DEFENSE NUCLEAR FACILITIES SAFETY BOARD April 20, 1994 MEMORANDUM FOR: G. W. Cunningham, Technical Director COPIES: Board Members FROM: J. W. Troan SUBJECT: Report on the Radiation Protection Training and Qualification Program at the Savannah River Site 1. Purpose: This memorandum documents the Defense Nuclear Facilities Safety Board (DNFSB) technical staff (Staff) and outside expert assessment of the Radiation Protection Training and Qualification Program at the Savannah River Site (SRS). This assessment is based on an on-site review at the SRS conducted on March 15-18, 1994, and subsequent document reviews. 2. Summary: The SRS training organization has developed a sound radiation protection training and qualification program that is structured upon proven performance-based training concepts, and uses available DOE standardized core course training material. It is evident that individuals in the training organization have worked hard, and that substantial advances have been made in achieving a quality of training programs that rivals those of the commercial nuclear industry. The SRS training staff is generally well qualified, however, the training staff may be overextended based on current commitments. This situation should not impact the current lessons being taught, but may be affecting the staff's ability to meet the training requirements outside the classroom, such as development and implementation of new or revised training curricula. The current General Employee Radiological Training, Radiological Worker (Worker I and Worker II, and Radiological Control Technician (Technician) Training and Qualification Program appeared to meet DOE Radiological Control Manual (Manual) requirements, and progress is being made towards satisfying other DOE Order requirements. For example, the SRS Radiological Control Inspector (synonymous with (Technician)) Training and Qualification Program has successfully achieved major milestones towards program accreditation. Although the current programs are considered adequate, the Staff believes the programs that have been put in place to upgrade incumbent Technicians and their First-Line Supervisors (Supervisors) may not produce equivalent results. An uncertainty of the depth of knowledge of some incumbents is likely to persist for some time since Supervisors are not subject to a comprehensive written examination, but are expected to have oral examination boards in the Spring of 1996. The overall effectiveness of the radiation protection program was examined through field observations. Radiological control practices in the field were observed, and included training demonstrations, evolutions and personnel interviews. Personnel interviewed expressed a positive attitude toward radiological safety, the need and appreciation for training, the concepts of as low as reasonably achievable (ALARA), and the individual worker's responsibility for ensuring radiological safety. Field observations at the F-Canyon and FB-Line revealed many weaknesses in the application of proper radiological control principles and procedures. For example: pre-job briefings varied in effectiveness, and in some cases were inadequate; safety precautions were not taken during a routine evolution, as prescribed by procedure; a person, after reading a Radiation Work Permit (RWP) was not aware of the radiological conditions to be expected in the work area; and supervisory personnel in the vicinity of an unexpected occurrence during a planned maintenance evolution did not take charge or seem to know what should be done. Some of these examples of poor field practices are analogous to the Westinghouse Savannah River Corporation (WSRC) post-training evaluation results for Worker I and Worker II which may indicate a potential problem with workers' retention of knowledge and field application of acquired skills. Facility specific radiation protection training programs are at various degrees of maturity. Neither F-Canyon or FB-Line have clearly defined and formally implemented specific qualification requirements for the Supervisor; nor have they developed a drill program, or a continuing training program as required by DOE Order 5480.20, Personnel Selection, Qualification, Training, and Staffing Requirements at DOE Reactor and Non- Reactor Nuclear Facilities. Presently, personnel in the SRS training organization are developing site level Supervisor radiation protection training and qualification requirements. This is expected to further upgrade these Supervisors' knowledge, skills and abilities. However, it will take time and may require further definition and implementation of facility specific radiation protection training and qualification requirements. 3. Background: The Staff has been performing ongoing reviews of the SRS radiation protection program since l990. Major programmatic reviews were conducted in l991 and l992. Review of facility radiation protection programs including training and qualification have been performed at K- Reactor, HB-Line, and Replacement Tritium Facility since l990. This review was conducted to assess the overall site's radiation protection training and qualification program as a follow-up to the earlier reviews; and to assess the implementation at the SRS, of the applicable DOE Orders and Manual radiation protection training and qualification program requirements. James Troan, Staff; Urlich Behling and Douglas Volgenau, Outside Experts conducted this review at the SRS during March 15-18, l994. Various aspects of the radiation protection training and qualification program were examined, including: organization, responsibilities, selection criteria and qualifications requirements for the trainers, training and qualification program development and implementation for general employees, Radiological Workers, Radiological Control Technicians, and Radiological Control Technician Supervisors; other radiation protection training development and implementation, training evolutions and radiological work practices in the field; and personnel knowledge. 4. Discussion/Observations: Overall, the SRS training staff is generally well qualified with regard to educational and professional experience, and the training organization has developed a sound program that is structured upon the proven performance-based training concept. Following major comments are noted where both positive results and weaknesses were observed. Further details can be provided by the Staff. a. The current training staff may be overextended based on current commitments involving initial, continuing and requalification training. b. DOE standardized core course training materials as well as site- specific information is being used in the various Radiation Protection Training Programs. c. General Employee Radiological Training at the SRS is adequate and meets DOE requirements. d. The current Worker I and II training programs contain the essential elements for preparing workers assigned to radiological work environments. However, observations of radiological work practices in the field, conducted by members of the WSRC Training Department responsible for Radiological Worker training have indicated a disconnect between what is taught in the classroom and what is actually practiced in the field . e. The current Technician Training and Qualification Program is a sound program that meets DOE and industry standards. This is evidenced by the fact that the program has successfully achieved major milestones towards program accreditation. However, several potential weaknesses were noted. For example, an attempt has been made to raise the knowledge level of pre-1990 Technician incumbents to current standards by means of Topic 1 through 9 Training (Topic Training). Topic Training was supposedly based on a systematic evaluation of pre-1990 training programs to the current program. It is uncertain, whether training documentation and records from the 1960's, 1970's, or even 1980's were sufficiently detailed or complete to allow such an objective evaluation. This impression is supported by comments supplied by incumbents interviewed and by their response to technical questions posed during the interview. The significance of this concern is highlighted by the fact that about 280 of the current staff of 480 Technicians are pre-1990 incumbents. f. WSRC does not expect to meet the DOE Implementation Plan commitment for Board Recommendation 91-6 to have completed standardized core training for Technicians by December 1994. However, WSRC has proposed an alternative approach, and is planning to complete this training requirement in early 1995. g. The current staff of 78 Supervisors at the SRS were all Technician qualified before 1990 and are, therefore, a product of training and qualification standards that are considered well below current technical training and qualification standards. Although Topic Training may have reduced the gap between incumbent and current standards, it is questionable that this current generation of Supervisors' depth of knowledge in technical matters can be expected to exceed that of Technician qualified after 1990. This uncertainty is likely to persist since Supervisors were not subjected to a comprehensive written examination as part of the "compensatory" training (i.e., Topic Training) nor is a comprehensive written examination a requirement for future Supervisor biennial requalification. h. SRS management has taken the initiative to develop and implement their own training in select "Other Radiological Training" and "Training for Special Application" areas, while standardized versions of the training material for these articles are currently in various stages of development through DOE Headquarters. It is anticipated that curricula for selected topics will be in place by the summer 1994. Impacts of DOE's "Other Radiological Training" schedule changes are not known, nor are they considered in the scope of the site's implementation plan. i. Facility-specific radiation protection training programs are at various degrees of maturity. At the Replacement Tritium Facility (RTF), Supervisors are required to qualify to the same Tritium Specific Health Protection Qualification Standard that the Technicians are held to, while at the F-Canyon and FB-Line, the qualification requirements for Supervisors requires further definition and improvement. Neither F-Canyon and FB-Line have a specific qualification card for the Supervisor; the specific training for these individuals is not clearly defined; and there is confusion as to whether Supervisors will be required to maintain qualification as a Technician. In addition, neither F-Canyon or FB- Line have developed a drill program, or developed a continuing training program as required by DOE Order 5480.20, Personnel Selection, Qualification, Training, and Staffing Requirements at DOE Reactor and Non-Reactor Nuclear Facilities. j. Radiological control evolutions were observed in the field. Pre-job briefings were observed and varied in effectiveness, and in some cases were inadequate. The following highlights some of the poor work practices that were observed: a Technician wore her personal dosimetry inside the inner layer of protective clothing, a Technician frequently touched the protective clothing and touched the shoe of the operator during personal monitoring prior to exit of the Contamination Area, and the operator did not know either the radiation or contamination levels to be expected in the room or in the vicinity of the maintenance to be performed. The planned replacement of a flange Teflon gasket in a nitric acid line, with radiological implications, was observed. The work planning efforts for this evolution and the actions taken during an unexpected occurrence were not considered adequate. One of the more significant deficiencies noted was that although several supervisory level people were witnessing the actions being taken at the scene during an unexpected occurrence, none took charge or seemed to know what should be done. k. Two randomly selected training instructors were observed presenting a previously given student classroom session. One instructor demonstrated excellent classroom demeanor and was an accomplished instructor, while the other was much less effective. In addition, a field training coordinator was observed while conducting an On- the-Job Training (Training) session. The Training session was considered only minimally adequate, and failed to reinforce the previously learned material. Other source check operating procedures were not used and safety precautions associated with the potential radiation hazards, while using a source check device, were not emphasized. Subsequent to this demonstration, a similar evolution was observed in the field where an operator demonstrated disregard for safety precautions (e.g., although approved beta eye protection was present, the Technician did not wear the eye protection while conducting the check as required by the source check procedure). During the Training Session, it was revealed that the training group was creating its own technical procedures for Training since they had found the in-place procedures lacking. Review indicated that the On-the-JobTraining Guide (Guide) was more complete and accurate than the procedure (e.g., the procedure lacked an important technical note that was included in the Guide). A Training exercise covering a newly received source check device for an X-ray and gamma survey instrument was also observed as an evolution. In contrast to the training session discussed earlier, the instructor was very thorough and completed the Training in a professional manner. The trainee was very responsive. l. Interviews were conducted in group sessions of randomly chosen individuals that had received the following training and qualification: General Employee Radiological Training, Worker I and II; Technician; and Supervisor. The interviews were used to assess: individual attitudes towards radiological safety and practices, functional relationship among the four groups as well as with line management, and technical knowledge related to their past training and current job qualification. Without exception, interviewees expressed a positive attitude toward radiological safety as evidenced by responses to questions relative to procedure compliance, the need and appreciation for training, ALARA, and the individual worker's responsibility for ensuring radiological safety. Individuals demonstrated a clear understanding of the relational responsibilities and functional roles of trained personnel toward one another. This was particularly evidenced by Worker II and Technicians responses on each group's role regarding pre-job briefings, job-coverage, ALARA reviews, stop-work orders, and procedure compliance. Responses to technical questions demonstrated some weaknesses. This was particularly true for Technicians and Supervisors most of whom had only recently completed Topic Training. Technical questions focused on fundamental radiological topics covered in the Phase I Core Academic Training for Technicians. It is unclear whether this reflects a weakness in the classroom instructional approach or a lack of reinforcement of classroom acquired knowledge during training and job performance. . 5. Future Staff Actions: Staff actions are expected to include the following: a. Monitor radiological work practices at the SRS. b. Monitor the implementation of Supervisors training at the SRS. c. Monitor the implementation of additional standardized core courses at the SRS. ATTACHMENT (A) SAVANNAH RIVER SITE RADIATION PROTECTION TRAINING AND QUALIFICATION PROGRAM REVIEW MARCH 15 - 18, 1994 STAFF DISCUSSION AND OBSERVATIONS a. Training Organization, Responsibilities and Qualifications: 1. Organization and Responsibilities General Requirement DOE Order 5480.20, Personnel Selection, Qualification, Training, and Staffing Requirements at DOE Reactor and Non-Reactor Nuclear Facilities, (Chapter 1, Section 2) states that ". . . The operating contractor shall establish an organization(s) within the line-management organization that is responsible for the training of operating organization personnel." DOE Order 5480.11, Radiation Protection for Occupational Workers, (Sections 1 and 9.0) specifically identifies the following requirement for Radiological Control Training: ". . . This Order specifies the requirements for radiation safety training of (1) all employees who may enter a controlled area, (2) radiation workers, and (3) radiation protection technicians." Other References: DOE Order 5480.20, Section 7; and the DOE Radiological Control Manual , DOE/EH-0256T (RCM) Chapter 6. Description of How This Requirement is Met Line Management for the Westinghouse Savannah River Site Corporation (WSRC) is responsible for training of personnel at the Savannah River Site (SRS). Training responsibilities for line management are defined in training program procedures and in position job descriptions. Radiological Control Technician/First-Line Supervisor Training Responsibility for the training of about 480 Radiological Control Technicians (generally referred to as Radiological Control Inspectors (RCI) at the SRS) and about 80 Radiological Control First-Line Supervisors (FLS) is assumed by Training and Documentation whose Manager, Mr. C.W. Lewis, reports directly to the Radiological Control and Health Physics (RC & HP) Manager (see Attachment 1). Reporting to Mr. Lewis are two instructional groups consisting of 15 instructors, when fully staffed. The first group consists of a group leader and seven instructors, who provide classroom training, develop classroom instructional materials, and maintain course material and records. The second instructor group consists of a group leader and four field training coordinators, who are responsible for developing on-the-job (OJT) training materials, coordinating OJT training and evaluation (job performance measures, (JPM)). OJT field instructors are assisted by about 100 OJT trainers in the field. OJT trainers are either qualified RCIs or FLSs who have been selected by their supervisors on the basis of job performance, work experience, and leadership skills. Radiological Worker I & II The training of about 15,000 Radiological Workers (RW) I and II is the direct responsibility of Radiological Programs managed by Mr. M.D. Sanders, who reports to the Manager of the Environment, Safety, Health and Quality Assurance (ESH & QA) Training Department (see Attachment 1). Reporting to Mr. Sanders is a staff of 14 RW Training (RWT) instructors and a respiratory protection training instructor. A Training Support group is matrixes to RW and RCI/FLS training and provides various support functions. General Employee Radiological Training General Employee Radiological Training (GERT) is the responsibility of Site Training, which is managed by Mr. R.R. Tansky. Radiological training for about 20,000 site personnel is provided by a GERT training supervisor and four dedicated instructors. The various training groups are part of a matrix organization that share certain support groups and responsibilities and are governed by common policies and procedures (see Attachment 1). For example, the RCI/FLS Training organization reports directly to the RC & HP Department Manager. Training policy and procedure guidance are obtained through specific department procedures, procedures from ESH & QA Division Training, and through site-level policies and procedures form the WSRC Training Manual, 4B. Additionally, RCI Training receives some program support from ESH & QA Division Training in select areas of instruction, training program maintenance, and training records. The interfaces between the training organizations and line management are defined in RC & HP Department Administrative Procedure Manual Q1-2, 501 and 545. Facility-Specific Training Facility-specific training is provided by dedicated training personnel assigned to that facility. For example, the F-Area Training organization is responsible for the analysis, design, development, implementation, and evaluation of F-Area facility-specific training programs that are a component of the initial and continuing training programs for operators, supervisor, managers, technical staff and radiological control personnel that include RCIs (see Attachment 2). Site-specific training and qualifications applicable to RCI, include training related to H-3/Pu/U-specific monitoring, area surveys, instrumentation, emergency response, industrial safety and hygiene, and operating procedures. The training staff also has the flexibility to recruit subject-matter-experts (SME) for select training topics. SMEs have in the past been selected from among on-site personnel and hired from the outside as subcontractors or from vendor organizations. Functional Role of the Department of Energy - Savannah River The Department of Energy - Savannah River (DOE-SR) staff has comprehensive responsibilities for providing support and oversight to the radiological training programs. Included among the primary responsibilities are the evaluation management and/or monitoring of (1) the technical adequacy and implementation of radiological training programs, (2) individual and training program records, (3) instructor qualification program, and (4) the SRS Accreditation Program. DOE-SR also develops select training materials and serves as contacts for DOE interface with WSRC training personnel. 2. Qualification of Training Staff: General Requirements DOE Order 5480.20 establishes the selection, qualification, training, and staffing requirements for the training staff and ". . . encompasses those prescriptive requirements (education and experience, examination and certification requirements, program deficiency, requalification, etc.) contained in accepted industry standards where available (e.g., ANS N18.1-1971, ANS 3.1- 1981, ANS 3.1-1987, ANS 15.4-1988 and 10 CFR 55)." DOE RCM, Article 616.1, states that ". . . All instructors should be qualified in accordance with the Contractor's Site Instructor Qualification Program or possess equivalent qualifications." Standards for selection and qualification of the training staff are also defined in DOE/WSC 5Q Manual, Article 616, DOE/EH-0262T-1 and other various site/facility-specific documents. In summary, these standards specify that the training staff must possess both technical knowledge and experience and in the development and instructional skills required to fulfill their assigned duties. Description of How Requirements are Met Selection of Instructors The training staffs responsible for GERT, RW I & III, and RCI/FLS training meet and exceed the minimum required standards. The training organization has hired a majority of its personnel with past experience in the commercial nuclear power industry, U.S. Nuclear Navy, and/or Institute of Nuclear Power Operations (INPO). Some recent vacancies have been filled by experienced site personnel from the RC & HP Department who have qualified as RCIs. Other qualifications include the following: Among training personnel who are responsible for RW I and II training the manager, two group leaders, and all current classroom instructors for the RCI and FLS training program all have four-year degrees with two individuals possessing Masters' degrees. Additionally, five classroom instructors and one field training instructor are National Registry of Radiation Protection Technologist (NRRPT) registered. The manager and nine instructors have four-year degrees; and five instructors are NRRPT registered. Additionally, eleven instructors have commercial and/or U.S. Navy experience in radiological control training or radiological control operations. All current GERT Instructors have had a minimum of three years of WSRC employment prior to selection. Training and Qualification of Instructors Candidates selected for training instructors at the SRS are qualified in accordance with a formal program which provides instructional skill training and training material development. WSRC Training Manual 4B, 111 ("Instructor Training and Qualification") defines the requirements for skills needed to design/develop training materials and instructional/teaching skills. Initial training requirements for instructors include (1) Performance-Based Training (PBT) overview (4 hours); (2) Training Material Design and Development Skills (80 hours); and (3) Facility-Specific Training (if applicable). Managers/supervisors within the training organization are required to take the following two courses: "Performance-Based Training Overview;" and "Evaluating Instructors." The latter course is intended to assist the training manager and/or supervisor in the required evaluation of all instructors. For qualified instructors, continuing training requirements include a minimum of 24 hours of annual training. This instructor training may be presented jointly by Training Integration and/or Division Training or it may involve an outside training vendor. 3. Analysis: The training staff is generally well qualified with regard to educational and professional experience. WSRC has achieved this by selecting candidates with the necessary educational and professional experience and by providing sufficient instructor training and oversight as part of its instructor qualification program. As such, the training staff of instructors, supervisors (i.e., group leaders), and managers meet and exceed the minimum standards defined by DOE and industry accepted standards defined by ANSI, ASTM, INPO, etc. At this time, all training staff has participated and successfully completed (or have met the requirements of) the instructor qualification program. If there is minor weakness in the current staff of instructors, it is that only a small percentage have field experience at the SRS. Based on documentation review, personal observations, and discussions with training personnel, the training organization has developed a sound program that is structured upon the proven performance-based training concept. It is evident that individuals have worked hard and that substantial advances have been made in achieving a quality of training programs that rival those of the commercial nuclear industry. Based on current commitments involving initial, continuing, and/or requalification training of about 20,000 site-employees, 500 RCIs, and 80 FLSs, the current training staff may be overextended. This is particularly true for the training staff responsible for RCIs and FLS. This group is currently operating with two instructor vacancies. This group is also engaged in additional training program development which has reduced instructor classroom time to 30% or less. Training management indicated that although they were able to fulfill the classroom requirements there were insufficient people to meet the training requirements outside of the classroom. While the current staff may in future (i.e., under steady state conditions) be considered adequate, training under current conditions may be undermined/compromised by the current instructor work-load. b. Programmatic Overview of Radiation Protection Training: 1. General Employee Radiological Training Background and Discussion DOE/WSRC 5Q Radiological Control Manual (RCM), Article 621 requires that personnel who may routinely enter a controlled area and encounter radiological barriers, postings, and/or radioactive materials receive General Employee Radiological Training (GERT). At the SRS, GERT is incorporated into an eight- hour General Employee Training (GET) Program required under DOE Order 5480.20. GET training is required for all new WSRC site employees. GERT consumes about a 1-hour block of time and includes DOE standardized core course training materials as well as site-specific information such as alarm responses, WSRC polices, and radionuclide-specific information unique to SRS. Examination questions relating to GERT are limited to ten multiple choice questions of which the trainee must answer a minimum of eight questions correctly in order to pass. Following full classroom presentation of GET/GERT to new employees, individuals are required annually to attend Consolidated Annual Training (CAT). CAT consists of all topical areas included in GET but is designed primarily as a review and challenge test to verify knowledge of GET/GERT subject matter. WSRC has recently (December 20, 1993) developed a Student Handbook, which supports GET/GERT and is intended to serve as a permanent reference text and study guide for use by employees prior to taking the annual CAT. Analysis GERT at SRS is adequate and meets DOE requirements. The Student Handbook serves a valuable purpose both as a study guide and a shelf-reference text. 2. Radiological Worker I and II Training: Background and Discussion A formalized Radiological Worker (RW) training program was first introduced in February 1990 in accordance with DOE Order 5480.11. The current RW training program is founded on the WSRC 5Q Manual, Articles 612, 613, 631, 632, and 633. An integral part of the current RW training is the DOE standardized core course material, which is supplemented by site-specific training inclusive of topic training related to Pu, U, and H-3 facilities. Training materials (i.e., lesson plans, study guides, training aids, OJT guides, and examinations) are developed and approved in accordance with DOE/WSRC 5Q RCM, Article 613.5 and with WSRC 4B, procedure 203. Furthermore, all RW training materials (other than DOE standardized core training) require concurrence with Radiological Control Operations line management. Radiological Worker I Training For RW I, training is provided in the form of core course material, site- specific instruction and practical factors in a 16-hour block of time. RW I trainees are tested by means of a written examination consisting of 25 questions and practical factors evaluation. Successful completion requires an 80% score on the written examination and practical factors. The RW I full presentation course is designed for the worker who has never been subjected to work in a low- level radiological environment and who requires instructional assistance in a classroom environment. The course centers around clearly stated learning objectives that adequately cover fundamentals in radiological protection. Of the approximate 15,000 RWs at SRS, about 700 are RW I trained workers. RW I trained workers must requalify biennially by means of a refresher training module that includes a video tape and associated brochure. For the more experienced worker or professional employee, a 4-hour self-study program has been developed which may substitute for the initial 16-hour full presentation RW I format. Individuals who elect this option are subject to an 80 question written exam and practical factors evaluation. The RW I self-study course is designed for the individual who does not require a classroom environment and instructor's assistance and whose background allows for a more rapid assimilation of required knowledge. Radiological Worker II For new SRS workers required to have RW II, a 32-hour full presentation training program has been developed. RW II training is more rigorous than RW I training and is required for entry into (1) high (>100 mr/hr fields) or very high (>500 mr/hr fields) radiation areas, (2) contamination areas, and (3) airborne contamination areas. Currently, SRS has about 14,000 RW II trained workers. RW II trainees must qualify by passing a 50-question written exam and a practical factors evaluation with a minimum 80% proficiency for each. Requalification for RW II is biennial; in the "off year" when training is not required, the individual is required to complete "Refresher Training." As in the case of the RW I training, WSRC provides a substitute for the full presentation RW II program in the form of a 4-hour self-study RW II course. This course is aimed at the new SRS worker who does not require the instructor assisted classroom environment as well as the RW II qualified worker who requires biennial retraining. In order to demonstrate an acceptable level of understanding, the RW II self-study program requires the individual to pass a 125-question written examination with a minimum passing score of 80%. Students in the RW II self-study course must also complete a practical factors evaluation that is based on the identical learning objectives presented in the full RW II presentation. Evaluation of RW I and II Training Evaluation of RW I and II training is based on a multi-tiered approach that includes (1) evaluation of trainees, (2) instructor evaluation, (3) course evaluation, and (4) post-training evaluation. Trainee Evaluation. Written examination require a passing grade of 80%. Questions are selected from a question bank of more than 1200 questions most of which are multiple choice. Questions with a more than 20% failure rate are evaluated for appropriateness against learning objectives and other criteria. The number of examination questions for RW I and II differ between full presentation and self-study as previously noted. - RW I Full presentation: 25 questions. Self-Study: 80 questions. - RW II Full presentation: 50 questions. Self-Study: 125 questions. Instructor Evaluation. Instructors are evaluated by their supervisors as part of their instructor qualification as per WSRC 4B-111 and 204, "Instructor Training and Qualification." Radiological Control Operations (RCO) line management also participates in unannounced classroom observation and evaluation of RW training. Course Evaluation. A general course evaluation is conducted at the end of each course. Included in this evaluation are survey forms completed by trainees. Survey information is reviewed by the training staff and, when deemed appropriate, is used to improve training materials, training aids, and/or instructional presentation. Post-Training Evaluation. The effectiveness of RW training is evaluated at 6-month intervals. The evaluation consists of testing randomly selected trained workers who are subjected to questions derived from learning objectives previously covered during training. Workers are also subjected to field observations by the instructor staff and line management. (see Attachment 3). Observations of radiological work practices in the field, conducted by members of the WSRC training department responsible for radiological worker training, indicated a disconnect between what is taught in the classroom and that which is actually practiced in the field at the facilities. For example, an observation of radiological work practices in the H-Canyon facility in January 1994 noted numerous work practice violations. Analysis The current RW I and II training programs contain the essential elements for preparing workers assigned to radiological work environments. Current programs also meet the established criteria of DOE Order 5480.11 and the DOE/WSRC 5Q RCM. However, based on post-training evaluation (PET) results, there appears to be a problem among worker's retention of knowledge (see Attachment 3) and field application of acquired skills (see Attachment 4). RW post-training evaluations conducted at three discrete time intervals, show excessive failure rates relating to specific questions. (Recall that written exam questions with a failure rate greater than 20% during trainee qualification training are scrutinized for appropriateness leading to corrective actions.) A failure rate in excess of 20% may, therefore, be interpreted as a deficiency in long-term retention and reflect an inadequate emphasis of certain training topics and/or an excessive time interval between requalification training. WSRC management was noted as making a concerted effort to reduce the number of individuals requiring radiological worker training. 3. Radiological Control Inspector Training and Qualification Program: Background and Discussion Requirements The primary basis for the WSRC Radiological Controls Inspector (RCI) Training Program is the DOE RCM. Other requirements specific to RCI training include: DOE Order 5480.20, DOE Order 5480.11, and DOE Order 5480.18A, Accreditation of Performance-Based Training for Category A Reactors and Nuclear Facilities,. WSRC has created a site-specific DOE/WSRC 5Q, RCM, 5Q. Other documents that specify RCI training requirements/program elements are DOE/EH-0262T-1; DOE/EH- 0262T-2; DOE/EH-0262T-3; DOE/EH-0262T-4; DOE/EH-0262T-5; DOE/EH-0262T-6; DOE/EH- 0262T-8; and WSRC Training Manual, 4B. The RCI training program ensures that qualified individuals are trained to the performance requirements of the job by using a systematic approach to training. Three functional positions are defined that correspond to specific phases of training/qualification: RCI Trainee, RCI Assistant, and RCI. Selection of Radiological Control Inspector Trainees Selection criteria into the RCI training program are based on DOE Order 5480.20, DOE/WSRC 5Q, RCM, Article 642.4, and DOE/EH-0262T-1, which specify minimum educational, technical, and work-related experience. At the SRS, candidates are subject to an initial screening process as part of the selection process. Screening criteria for both new-hires and transfers from other DOE facilities have been established at the WSRC by joint agreement among Human Resources (HR), RCO, and Radiological Controls (RC) Training. These requirements are documented in the Site Fundamentals Program and RC & HP Department Administrative Procedures Manual Q1-1, 501, "Radiological Control Inspector Training Program." Resumes, including grade transcripts, are reviewed by the RCO for acceptability prior to administration of a written test battery developed by HR. The purpose of the test battery is to determine if applicant's level of ability in the areas of reading comprehension, arithmetic skills, and decision-making aptitude provide a reasonable level of confidence that applicant possesses the necessary qualifications to complete the RCI initial training and qualification program. Applicants who pass written examinations are subject to further screening by interviews conducted by trained HR and RC personnel. Trainee Mode of Progression An individual entering the RCI Training Program is classified as an RCI Trainee. To advance to the Assistant RCI, the trainee must complete Phase I classroom training and Phase I OJT as well as a time-in-grade requirement of approximately 12 months (see Attachment 5) The Assistant RCI must next complete all Phase II classroom training and Phase II OJT, which is followed by a comprehensive written exam, and an oral examination board. The time-in-grade for the Assistant RCI is approximately 24 months. The successful completion of all these requirements qualifies the individual as an RCI. At this time, the individual is enrolled in a biennial requalification program that includes continuing training. Programmatic Responsibilities Responsibilities for training associated with the RCI training program are defined in RC & HP Department Administrative Procedures Manual Q1-1, 201, "Health Protection Mission and Responsibilities." The RC & HP charter states that the department is responsible and accountable for ensuring the content and conduct of the Radiological Control and Radiation Worker Training Programs. The training manager and instructor/developer responsibilities for implementing and delivering training are described in the RC & HP Department Administrative Procedures Manual Q1-1, 500 series procedures. These procedures define the responsibilities for the design of the training program; writing objectives, test items, and lesson plans; conduct of classroom training; course evaluation; and development, review, administration, and control of examinations. Radiological Control Inspector Initial Training Program Prerequisites to the RCI initial training program are completion of General Employee Training, Radiological Worker II Training, Respiratory Protection training, and applicable portions of the WSRC core fundamentals training program. The RCI Initial Training Program contains two major elements, Phase I and Phase II. Phase I consists of a 10-week block of classroom training that covers fundamental topics in basic sciences, health physics theory, and radiological protection. Instructional material for Phase I classroom training is defined by DOE standard core course material. Classroom training for RCI trainees is followed by Phase I OJT. Phase I OJT is based on the completion of 30 OJT Guides of which the first 18 are generic (i.e., all WSRC facilities) and 12 are facility-specific (see Attachment 6). After successful completion of Phase I classroom instruction and OJT, the newly qualified RCI Trainee may provide a limited number of job functions for which the individual is qualified during his/her remaining stand-in-grade requirement. After one year, the individual is eligible for position upgrade to Assistant RCI and commences with Phase II training. The purpose of Phase II training is to build upon classroom knowledge and skills acquired in Phase I and to develop knowledge and skills considered advanced as well as unique and essential to a specific SRS facility. Phase II begins with a 3-week block of classroom instruction, practical exercises, and area specifics. Classroom training contains a generic component and a facility-specific component, which is determined by the individual's assigned duty station. A 3- to 4-week Phase II OJT period normally follows the classroom instruction and focuses on advanced tasks and facility-specific tasks (see Attachment 7). Subsequent to completion of Phase II classroom and applicable Phase II OJT Guides, Assistant RCI may provide coverage and fulfill most of the duties of an RCI. The time-in-grade for the Assistant RCI is approximately 24 months during which the individual must take a comprehensive written examination and an oral examination board. The purpose of the oral board is to verify that the individual has been able to integrate the knowledge and skills previously learned in a functional way that ensures the individual's ability to meet job duties. Position qualification as an RCI is approved following an evaluation of all above-cited training and qualification requirements and is limited to one of the four functional areas for which the individual was trained. The four areas are: Reactors; Nuclear Material Processing Division (NMPD) / High Level Waste (HLW) / Solid Waste and Environmental Restoration (SWER); Replacement Tritium Facility (RTF)-Tritium; and Savannah River Technology Center (SRTC) / Site Support. A transfer to another area requires the completion of area-specific classroom and OJT Guides unique to that area. Facility-specific RCI training relating to Articles 661 (Plutonium Facilities), 662 (Uranium Facilities), 663 (Tritium Facilities) is currently awaiting development of training modules by DOE-SR. Incumbent Training and Historical Overview of Program Development Guidance for training content of RCI prior to the DOE RCM was provided by DOE Order 5480.11 (see Attachment 8). Under DOE Order 5480.11, initial training materials were based on a Job Task Analysis (JTA) developed by a subcontractor to Westinghouse and implemented for the first time in 1990. In compliance with DOE Order 5480.11, all classroom training for RCI initial training was initially presented (i.e., 1991) in one (uninterrupted) 14-week session. Classroom instruction included math and science review, health physics fundamentals, topics in radiation protection, administrative processes, and site-/facility- specific instructions. Upon completion of 14 weeks of classroom instructions, trainees began OJT. In the following year, 1992, training under DOE Order 5480.11 was modified by segregating training into two phases each containing a segment of classroom training followed by OJT. Phase I contained introductory classroom instruction along with generic OJT. Phase II classroom instruction addressed more advanced topics, which was followed by Phase II OJT consisting of area-specific tasks. A total of 175 individuals completed RCI initial training between 1990 and 1993. With the issuance of DOE RCM, the RCI tasks were reevaluated. For generic tasks, a Job Task Analysis (JTA) was completed in 1992 and resulted in the development of DOE standardized core training courses. A facility-specific JTA was subsequently completed in 1993. Generic JTA identified 253 tasks performed by RCI, which are grouped into 15 duty areas. As of March 15, 1994, a total of 24 individuals has completed Phase I training of the current RCI initial training. A comparison of the current training program to the former training elements defined by DOE Order 5480.11 is provided in Attachment 9. Although the RCI initial training, as defined by DOE Order 5480.11, has been modified to meet compliance with DOE RCM, these two programs were judged comparable. Thus, individuals who successfully completed RCI initial training in 1991 and 1992 are judged to be on par with current requirements. RCI who had been qualified prior to 1990 were known to have been trained under several different programs. As a result of systematic review of available training records for all current RCIs, individuals were placed in one of the following groups (see Attachment 10): Group 1: trained after January 1990 Group 2: trained between 1986-1990 Group 3: trained between 1977-1985 Group 4: trained between 1960-1977 Group 5: trained before 1960 The training programs for Groups 2, 3, 4, and 5 were compared to the current training content defined by Group 1. A conclusion was reached that the training topics in health physics fundamentals did not adequately match the current program content. A consequence to this conclusion was the development of a topic training program consisting of nine one-week training modules to be completed within a two-year period (see Attachment 11). The intent of Topic 1 through 9 training (Topic Training) is to have all pre-1990 incumbents (280 RCIs as well as 78 FLSs) trained to common standards in health physics fundamentals. Following completion of Topic Training, incumbents are entered into a biennial requalification program which is common to all qualified RCI, independent of qualification date. As of March 15, 1994, a total of 177 incumbent RCIs (and 67 incumbent FLSs) have completed Topic Training. Evaluation of the Radiological Control Inspector Training Evaluation of training at the SRS is achieved at two levels. The first or programmatic level deals with the training content, format, and delivery. The second level of evaluation is aimed at measuring the effectiveness of training on the individual's knowledge and job skills. Program Evaluation ESH & QA Administrative Procedures, Q1, 4B-205, ("Evaluation of Training Effectiveness") and the site-level procedure, WSRC Training Manual, 4B, 205, ("Evaluation of Training Effectiveness") and RC & HP Department Administrative Procedure Manual, Q1-1, 537, ("Post-Training Evaluation") provide general guidance for the conduct of training evaluation. Collectively, these documents define evaluation protocols that may be used to determine the adequacy of training and, if needed, the means to amend, delete, or modify training. The resolution of deficiencies and affected changes are tracked by the Radiological Control Training Change Action and Commitment Tracking System. Primary tools for training evaluation include the following: Internal Appraisals. The RC & HP Internal Appraisal Group conducts assessments of select training components (e.g., training materials, instructor qualification, training records, etc.) on a three-year cycle. Other groups that provide evaluation feedback include QA personnel, RC & HP line-management, the Training Advisory Committee, and the Training Review Committee. Feedback is also gleaned from the Change Action Tracking System and the Training Development Request System. Training Audits. RC & HP Procedure Manual Q1-1, 520, establishes criteria for evaluating instructors by their supervisor and others. Instructors are evaluated at least annually on the basis of instructional approach, lesson presentation, classroom management, and interpersonal skills, training aids, and knowledge level. RCO Observations and Field Surveillance. The RCO management surveillance program tasks RCO Facility Managers and FLSs with performing weekly facility tours for inspection and observation of work activities. The RCO management surveillance of field activities is in addition to the requirement of each RCO Facility Manager and FLS to perform at least one annual training evaluation involving classroom instruction or OJT. Criteria and guidance forms for line management in support of training observations and evaluation are contained in the Administrative Procedure Manual Q1-1, Procedure 501 (see Attachment 12). External Audits. Periodic audits are scheduled by the DOE-SR's Radiation Protection Branch and by the Office of Training. DOE-SR has multiple oversight and input functions that relate to training. Chief among them are its responsibility to (1) evaluate the technical adequacy and implementation of all radiological training programs by means of documentation review as well as surveillance, (2) assess the training instructor qualification program, and (3) manage the SRS training accreditation program. External audits may also be conducted by the DNFSB and others. End-of-Course Trainee Critiques. Standardized survey critique forms have recently been developed and made available to trainees for optional and anonymous use. Information is summarized and reviewed by the training staff and the Training Review Committee. Similar trainee critiques have been developed for OJT. Instructor Critiques. Post-training critiques are also requested to be submitted by instructors at end-of-course classroom training or OJT. Instructor critiques are also submitted to the Training Manager and RCO management for review/action. Survey of Training Graduates. Evaluation/testing of randomly selected former trainees has recently been initiated. These random surveys of previously trained individuals provides valuable information relating to retention of learned knowledge/skills and the frequency with which they are applied by trainees (see separate write-up). Evaluation of the Trainee The knowledge and job skills acquired by the trainee is assessed by means of periodic written examinations, a comprehensive written examination, job performance measures, oral boards, and field surveillance during time-in-grade as RCI Trainee and Assistant RCI. Collectively, this evaluation process determines if defined learning objectives have been met and the trainee is adequately prepared in performing the tasks and duties of a qualified RCI. Protocols for the development of written examinations, JPMs, and oral boards at the SRS are well established and proceduralized (i.e., RC & HP Department Administrative Procedures Manual, Q1-1, 539, "Development and Review of Examinations," and 540, "Administration and Control of Examinations"). Based on procedural requirements, individual examination questions are developed directly from learning objectives and are subject to review for content, validity, and appropriateness during lesson review/approval. Written examinations employ a computer software program that randomly selects an appropriate number of questions for each instructional topic from a question bank. Examinations vary in question composition, which adequately maintains test integrity. Examination banks are maintained on electronic medium and hard copy format under conditions of controlled access. For OJT, 100 percent of all learning objectives that are defined in OJT Guides are examined during JPMs. JPMs are constructed based on the guidance provided in site and facility procedures and must comply with the protocol defined in RC & HP Manual, Q1-1, 526, "Writing Job Performance Measures." JPMs may employ the techniques of "perform," "simulate," and/or "discuss" in testing the trainees's knowledge and skill. The final step for RCI qualification/requalification is the Oral Examination Boards. To date, oral boards have not been conducted but are currently under development and in various stages of completion. Milestones include the development of (1) reference learning objectives that are based on site- and facility-specific scenarios, (2) questions and answers corresponding to reference learning objectives, and (3) associated procedures/manuals for each question and answer. Procedural provisions are in place that adequately address trainee failure at all stages of RCI training and qualification and encompass remediation training and restricted duty assignments (when appropriate) of the trainee. Radiological Control Inspector Training Accreditation Requirements DOE Order 5480.18A establishes the requirement for the accreditation of a performance-based RCI training program that encompasses the following five elements: (1)Systematic analysis of the jobs to be performed; (2)Learning objectives derived from the analysis which describe desired performance after training; (3)Training design and implementation based on the learning objectives; (4)Evaluation of the trainee mastery of the objectives during training; and (5)Evaluation and revision of the training based on the performance of trained personnel in the job setting. DOE Order 5480.18A also identifies the following five major activities of the accreditation process leading to accreditation: (1)Initial Self-Evaluation Report (ISER) (2)Training Program Accreditation Plan (TRAP) (3)Contractor Self-Evaluation Report (CSER) (4)Accreditation Review Team Evaluation (5)Accreditation Board Decision. Guidance for the implementation of each of these major activities leading to accreditation are provided in DOE Training Accreditation Program (TAP) 1, 2, and 3 Manuals. The following highlights each program: ISER. As part of the Initial Self-Evaluation (ISER), a facility compares the current training program to the accreditation objectives and criteria contained in TAP Manual 1. Guidelines for the conduct of the self-evaluation are contained in the Training Program Support Manual, Tap 3. ISER identifies strengths and weaknesses of the facility's training and provides solutions and action plans for the problems identified. TRAP. The Training Program Accreditation Plan (TRAP) is based on the results of the initial self-evaluation in which the contractor determines the necessary improvements needed for program accreditation and identifies a realistic implementation schedule. CSER. Findings in the initial self-evaluation are formalized in the Contractor Self-Evaluation Report (CSER). The CSER must describe how the training program meets pertinent accreditation objectives and criteria. Detailed guidance on the content and format of the CSER is provided in TAP 3 Manual. When the Contractor Self-Evaluation Report is received by the Training Accreditation Program (TAP) Staff, an Accreditation Review Team is appointed that conducts an on-site evaluation. The Accreditation Review Team submits a Comprehensive Evaluation Report to TAP, which forms the basis for the Accrediting Board Decision. Milestones and Current Status for Radiological Control Inspector Training Accreditation The Initial Self-Evaluation Report (ISER) was submitted September 10, 1990. Findings and recommendations from the ISER were incorporated and implemented into training. The Training Program Accreditation Plan (TRAP) was submitted to DOE on March 28, 1991 and approved by DOE Headquarters April 13, 1992. A Pre- Accreditation Review Visit was conducted May 2-14, 1993. The Review Team consisted of six subcontract personnel from utilities and INPO who had experience with the accreditation of commercial nuclear power training programs. Taking into account findings of the Pre-Accreditation Review Visit, WSRC submitted its CSER to DOE-SR on August 7, 1993. For the purpose of validating the CSER, DOE-SR conducted a surveillance/review of RCI training program on September 29, 1993. Surveillance and review of the RCI Training and Qualification Program was based on requirements defined by applicable DOE Orders, DOE RCM, TAP 1, 2, and 3 Manuals, and other applicable criteria. Although six program deficiencies were noted in the Evaluation Report (issued November 4, 1993), the review summary described the RCI program as having "quality design" and "worthy of accreditation." In response to the six findings, WSRC revised and resubmitted its CSER on December 21, 1993. A final revision of the CSER was submitted on March 4, 1994. At the time of DNFSB's site visit (March 15-19, 1994), the CSER was in its final approval cycle by DOE- SR. Of the twenty accreditation action items that had been identified by the Subcontractor Review Team and DOE-SR and acknowledged in the final CSER, twelve have been completed as of March 15, 1994. For the remaining eight action items, resolution is either imminent or have due dates prior to January 1, 1995. Analysis Under the former Radiological Control Training Programs (pre-1990), incumbent training was not based on performance-based training and qualification standards. Pre-1990 training and qualification standards were less rigorous than those employed by the U.S. Navy or standards adopted by the commercial nuclear industry in the 1980's. Since 1990, RCI training and qualification has undergone major changes that have aligned DOE facility standards to industry standards. The major impetus to change was the (1) issuance of DOE Order 5480.11, DOE Order 5480.18A, DOE RCM, and other supporting documents, (2) a more qualified training staff, (3) higher selection standards of trainees, and (4) line management's commitment to training. The WSRC training organization consists of a qualified staff of degreed personnel with extensive experience in the commercial nuclear industry and/or U.S. Navy. Their past professional experience have enabled these individuals to effectively and efficiently implement the training and qualification currently specified by the DOE. Current selection criteria for RCI trainees at the SRS not only exceed minimum standards defined by DOE Order 5480.20, RCM 642.4, and DOE/EH-0262T-1, but go beyond those defined by ANSI 3.1 (1987), Selection, Qualification and Training of Personnel for Nuclear Power Plants, and INPO 87-008. An example of the more stringent selection criteria currently employed at SRS is that candidates have a Navy Nuclear background or be a high school graduate with successful completion of algebra, physics, and/or chemistry courses at the first-year college level. The RCO organization is responsible for radiological training programs and line management's commitment to training is evident at various levels of training. By means of a Training Review Committee (TRC), the RCO line management has taken an active role in the content, modification and implementation of training. The TRC consists of the RC & HP Department manager, select members of line management, and training staff. Its responsibilities include identifying strengths and weaknesses related to training programs, review and approval of site-specific classroom lesson materials and OJT Guides, recommendation of corrective actions to noted deficiencies, and reviewing training accreditation and evaluation reports. The TRC has operated under the official charter of the RC & HP Department Procedure Manual Q1-1 since August 1993. Another recent example of line management involvement in training is their documented classroom surveillance of Topic Training as well as practical exercises. The DOE Implementation Plan commitment for DNFSB Recommendation 91-6 to have completed standardized core training for RCI's by December 1994 is not expected to be met. However, WSRC has proposed an alternative approach, and is planning to complete this training requirement in early 1995. In summary, the current RCI Training and Qualification Program is a sound program that meets DOE and industry standards. This is evidenced by the fact that the program has successfully achieved major milestones towards program accreditation. Several potential weaknesses, however, were noted and include the following: Training Staff. Based on current commitments to present training, to training program development, and to achieve accreditation, the current instructor staff may be inadequate. Training Laboratory. There is no laboratory facility that is exclusively available for training purposes. An off-site training laboratory can be expected to enhance instructions and practical factors related to the operation and use of radiological instrumentation, sample, counting/analysis, and demonstration of counting statistics. Although OJT currently addresses these specific skills, there is a need for providing this training in a more structured and controlled environment. Incumbent Qualification. An attempt has been made to raise the knowledge level of pre-1990 RCI incumbents to current standards by means of Topic Training. Topic Training was supposedly based on a systematic evaluation of pre-1990 training programs to the current program. It is uncertain, however, whether training documentation and records from the 1960's, 1970's, or even 1980's were sufficiently detailed and/or complete to allow such an objective evaluation. This impression was supported by comments supplied by incumbents interviewed and by their response to technical questions posed during the interview. Additionally, initial qualification of these incumbents did not include a comprehensive written examination or an oral board. The incumbent's first encounter with these two qualification requirements will only come as part of their biennial RCI requalification. The significance of this concern is highlighted by the fact that about 280 of the current staff of 480 RCI are pre- 1990 incumbents. Line Management. The role of line management in training-related matters is adequately proceduralized and documented. For review and approval of training materials, and for classroom audits and field surveillance, line management, however, must possess the necessary technical knowledge and familiarity with performance-based training process/accreditation. It is uncertain whether line management engaged in these activities is sufficiently qualified to assume these responsibilities in a meaningful way (see Attachment 12). 4. Radiological Control Inspector's First-Line Supervisor Training & Qualification: The FLS is responsible for oversight of RCIs assigned to them in their performance of assigned job duties. Supervisory oversight includes (1) technical guidance for all radiological functions and duties assigned to RCIs, (2) evaluation of radiological control tasks, (3) assignment and scheduling of radiological control tasks, (4) administrative duties, (5) resolution of problems that are technical in nature or relate to worker conflicts, and (6) provide interface between radiological controls and craft workers, line- supervisors/managers, and technical staff. Currently there are 78 FLS at the SRS all of whom qualified" prior to 1990 and before DOE Order 5480.11 criteria for RCIs were implemented at SRS. The DOE RCM lacks specificity in the certification requirements for Radiological Control Supervisors, and WSRC has not clearly defined what this certification entails. Currently, there is no formal training for supervisors in radiological controls beyond that received by technicians, and the technical training required for supervisors is not greater than that required for technicians. However, FLS training and qualification is being upgraded, and some of these discrepancies may be eliminated. The new requirements for Radiological Control FLS are defined in DOE/WSRC 5Q Manual, Article 644. Key qualification elements stated in Article 644 are that 1) ". . . Health Protection Operations Supervisors shall have qualified as Health Protection Inspectors" and that 2) ". . . The Health Protection Operations Supervisor's depth of knowledge should exceed that expected of a Health Protection Inspector." In order to meet the first requirement, all FLS were required to attend Topic Training that would assure parity with RCIs who qualified after 1990. In addition, credit for RCI practical factor training has been given for FLSs who have accomplished what is considered equivalent training, titled "Deliberate Operations Training." To meet the second requirement, a job analysis for FLS was performed and completed in July of 1993. This FLS job analysis identified a total of 128 tasks which were subsequently categorized into six duty areas. Based on the FLS job analysis, a training program consisting of technical course and supervisory skill courses is currently under development by RCO training staff and Human Resources training staff, respectively. The FLS technical training will be divided into the following six general categories of core courses (see Attachment 13): Orientation (2 hours) - Material presented will give an overview of duties, responsibilities, position requirements, and training requirements for the FLS. Math Review (2-4 hours) - Training will address skills used by FLS to review and validate survey measurements, calculating release rates, and activity concentrations. ALARA Coordinator (8 hours) - This existing course has been developed for coordinators throughout the site and addresses the application and use of procedures pertaining to Radiation Work Permit (RWP)/ALARA review process (currently 62 out of the 78 FLSs have completed this training). Work Coverage (16-24 hours) - This training module will address surveillance activities, good work practices, and contamination control through classroom review, mock exercises, and field surveillance exercises. Abnormal Incidents (16-24 hours) - Training topics include response to alarms, personnel decontamination, and drill activities. Administration - This is primarily a self-study course with some classroom review. Study topics will address administrative duties related to RWP development, radiological surveys, source checks, procedure revisions, etc. Radiological control supervisory skill training courses are currently being developed and will be taught by Human Resources training staff (see Attachment 14). A core course program of six courses is required of all FLSs within 18 months of promotion to FLS. The current staff of 78 incumbent FLSs have 36 months to complete core courses. FLSs will also receive on-the-job training that is facility-specific by qualified OJT trainer/evaluators. The training material for this portion of the training will be identified and approved by the Training Advisory Committee (TAC) and the Training Review Committee (TRC). Qualification/Evaluation of FLS Written examinations, requiring a passing score of 80%, are administered for each classroom training module. For OJT, practical examination of JPMs are conducted by OJT evaluators. JPMs are based on knowledge, practical learning objectives, and performance standards defined in OJT Guides. A final qualification step for the FLS is an oral examination before a three-member board consisting of RC & HP facility line-management. Oral boards will comply with guidelines set forth in DOE/WSRC 5Q Manual, Article 615 and DOE/EH-0262T-8. The first oral boards are expected to take place in the fall of 1994 with all FLS (and RCIs) completing their boards by summer of 1996. A special note about this process is that FLSs are not required to take a comprehensive written examination as part of their final qualification process. FLSs are required to requalify every two years, concluding with an oral board. At this time, a training program for requalifying FLS has not been firmly established but will likely draw upon RCI continuing training material and FLS- specific topics such as the elective courses on supervisory skill offered by Human Resources training staff. FLS Continuing Training Continuing training for FLSs is addressed in DOE/WSRC 5Q Manual, Article 644, and described in RC & HP Manual Q1-1, Procedure Q1-1. This program is intended to maintain and enhance technical proficiency, broaden the supervisor's understanding of his/her job duties, and prepare for biennial requalification. Continuing training in part, therefore, includes some review/retraining of HP fundamentals and job skills. Technical training topics to be covered during continuing training of FLSs (and RCIs) include the following: select topics in RC & HP fundamentals select OJT Guides pertaining to observed operational deficiencies new/revised procedures new (modifications to) equipment and instrumentation lessons learned from facility and/or industry experiences. All qualified FLSs should complete a minimum of 40 hours of technical continuing training and 20 hours of supervisory skills continuing training per year (see elective courses offered by Human Resources in Attachment 14). First-Line Supervisor Training Program Evaluation The approach and methods used to evaluate the effectiveness of training and qualification of FLSs are nearly identical to those previously described for the evaluation of the RCI program. In summary, the major elements for the programmatic evaluation of FLS training and qualification include: FLS trainee examination scores FLS oral board examination results observation of individual FLS job performance the collective performance reflected by Facility-Site Performance Indicators incumbent feedback evaluation critiques RC & HP line-management evaluation internal and external audits of classroom instruction evaluations and critiques provided by the Training Review Committee and the Training Advisory Committee. Analysis At the SRS, the current staff of 78 FLS were all RCI qualified before 1990 and are, therefore, a product of training and qualification standards that are considered well below current RCI training and qualification standards. Although Topic Training may have reduced the gap between incumbent and current standards, it is questionable that this generation of FLSs' depth of knowledge in technical matters can be expected to exceed that of RC Inspectors qualified after 1990. This uncertainty is likely to persist since FLS were not subjected to a comprehensive written examination as part of the "compensatory" training (i.e., Topic Training) nor is a comprehensive written examination a requirement for future FLS biennial requalification. 5. Other Radiation Protection Training: Other Radiological Control Standardized Core Training Radiological Control standardized core training courses for the RCM, Chapter 6, Part 5, Other Radiological Training, and Part 6, Training for Special Applications were described by the DOE in June 1993. DOE provided the current development status, including milestones for the development, use, and implementation. During the review, the SRS's involvement with this training was discussed. The basis for this discussion were the RCM requirements, and information on the status of this training that was presented at the March 1994 Radiological Control Committee Meeting. In general, the coordination and integration of this training in the complex appears to be less than efficient. However, the SRS approach may result in accomplishing some training before standardized core training materials are made available by DOE. The following highlights the issues: SRS management has taken the initiative to develop and implement their own training in select "Other Radiological Training" and "Training for Special Application" areas, while standardized versions of the training material for these articles are currently in various stages of development through DOE Headquarters. WSRC has developed training programs to fulfill the requirements of the Radiological Control Manual, Chapter 6, Article 622, Radiological Orientation for Visitors, and Part 5, Other Radiological Training, Articles 654 (1 of 5 parts) and 657, and Part 6, Training for Special Applications, Articles 661, 662, and 663. WSRC was directed in June 1993, by DOE-SR to develop, and is developing the curriculum for Specialized Radiological Worker Training (Article 634), Management Training (Article 651), for Technical Support Personnel (Article 652), for Planners (Article 653), for Radiological Control Personnel (Article 654), for Radiographers and Radiation Generating Device Operators Article (655), and for Emergency Response Personnel (Article 656). It is anticipated that these curricula will be in place by the summer 1994. Impacts of DOE's "Other Radiological Training" schedule changes are not known, nor are they considered in the scope of the site's implementation plan. Although the SRS is making progress with this training, their efforts are not coordinated, and eventually, the DOE standardized core training course integration and implementation will be necessary. A review of the DOE status revealed that 2 courses are on schedule, 1 course has an improved schedule, 1 course is on schedule providing it receives continued support, 2 courses have schedule slips of 3 months, 1 course has a schedule slip of 6 months, 2 courses have a schedule slip of 9 months, and 12 courses have uncertain schedules because of delays or support requirements issues. A clear understanding of what DOE course material is to be provided, additional requirements needing for implementing, and when training is to be accomplished was not thoroughly apparent. In addition, from the discussion, it became evident that DOE's status of "implemented" for the DOE standardized core training may have various interpretations, and does not necessarily mean that all applicable personnel will have been trained by the date. Subcontractor Radiological Training and Qualification The RCM, Article 645 specifies the requirements for the knowledge and qualifications for Subcontracted Radiological Control Technicians. WSRC personnel explained that personnel are screened and training is conducted, however, detailed implementation procedures that define the process of how the Training Group would routinely and consistently satisfy the RCM requirements, such as "to verify appropriate knowledge level" has not been accomplished. 6. Facility Specific Radiation Protection Training Programs: F-Canyon and FB-Line Facility specific radiological control training and qualification programs were reviewed, and the following observations are provided: Both facilities have implemented successful programs to reduce the instances of personal contamination cases, and to reduce the amount of internal and external radiation exposure. Neither facility has developed a drill program. Drilling for radiological control related abnormal or emergency conditions is not routinely conducted in either facility. Neither facility has developed a continuing training program as required by DOE Order 5480.20. There appeared to be little understanding of the requirements and how to develop an effective program. Some random training sessions are conducted, but these appear to be of little value. These session were not coordinated with the central organization. The qualification requirements for FLS's at both facilities requires further definition and improvement. Neither facility has a specific qualification card for the FLS, the specific training for these individuals is not clearly defined and there is confusion as to whether FLS will be required to maintain qualification as an RCI. Replacement Tritium Facility (RTF) and Tritium Area specific radiological control training and qualification programs were reviewed, and the following observations are provided: The Compliance Assessment Process for the RCM, Part 6, Training for Special Applications, Article 663, Tritium Facilities was examined. Partial compliance was noted with the comment that the site is awaiting preparation of the DOE course materials for Tritium Facilities. Remaining actions schedule dates appeared to be coordinated with the DOE implementation date of May 31, 1994. Previous training developed and implemented at RTF and programming at the Tritium Facility were not cited; and the compensatory measures did not address interim actions taken, nor justify why no additional compensatory measures were necessary. Comments provided on a DOE RCM Compliance for WSRC (Chapter 6) dated March 16, 1994 did not address the total population of trainees that should receive the training. However, discussions with RTF Training personnel indicated that the workers at RTF received this type of training as part of their Facility-Access Training, and/or will be retrained by June 1994. FLSs at the RTF are required to qualify to the same Tritium Specific Health Protection Qualification Standard that the Health Protection Inspectors are held to. c. Observations of Evolutions and Tours: Radiological Control Field Observations at the FB-Line facility. A Sample Assay Room decontamination evolution was selected for observation. The evolution was cancelled during the pre-job briefing when a deficiency was noted in the procedure that required a modification. A second evolution, to observe the removal of a waste cut-out from a precipitator area, was selected. The work pre-job briefing for this evolution was conducted in the Operations Command Center. Seven people attended this briefing, in this small room, which required four people to stand. The briefing lacked formality and consisted mainly of quiet individual discussions. The evolution was cancelled shortly before the operators suited to enter the contamination area (CA) when one operator noted that the RWP did not allow a sufficient number of people in the CA to complete the evolution. The RWP had not been reviewed at the pre-job briefing, contrary to RCM, Article 324. This discrepancy had not been noted by any supervisor or the assigned RCI. The entry to and exit from a CA for the conduct of a maintenance action was observed. This evolution involved two people, an operator and an RCI and required entry into a CA with further entry through an airlock to conduct the maintenance action and subsequent exit from the outer contamination area. The following comments resulted from observations at the CA: The CA just outside the airlock had some loose trash on the floor covering, such as pieces of tape, a small wing nut and dirt. No effort was made to pick these items up prior to entry into the airlock. The RCI wore her personal dosimetry inside the inner layer of protective clothing, contrary to the RCM. When questioned, she knew the proper procedure. The RCI frequently touched the protective clothing and touched the shoe of the operator during personal monitoring prior to exit of the CA, contrary to the guidelines of RCM, Appendix 3D. The operator did not know either the radiation or contamination levels to be expected in the room or in the vicinity of the maintenance work. He indicated that he had read the RWP. The personal hand held survey instrument was encased in plastic. The RCI indicated that this was intended to prevent the spread of contamination. However, the plastic around the probe was ripped extensively and should have been replaced prior to entry into the CA. Another instrument, with an intact plastic wrapping, was located adjacent to the instrument used by the RCI. Upon completion of the evolution the RCI turned the personal hand held survey instrument off. The other instrument had been on during the entire evolution and was left on thereafter. When questioned, the RCI indicated that it was the practice of some of the RCI's to leave the instruments continuously energized following the daily source check. The Facility Manager indicated that this was not his policy. The corridor containing the CA is relatively narrow and serves as a main passageway for people. This corridor had several other CA's set up adjacent to airlock entries. The CA's had collected dirt, dust and loose materials and by their location impeded traffic. These CA's seem unnecessary since the design of the airlock is intended to provide an appropriate area prior to entry into or exit from a given space/room. Radiological Buffer Areas or no areas seem more appropriate. Radiological Control Field Observations at the F-Canyon Facility: The Health Protection (HP) space in the F-Canyon Facility consists of four rooms. The entire space is a Radiological Controlled Area (RCA), and one room is a CA. The CA was messy, with extraneous material on a table, and such things as plastic shoe covers and a yellow plastic sheet adrift. The remaining rooms, within the RCA, were messy and contained much extraneous material, such as stacks of paper and notebooks not routinely used, and many items of a personal nature, such as coats, hats and shoes. An RCI was observed conducting a routine daily source check of a beta-gamma survey instrument. The RCI referred to the procedure while conducting the source check. However, the procedure used was a copy that had not been verified, contrary to the facility requirements. Although approved beta eye protection was present, the RCI did not wear the eye protection while conducting the check as required by the source check procedure. An OJT covering a newly received source check device for an X-ray and gamma survey instrument was observed as an evolution. The instructor was a qualified FLS and the trainee was a qualified RCI. The instructor was very thorough and completed the OJT in a professional manner. The trainee was very responsive. The planned replacement of a flange teflon gasket in a nitric acid line, with radiological implications, was observed. The maintenance effort was to be conducted inside a CA, set up in a broad corridor that permitted viewing from all sides outside of the CA. The work was to be done inside of a glove bag by two technicians. An RCI was in attendance inside the CA. Three individuals from the outside maintenance group were to observe the work from outside the CA. The work planning efforts for this evolution and the actions taken during an unexpected occurrence were not considered adequate. The following comments result from the observation of this evolution: The pre-job briefing was conducted in the corridor and led by the Maintenance Coordinator. The briefing was short, did not review any of the maintenance particulars, and did not discuss precautions or actions in the event of an acid leak. The liquid in the pipes was a 50% nitric acid solution. The briefing was not adequate for the planned maintenance. One maintenance technician wore his personal dosimetry inside his protective clothing instead of outside, as required by the instructions posted at the entrance to the CA. One technician had one instead of two pairs of rubber gloves on one hand. These errors were not noted by the RCI. None of the three people inside the CA wore any clothing to protect against an acid splash. None wore face protection and each wore only a single set of cotton coveralls. Although the CA provided adequate work space for the technicians, a temporary cardboard box that contained several hard hats was positioned near where they worked and interfered with their work and the movement of the RCI in the CA. This was not corrected until prompted. Shortly after a technician began loosening the bolts on one of the flanges a steady stream of dark brown liquid began leaking into the glove bag. One technician attempted to remove the liquid using a small hand pump, previously positioned for use to remove the small amount of liquid that had been expected to collect inside the glove bag. The pump could not keep up with the amount of liquid entering the glove bag. In a short period 2 to 3 gallons had entered the glove bag and the acid solution began leaking from the bottom of the glove bag onto the brown paper that was on the floor inside the CA. The amount of liquid coming from the loosened flange was significantly more than expected. There was no effort to immediately retighten the flange bolts when this unexpected event occurred.  Several cups of liquid leaked from the glove bag. The technicians moved several feet away from the glove bag and some of the acid was covered with soda ash. The RCI conducted a quick survey to measure for contamination. A level of 60,000 DPM beta-gamma was noted near the spilled acid. One technician was equipped with an air fed plastic hood and returned to the glove bag to retighten the flange bolts. The hose for the hood was run 10 to 15 feet outside of the CA and then back inside of the CA. It could have easily been run such that only about two feet was outside of the CA. The technician in the hood was given no assistance. The RCI was occupied surveying (frisking) the second technician out of the CA. Although several supervisory level people were witnessing the actions being taken at the scene, none took charge or seemed to know what should be done. The procedure covering the breaking of a line containing hazardous materials was not present at the work site. The maintenance coordinator indicated that none was required. A review of the line break procedures revealed that the operations procedure was a Category 1 work procedure required to be at the work site. The maintenance procedure for line breaks was not required to be at the work site. A review indicated that this procedure was not adequate for acid hazards. The use of acid solutions is extensive in this facility. Discussion with the Facility Maintenance Supervisor revealed a lack of knowledge of the work to be done and the potential hazards. For example, he thought that there was double valve protection on both sides of the flanges when in fact there was only single valve protection in each pipe on the downstream side. When this was noted, he still thought it not a problem even though there was a considerable run of vertical pipe, full of liquid, above the valve. He did not know what type of valve was in the pipe and whether it could be expected to leak from the head pressure. Further, he indicated that they had conducted work in glove bags on acid lines before without problems, but they could improve their techniques. In fact, the glove bag technique had been used for pipes containing up to a 4% acid solution, but this was the first time with a 50% acid solution. No study or review had been done for this case. The glove bag had been glued at the bottom. It appeared the acid solution had caused the glue to fail. WSRC management was noted as making a concerted effort towards reducing the number and size of contaminated and radiological controlled areas at site facilities. Significant progress was noted in the reduction of these areas in both the F-Canyon and FB-Line facilities. d. Training Demonstrations: Observation of Instructor Demonstrations. Two randomly selected training instructors were observed presenting a previously given student classroom session. One instructor presented material designed for RW II candidates. The other instructor presented a Health Physics Theory lesson from the initial core training course. The first instructor demonstrated excellent classroom demeanor and was an accomplished instructor. Her students would have significantly benefited from the session. The second instructor was not as accomplished. He did not orient the student to the written lesson material, his appearance was casual, answers to questions were not always clear and understandable, and he demonstrated confusion regarding the pulse height discrimination process in gas-filled detectors. Review of an OJT training exercise. A field training coordinator conducted an OJT training session for the reviewers on the operation of an X-ray and gamma survey instrument. The trainer referred only to the OJT Training Guide and did not refer to the instrument operating procedure. When questioned, she indicated that the training group was creating its own technical procedures for OJT since they had found the in-place procedures lacking. Review indicated that the OJT Guide was more complete and accurate than the procedure. Also, the procedure lacked an important technical note that was included in the OJT Guide. Operation of the instrument required a source check, which itself had an associated OJT. Supposedly the source check OJT was to have been completed by the trainee before the operational OJT. However, the instructor did not refer to the source check procedure when conducting a simulated source check with a training device to reemphasize the trainee's knowledge and to reenforce the importance of properly using operating procedures. In addition, she did not mention any of the safety precautions associated with the potential radiation hazards while using the instrument source check device. Subsequent to this demonstrationn, a similar evolution was observed in the field where an operator demonstrated disregard for safety precautions (e.g., although approved beta eye protection was present, the RCI did not wear the eye protection while conducting the check as required by the source check procedure). The instructor did not know why the OJT operator was required to allow the instrument to stabilize for one minute on the low scale. The session was considered minimally adequate. The instructor, as a field training coordinator, is also required to conduct field evaluations as part of her duties. She was not a qualified RCI, but had completed all of the classroom training for this qualification. The last three evaluations conducted by this individual were reviewed. The areas selected for evaluation were good, but no constructive criticisms had been noted. e. Interviews: Background Interviews were conducted in group sessions of randomly chosen individuals that had received the following training/qualification: GERT (2); RW II (4); RCI (4); and FLS (4). Each group was interviewed for approximately 45 minutes. Purpose The purpose of the interview was to assess (1) individual attitudes towards radiological safety and practices, (2) functional relationship among the four groups as well as with line management, and (3) technical knowledge related to their past training and current job qualification. Summary of Findings  All individuals interviewed were up-to-date in their training qualifications and met the minimum selection standards as defined by DOE Order 5480.20 and RCM, Article 642.4. (These standards are consistent with those defined by ANSI (ANSI 3.1 (1987)) and INPO (INPO 87-008).)  Without exception, interviewees expressed a positive attitude toward radiological safety as evidenced by responses to questions relative to procedure compliance, the need and appreciation for training, ALARA, and the individual worker's responsibility for ensuring radiological safety.  Individuals expressed a clear understanding of the relational responsibilities and functional roles of GERT/RW II/RCI/FLS trained personnel toward one another. This was particularly evidenced by RW II and RCI responses to each group's role regarding pre-job briefings, job-coverage, ALARA reviews, stop-work orders, and procedure compliance.  Responses to technical questions demonstrated some weaknesses. This was particularly true for RCIs and FLSs most of whom had only recently completed Topic Training. Technical questions focused on fundamental radiological topics covered in the Phase I Core Academic Training for radiological control technicians (i.e., RCIs). It is unclear whether this reflects a weakness in the classroom instructional approach or a lack of reinforcement of classroom acquired knowledge during OJT and job performance.  Consensus opinion among the RCI and FLS interviewees was that the most recent RCI trainees have a better (and unprecedented) technical understanding of radiological fundamentals and theory as demonstrated by their performance during the Phase I OJT. They attributed the higher performance of RCI trainees to the recently completed Phase I Core Academics and Site Academics training program.  None of the 4 RCIs and 4 FLS interviewed were NRRPT qualified or intended to become qualified. In their opinion, they felt no "sense of encouragement" by management or incentive to pursue NRRPT qualification as defined by RCM, Articles 642.5 and 642.6.