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.