NRC INSPECTION MANUAL FCSS

 INSPECTION PROCEDURE 88010

TRAINING
Issue Date: 02/07/14 1 88010

88010-01 INSPECTION OBJECTIVES

To determine whether the licensee1is complying with regulations and license2requirements 

related to the implementation of a training program for licensee employees and other personnel.

88010-02 INSPECTION REQUIREMENTS AND GUIDANCE

02.01 Training Program. 

a. Inspection Requirements. Verify that any changes the licensee has made to the 

training program are in compliance with license requirements and regulatory 

requirements.

b. Inspection Guidance. Discuss the program with the training program manager or 

equivalent. Determine if any changes were recently made and verify that substantive 

changes were reviewed and approved by licensee management and are in compliance 

with requirements. 

Review changes to the licensee’s training program to determine whether the licensee has a

means of updating the facility's training program regarding identified changes in the plant. The 

recommendations may pertain to changes to items relied on for safety (IROFS) and/or changes 

to radiological safety, criticality safety, emergency preparedness, and operational safety 

programs. Determine if the licensee has included lessons learned from past events or mishaps 

into the program or individual training modules.

Determine if the following were addressed in updating the licensee’s training program:

1. A tracking system to ensure that each change was addressed on a timely basis. 

The inspector should cross-check with the features of the tracking system 

identified in the hazard identification and assessment element as applicable.

2. Management-approved recommendations from hazard identification and 

assessment, incident investigations, and/or audit programs, which identified 

deficiencies in the training program, were addressed in a timely manner to 

ensure that hazards at the facility were sufficiently addressed. The inspector 

should cross-check the training program elements with the incident investigation 

and/or audit results.

3. Training actions initiated by the Change Management process should be 

addressed before the change is implemented. Verify that all personnel affected 

by the change received updated training. Determine if this is captured by a

pre-startup safety checklist or other tool.

 

1

The term licensee as used in this Inspection Procedure (IP) also applies to certificate holders.

2

The term license as used in this IP also applies to certificates.
Issue Date: 02/07/14 2 88010

02.02 Procedures. 

a. Inspection Requirements. Verify that the licensee’s training program maintains 

established, written procedures as required by the license application.

b. Inspection Guidance. Review the licensee's training program to determine whether the 

licensee has established written procedures for the identification of training 

requirements and training material, selection and qualification of instructors, 

maintenance of employee training records, ensuring adequate frequency of refresher or 

requalification training, and contractor/visitor training.

Determine if the licensee maintains a training outline that defines requirements, material, and

testing.

1. Verify that in-house training programs for selected positions cover initial 

orientation, specific process training (both classroom and on-the-job), and 

refresher training. Procedures should be available for trainee evaluation and 

final qualification/certification.

2. Verify that training material addresses the following topics:

(a) IROFS, process safety information elements (such as safety and health 

hazards, relevant material safety data sheets [MSDSs], personal protective 

equipment, etc.);

(b) Safe work practices (such as lockout/tag out procedures, opening process 

equipment, hot work, control of entry into hazardous/radiological areas, 

etc.);

(c) Process technology, as required;

(d) Operating procedures for all phases of operation;

02.03 Program Implementation. 

a. Inspection Requirements. 

1. Determine that the licensee is in compliance with license requirements relating to 

the implementation of the training program.

2. Verify that training for administrative controls IROFS are implemented per Title 

10 of the Code of Federal Regulations (10 CFR) 70.62 (d) to ensure that IROFS 

are available and reliable. 

b. Inspection Guidance. Specific regulatory requirements related to the licensee’s training 

program will be contained in license conditions. 
Issue Date: 02/07/14 3 88010

1. Determine that the training program was implemented per the license conditions 

by discussing the program with staff and through reviewing relevant 

documentation. Verify that the training program includes radiological, fire, 

chemical and nuclear criticality safety content for operators.

(a) Verify documentation of training, evaluations, and 

qualification/certification activities for employees. Training records should 

be accessible and easily referenced. Information may include: name of 

employee, date of training, name of trainer, and the method used to 

determine that training material was understood.

(b) Verify that refresher training was provided at least every 2 years, or as 

specified in the license. Content of required material will be specified in 

the license application, if applicable, and may include the following: 

safety and health hazards, relevant MSDSs, job-specific chemical 

hazards, safe work practices, emergency procedures, and standard 

operating procedures. 

The inspector should interview trainers and/or trainees to determine that 

refresher training is conducted according to the schedule.

(c) Determine if general employee training is required by the license 

application. The training program for employees, contractors, and visitors 

should be appropriate given the hazards in the area in which they will be 

working or visiting. Every person who enters the facility should go 

through a site-specific general orientation covering safety and health 

hazards, emergency procedures, and alarms. In addition, maintenance 

employees and contractors, if relevant, should undergo training in safe 

work practices, process hazards, etc., as relevant to the work they will be 

performing.

(d) Review internal audits or self-assessments pertaining to the training 

program. Discuss the licensee’s evaluation of the overall effectiveness of 

the training program. Assess the sufficiency of the training program in 

addressing the radiological, fire, criticality safety, and chemical safety 

aspects of hazards that can affect operations with special nuclear 

material at the facility. The principal objective of the training program is to 

ensure that employees have been adequately prepared to perform their 

job tasks in a safe and effective manner.

Note: Content of the nuclear criticality course and professional training for criticality safety staff

is reviewed in IP 88015, ‘Nuclear Criticality Safety Program.’ Do not duplicate.

2. Review a list of training which represents or includes management measures for 

IROFS (i.e., administrative controls). Select a sample to review in detail.

(a) Discuss the training program with one or more supervisors and selected 

operators or technicians to determine their participation in the training 
Issue Date: 02/07/14 4 88010

program as indicated by training records. Verify the completion of initial 

training, periodic retraining, on-the-job training, and examinations of 

trainees. Determine if the operators or technicians independently worked 

in an area in which their training and qualification had expired or was not 

complete.

(b) Examine five or more records of initial training for new employees for a 

variety of positions. Include tests or exams in the review if tests are 

required by the program.

(c) Examine five or more records of retraining for experienced employees for 

a variety of positions. Include tests or exams in the review if tests are 

required by the program.

(d) Determine by discussion, document review, and observation that the 

training program ensures that each individual receives performance

based IROFS training. Verify the individual receives safety control 

training (knowledge and skills) to understand his or her personal and 

organizational authority and responsibility for safety. Interview trainees to 

verify that they understand shutdown authority when IROFS and/or safety 

controls are in doubt. Verify that both shutdown authority and restart 

authority were addressed in the procedures.

02.04 Training Observations. 

a. Inspection Requirements. Verify that training classes and/or teaching aids are 

conducted in accordance with license requirements and procedural requirements.

b. Inspection Guidance. Observe training with staff in a variety of positions, such as 

managers, supervisors, operators, maintenance mechanics, instrument and control 

technicians, etc. The training observations may include classroom training, on-the-job 

training, or one-on-one instruction. Discuss procedural expectations with these 

selected staff to determine whether the staff can effectively implement procedures. 

Discuss with the staff to determine whether they thought the training was adequate. 

Note: On-the-job training should, as a minimum, include: equipment familiarization, 

completing log sheets, equipment startup/shutdown activities, limiting operating 

conditions, control of process variables, and applying operating procedures in the 

field.

02.05 Changes in Examinations. 

a. Inspection Requirements. Verify that changes to training examinations, if applicable,

are in accordance with license requirements.

b. Inspection Guidance. Examine the changes to selected tests given under the training 

program to determine that tests required by the program were administered. Verify that 

the scores or results achieved satisfied program criteria.
Issue Date: 02/07/14 5 88010

88010-03 RESOURCE ESTIMATE

The resource estimate to perform this inspection procedure is estimated to be 16 hours. 

88010-04 REFERENCES

10 CFR 70.61, ‘Performance Requirements.’

10 CFR 70.62, ‘Safety Program and Integrated Safety Analysis.’

29 CFR 1910.119, Occupational Safety and Health Association, ‘Process Safety Management 

of Highly Hazardous Chemicals,’ (g) ‘Training.’

Center for Chemical Process Safety, ‘Guidelines for the Technical Management of Chemical 

Process Safety,’ Chapter 10, pp. 105-110, American Institute of Chemical Engineers, New York, 

dated 1989.

Chemical Manufacturers Association, ‘Process Safety Code of Management Practices,’

Practices 17, 18, 19, 20, Washington, dated 1990.

88010-05 PROCEDURE COMPLETION

Implementation of each applicable inspection requirement will constitute completion of this 

procedure. Individual inspection samples and breadth of review will be determined by the 

inspector based on requirement compliance, risk-significance of activity, and extent of the 

activity or records available.

END

Attachment:

 Revision History for IP 88010
Issue Date: 02/07/14 Att1-1 88010

Attachment 1 - Revision History for IP 88010

Commitment 

Tracking 

Number

Accession 

Number

Issue Date

Change Notice

Description of Change Description of 

Training 

Required and 

Completion 

Date

Comment 

Resolution 

Accession 

Number

N/A 09/05/06

CN 06-020

This document has been revised to: (1) 

emphasize the risk-informed, performancebased approach to inspection, (2) impose 

changes to the core inspection program 

based on operating experience, and (3) 

remove completed or obsolete IMCs and 

incorporate other fuel cycle IMCs into a 

central location. 

N/A ML061940176

N/A ML13233A178

02/07/14

CN 14-005

This document has been revised to: (1) 

remove inspection requirements pertaining to 

10 CFR 19.12 that are duplicated in IP 

88030, (2) reorganize and reword for clarity, 

and (3) reformat per IMC 40 guidance. 

N/A ML13347A908