

Division Directors Approval:

Printed Name: __________________________

Signature: _____________________________

Date: _________________________________

Copies to:

Employee TMS File ADAMS

Issue Date: TBD 74 1248 App M DIVISION OF DECOMMISSIONING, URANIUM RECOVERY, AND WASTE PROGRAMS Technical Proficiency-Level Project Manager Certification (name) has successfully completed all of the requirements to be certified as a TECHNICAL PROFICENCY-LEVEL PROJECT MANAGER CERTIFICATION Immediate Supervisor Signature: _______________

Date: __________________

DIVISION OF DECOMMISSIONING, URANIUM RECOVERY, AND WASTE PROGRAMS Technical Proficiency-Level Reviewer Certification (name) has successfully completed all of the requirements to be certified as a TECHNICAL PROFICIENCY-LEVEL REVIEWER Immediate Supervisor Signature: ____________________

Date: __________________

Issue Date:

Att1-1 1248 App M : Revision History IMC 1248, Appendix M 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 ML23338A194 date CN #

Initial issuance. This issuance is for full proficiency-level for DUWP PMs and Technical Reviewers.

Replaces UR PM and TR Training and qualification journal None None Moved training courses, ISAs, and OJTs from IMC 1248 Appendix J into Appendix M.

None None

ML25198A161

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