10 CFR 830, Subpart A, Quality Assurance Requirements

DOE-STD-1186-2004

The following training issues should be evaluated carefully for applicability to new SACs, and

existing SACs, as defined in this Standard.

Personnel Selection: The minimum qualification and experience requirements of the personnel

performing the task should be considered carefully when formulating, implementing, and

maintaining SACs. Some SACs may require operators with special knowledge, skills, or

physical abilities. In the combustible loading example previously noted, such a control will

require an individual with specialized knowledge and experience in assessing the fire hazards in

an area. Some controls rely on the ability of the operator to distinguish color differences, to

perform strenuous tasks, or gain access to relatively inaccessible areas. These specific factors

must be considered explicitly in the formulation, implementation, and maintenance of SACs.

Job Task Analysis: The formulation of SACs should include a thorough job task analysis (JTA).

A JTA will identify the required plant instrumentation, physical controls, operator skills and

abilities, and other important variables necessary to successfully perform the task. The JTA

should include or incorporate the appropriate human factors considerations in developing the

controls.

Initial Qualification Requirements: Depending on the results of the JTA, the operator training

and qualification requirements for tasks related to SACs should then be developed. The

training requirements should account for and disposition each important variable in the JTA,

hazard analysis, or other basis documents being used to develop the SAC. Many hazard and

accident analyses contain assumptions (both implicit as well as explicit) regarding the ability of

the operators to detect and respond to accident scenarios. It is important to identify clearly

these assumptions so that operators are specifically trained with respect to the SACs that are

credited in the analysis. The training program should identify explicitly the required training for

SACs. Additionally, consideration must be given to the development of formal written and

practical examination requirements for these ACs.

Continuing training requirements: In addition to formal, initial training requirements, the

knowledge and skills set for SACs should be considered for inclusion in a continuing training

program. This will ensure that the important training objectives for the controls are periodically

reinforced to plant operators, supervisors, and managers. Additionally, such learning objectives

should be considered in formal, periodic re-qualification programs.