IR 05000250/1989023
| ML17345A737 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 05/30/1989 |
| From: | Breslau B, Kellogg P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17345A736 | List: |
| References | |
| 50-250-89-23, 50-251-89-23, NUDOCS 8906200058 | |
| Download: ML17345A737 (30) | |
Text
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/ 0 sp p*y4 UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323 Report No.: 50-250/89-23 and 50-251/89-23 Licensee:
Florida Power and Light Company 9250 West Flagler Street Miami, Fl 33102 Docket NoeI 50-250 and 50-251 Facility Name:
Turkey Point 3 and
Inspection Conducted:
May 1-5, 1989 Inspectors:
8, Bres au, Team Leader, Region II Team Members:
License Nos.:
DRP-31 and DRP-41 ate Signed D. Lange, NRR G. Lapinsky, NRR T. Mazour, Consulting Assoc.
K. McCoy RR Approved by:
P.
Ke.
,
i.,
egion II Operational Progra s Section Divis-ion of Reactor Safety SUMMARY Date Signed Scope:
The licensed, non-licensed operator, and the licensed operator requalification accredited training programs were inspected.
The inspection focused on, (1)
how the tasks were analyzed, (2)
how training objectives were derived from the tasks, (3)
how training or the tasks was'esigned, developed, and implemented, (4)
how trainees were observed and evaluated during training to determine their level of task mastery, and (5)
how feedback on training, trainee evaluations, and on-the-job performance indicators are incorporated into revision and evaluation of the tra1ning programs.
This inspection did not address the unsatisfactory status of the operator license requalification program per NRC Inspection Report No.
OL-89-01 Results:
Although the documentation of the training programs is adequate, the inspection resulted in several areas of concern in program implementation and program evaluation.
These concerns are as follows:
The non-licensed operator training program is not providing an adequate number of personnel to the licensed operator training program to compensate for the attrition of licensed operators.
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Additionally, the program is allowing too many people to get to the end before eliminating those who are not able to pass the licensee audit exam.
The licensee examinations have not been effective in early identification of substandard trainee skills and knowledge, resulting in excessive attrition during contractor and NRC licensing examinations.
2.
There is no identified schedule for completing the update of the task analysis for new reactor operator tasks, or for revising training materials based on the results of this analysis, paragraph 2.a.
3.
5.
6.
7,
'While a systematic method was used to determine the content of the 1989/1990 licensed operator requalification cycle, this method is not described in any administrative procedures or guidelines, paragraph 2.a..
Training files lack the details to determine how instructor training requirements were met, also administrative instructions are vague concerning documentation of training requirements, paragraph 2.d.
The volume of material provided to students during requalification classes is excessive for the time period in which the students need to assimilate the material, paragraph 2.e.
Insufficient simulator training time has been provided for requalification training to ensure that licensed operators are proficient in responding to abnormal and emergency events.
In addition, for individuals who are not normally assigned on-shift, insufficient time manipulating simulator controls has been provided, paragraph 2.e.
and 2.f.
There are no instructions or procedures for 'examination development that provide direction to instructors concerning what sample of-learning objectives should be evaluated by examinations, paragraph 2.f.
8.
9.
Licensed operators were not adequately prepared for the types of examination methods used for requalification examinations, including open-reference written exams, JPMs, multiple casualty simulator operating tests, and static simulator operating tests, paragraph 2.f.
The sustained extensive work load which the licensee has experienced during the last six months coupled with the impact of added requalification training hours can lead to fatigue and stress.
The'icensee needs to address this issue.
10.
An area that was not explicitly addressed as part of the inspection but revealed through the inspection is the attrition rate of licensed operators.
Discussions with licensed operators and
supervisors indicated that some ROs were working 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> or more o
OT per year, with SROs averaging less (500-600 hours per year).
Inspection of licensee records revealed operators working 30-35 percent overtime, a rate that could lead to the number of hours reported by the operators.
Related to the extensive OT is the degree program for ROs/SROs.
The licensee is planning to implement this program in the near term by offering on-site courses on a
schedule that wi 11 support =attending courses while on shift work.
With the current amount of OT being worked it doesn't seem feasible that operators will have the additional time available to attend and
'repare for classes for the degree program.
Attrition may have an impact on training resources and is therefore an additional area of concer REPORT DETAILS Persons Contacted Licensee employees b'C.
Woody, Executive Vice President, FPSL 8*J. Arias,Jr.,
Technical Advisor to Plant Manager 0'*K. Beatty, Training Advisor to Plant Manager 8W. Bladow, Superintendent, guality Assurance b'*R. Broadnax, Training Administrative Supervisor 8D. Chancy, Director, Nuclear Licensing 5'*J. Cross, Plant Manager O'. Earl, Supervisor, guality Assurance
>*T. Finn, Superintendent, Training Department 8J. Hartzog; JUNO Licensing Engineer fD. Herrin, Senior Licensing Engineer 5'*G. Hollinger, Supervisor, Operations Training PG.
LaGarde, Emergency Planning Coordinator
- G. Madden, Supervisor, Nuclear Licensing
- A. Mueller, Recorder
.8J, Odom, Site Vice President
~*L, Pearce, Superintendent, Operations PJ.
Palchinsky, Staff Curriculum Specialist
- M. Shappard, Supervisor, Operations Training, St Lucie g~W. Waylett, Manager, Nuclear Training
~K. VanDyne, Supervisor, Regulatory Compliance Other Licensee employees contacted included instructors, engineers, technicians, operators, and office personnel.
<*P. McCullough NRC Representatives
- R. Butcher, Senior Resident Inspector f/T. McElhinney, Resident Inspector FJ.
Roe, Division Director, Licensing Performance 5 guality Evaluation,NRR 8S.
Shankman, Chief, Procedures 8 Training Section, Human Factors Assessment Branch, NRR
- Attended entrance interview PAttended exit interview Acronyms used throughout this report are listed in the last paragrap.
Licensed, Non-Licensed Operator Initial and Requalification Training (41701,41400)
This inspection was conducted using the guidance and checklists of NUREG-1220,
"Training Review Criteria and Procedures."
The following 10 tasks were selected by the inspection team for evaluation of licensed operator initial and requalification training.
Task Number Task Title 10030203000 10380083000 10410293000 10750023000 12000255000 14003016100 14016020300 14023015500 14092011300 24094001500 Respond to a loss of vital AC Respond to a fuel handling incident Evaluate and respond to low pressurizer pressure Control S/G level locally with AFW control valves Respond to a loss of emergency coolant recirculation capabi 1 i ty Transfer Vital Load Between.Inverters Respond to Spurious Activation of Fire/Isolation Dampers Recover From an EDG Auto Start Failure Backfeed Unit Auxiliary Transformer to Supply 4KV Busses (Generator Links Removed)
Place Post-Accident Hydrogen Monitor in Service In addition to reviewing all materials used in the analysis, design, development and evaluation of training related to these 10 tasks, the team also observed classroom, simulator and on-the-job training, and interviewed 21 individuals (licensed, non-licensed operators, trainees, instructors, supervisors, and managers).
a.
Systematic Analysis of Jobs To Be Performed All 10 of the tasks above, noted as being required by the licensee as either initial or continuing training, were selected from the licensee's Job Analysis Reports dated September 23, 1988,
"Non-Licensed Operations Positions ANPO, NPO, SNPO" and November 14, 1988,
"Reactor Control Operators."
This report was an update of the original job analysis done by the licensee for INPO accreditation in August 1986.
Administrative Guideline AG-014, describes the methodology required for conduct of job and task analysis for Turkey Point positions subject to INPO accreditation.
The team found these procedures to be comprehensive, and they also found that the procedures were being followed for the tasks selected for this inspection.
These procedures require use of the same measures (difficulty, importance, and frequency)
and the same five-point scales as were used by INPO for the industry-wide job analysis.
A combination of difficulty and importance are used to select or de-select tasks for initial training and subsequent task analysis.
The frequency measure is added to select tasks for continuing training (i.e., infrequently performed tasks, where frequency is not maintained through routine job performance were selected for continuing training).
The licensee's task analysis procedures and the completed task analyses for the tasks selected for this evaluation indicated that a
method had been used which identified the information needed for training program design and development, including task elements, conditions and standards, and related skills and knowledge.
The licensee now has in-place the TSAR process to identify and track needed changes in job and task analyses, and related training materials, based on new/revised job performance requirements resulting from such sources as:
procedure revisions, plant modifications, and plant or industry operating events/experience.
The process is documented in Administrative Guide AG-020.
A review of random items in the TSAR system indicated that it provides an effective method to identify and track needed changes in front-end analyses and training programs.
However, until recently the TSAR process was not used to identify and track needed changes in job and task analyses.
As a result the data from these analyses did not reflect current job performance requirements.
The paragraph below describes the efforts underway to rectify this condition.
The licensee's job analysis report above resulted in a realignment of tasks to be consistent with INPO's industry-wide job analysis.
This realignment resulted in 126
"new tasks" being identified.
The majority of these
"new tasks" were found to be a re-grouping, or re-statement of tasks identified and analyzed initially.
Discussions with the individuals responsible for this analysis indicated that approximately 30-percent of the
"new tasks" were in fact tasks that had not been previously analyzed.
These tasks that had not been previously analyzed were primarily identified through either the Procedures Upgrade Program or EOP development.
None of these tasks have yet been completely analyzed, although some are now in the review/validation process, and training materials have not yet been revised based on the results of this analysis.
While efforts are on-going in this area, there is no documented schedule indicating either when the analysis of these new tasks will be completed, or.when training materials will be revised based on the results of this analysis.
This area is considered as Inspector Fol low-up Item 250, 251/89-23-01 While a systematic method was used to determine the content of the 1989/1990 licensed operator requalification cycle, this method is not described in any administrative procedures or guidelines.
Development of Learning Objectives, Terminal learning objectives for both initial and requalification training were determined to exist for all
tasks selected for evaluation.
These learning objectives are included at the front of:
applicable lesson plans for classroom training, exercise control guides f'r simulator training, and modules/JPMs for OJT.
Enabling learning objectives were found for all 10 tasks, with one exception.
There were no enabling learning objectives in the fuel handling system lesson plan related to the task
"respond to a fuel handling incident."
Further review of the
'lesson plan indicated that both the fuel handling system description and the body of the lesson plan included information r'elated to fuel handling incidents.
However,
because Turkey Point Nuclear Plant Training Department and SAT guidelines. indicate that test items are to developed only from learning objectives, trainees would never be examined in this area during fuel handling systems training.
There were no such oversights found with respect to the tasks selected for non-licensed operator training, and based on only this single deficiency, the team judged this to be an isolated case.
Organi zat ional and Des i gn Structure The =Turkey Point Training Organization Manual and the Nuclear Training Center Training Plan jointly provide a fairly clear picture of the mission and structure of the Turkey Point Training Organization.
Goals and objectives are clearly identified.
Plans for accomplishing these goals and objectives are stated in general terms with speci fic impl ementati on (accountabil ities)
del ega ted to specific job positions within the organization.
For the most part, success criteria are defined in measurable terms, allowing for objective evaluation of the organization's effectiveness.
The team found evidence of on-going evaluation and revision of goals, objectives, and plans.
During the past year, Turkey Point has initiated quantitative goals for the training organization and has tracked the training program to monitor progress toward these goals.
These include:
I)
Increasing the number of FPL instructors holding SRO licenses to at least 805 by 1992; 2)
Maintaining at least 80% passing rate for each NRC initial license exam attempt; 3)
Maintaining at least 80% passing rate for each SRO upgrade exam attempt; 4)
Maintaining at least 90% first attempt passing rate for each NRC requalification exam; 5)
Maintaining at least 85% attendance rate for training courses.
Not all of these goals have been achieved.
Turkey Point management is aware of the shortfalls and has been directing changes in the organization e.g.,
changes in the content and sequencing of Non-licensed Operator Training to enchance the retention rate in the Non-licensed/Licensed Operator career path.
The Training Organization Manual clearly identifies responsibilities and authorities for all specific job positions within the training organization that are represented on its approved organization chart.
Personnel qualifications and training requirements are also addressed.
However, instructor qualifications and training requirements are vaguely stated, e.g.
hours of continuing training are required to retain qualification as an instructor, but the content of that training is undefined.
The team was concerned that this could lead to abuse because in the past training has
included tangentially related subjects such as computer languages.
Continuing training should be closely related to weaknesses identified during instructor evaluations.
The team also noted that evaluations of instructors'echnical competence have not been properly done.
This
. aspect of instructor qualification and competence is further clouded by negative feedback from trainees and incumbents regarding the competence of certain instructors to teach their subject areas or, indeed, to teach at all.
The instructor qualifications and training requirements in the Training Organization Manual and in Administrative Guideline, AG-001, Training Personnel Guidlines, January
1988, should be stated in specific and objective terms so that subjective judgment
.of qualification is minimized.
Requirements for training should be related to job/task elements and should be specifically defined.
Criteria for exemptions from training should also be specific and related to the knowledges, skills, and abilities needed to effectively accomplish the tasks'f an instructor.
Continuing training should be directly related to enhancing or remediating instructor knowledges and skills.
Selection of specific content for continuing training should be based in part on a valid evaluation of an instructor's technical competence and presentational skills.
AG-001 and AG-018, Evaluation Phase-SAT, October 12, 1988, should be revised to re lect the above concerns.
Relationships with other parts of the Turkey Point organization have become better defined over the past few years.
The relationship between operations and training appears to have improved somewhat since the rift that was identified by the licensee's independent management appraisal in late 1987.
However, training coritinues to suffer from credibility problems, primarily in the area of plant operations and systems training.
Although FP&L committed in its August 18, 1988 response to the IMA to staff the training organization with more FPEL employees, it has made virtually no progress, at least in the area of operations training.
The reason is that operations is too understaffed
.to a'ilow experienced operators to leave shift, even on a rotational basis.
Several operators stated during interviews that they would be interested in joining the training organization, but that they were
"not allowed to" because of the understaffing and excessive overtime problems in operations.
This issue should be addressed by the licensee when a staffing plan is developed for operations.
The staffing plan should include the needs of other organizations beside operations (e.g.
training)
when determining the optimum staffing goal for licensed/experienced operators.
d.
Training Records e.
Training records are maintained for the instructors and trainees.
The trainee files primarily contain copies of exams, but none of the 12 trainee files examined contained records of the actual courses taken or classes attended.
Attendance records for each class are available, however, the tracking of each students training is not maintained in each students file.
The instructors files were complete and contained records of initial and continuing training requirements listed in AG-001.
However, all 9 instructor files evaluated lacked the detail necessary to determine how the requirements were actually met.
For example, documentation was not available for 7 of the instructors reguarding what specific courses were taken to complete the "technical skills training" requirements.
The licensee stated that the records would be reviewed and organized to provide an auditable record.
Additionally, the administrative instructions would be strengthened to. clarified the requirements.
This item is considered Inspector Follow-up Item 250, 251/89-23-02 Implementation of Training The inspection team observed the conduct of:
a remedial requalification lecture on emergency operating procedures, a
remedial requa1 ifi cati on s imul ator exercise emphas izing classification of events in accordance with the
'emergency plan, an on-the job training/evaluation session involving paralleling control rod drive NG sets for an initial non-licensed operator training class, and a non-licensed operator class on EOP familarization.
In all four cases, the training was conducted in accordance with an approved lessori plan by individuals who demonstrated adequate skills and knowledge in their assigned areas.
For the classroom lecture, learning objectives were emphasized by the instructor as an introduction to the lesson, and were used to summarize the lesson at the end.
There was one error identified by students in the lesson 'plan, which dealt with S/G depressurization (the lesson plan indicated 215 psig, while the procedure indicated 90 psig).
The instructor dir'ected the students to revise their student guides to reflect the correct value.
Subsequent discussions with the instructor responsible for this lesson plan indicated that this error had been corrected in a draft lesson plan associated with a
new revision to the EOPs (Rev 1A), which is scheduled to be taught in June.
Students in this class included individuals who had failed the NRC requalification examination in March 1989.
The team noted:
that there was a positive attitude toward learning evident in all students in the class, and good relationships with the. instructor, who is a contractor.
The simulator exercise observed was conducted by= two contractor instructors, with the lead licensed operator instructor and the operations supervisor also observing.
The exercise involved a
simulated small break loss of -coolant accident.
While all learning objectives in the ECG were addressed, those related to classification of the event in accordance with the emergency plan
were emphasized.
The exercise was terminated when the students had made their required emergency plan notifications.
This ECG was for an evaluated exercise, and while the evaluation criteria in the ECG were generally appropriate, in some cases references to applicable procedures were not included, and the level of detail of the criteria were not consistent (e.g.,
one criterion is
"perform actions of steps 15-25 of E-O," while the preceding criterion lists 12 specific actions to be evaluated).
Turkey Point practices and procedures call for a student self-critique before instructors or evaluators provide their comments.
This was observed to have a
positive effect on the willingness of students to accept the critique in a positive way.
While the inspection team judged the critique to be effective overall, in some cases, instructors provided references to "rules of thumb" rather than procedures, which does not reinforce the need for procedural compliance.
The on-the-job training/evaluation session was conducted by a
full-time training department instructor as part of the regularly scheduled systems training for an initial non-licensed operator
'lass.
The instructor took two students into the plant to simulate paralleling control rod drive motor generator sets.
The training session was guided by an OJT self study module.
The instructor first demonstrated the task by using 'the applicable procedure to simulate task performance, explaining the rationale for the steps as he proceeded.
After answering the students questions, each student was required to simulate performance of the task, while talking through what they were doing.
When the students had completed their simulations, the instructor asked each of them two of the self-study questions from the training module.
Both students were judged by the instructor to have satisfactorily demonstrated performance of the task.
In general, the session was well conducted, the instructor was knowledgeable of the subject matter, and the students demonstrated adequate skills and knowledge, and a positive attitude toward learning.
There were some. areas noted by the team where improvements could be made.
These included:
(1)
having separate evaluation questions from the self-study questions in the module, as the student has the answers to the self-study questions before the training session; (2)
the JPM for this task (No.
4407512)
has conflicting information; the top of the JPM has a statement
"This task is a perform only requirement.
Successful completion requires that all critical steps be performed, Non-critical steps may be simulated or discussed,"
while, in the middle of the JPM blocks are checked indicating that testing may be either through performance or simulation.
While plant conditions would have allowed performance of the task observed, arrangements had not been made beforehand by the instructor with shift supervision, and thus the task was simulated.
Administrative Procedure AP-0301 describes the licensed operator requalification program.
This procedure is not completely consistent with Turkey Point Nuclear Plant practices.
For example, the procedure requires that 240 hours0.00278 days <br />0.0667 hours <br />3.968254e-4 weeks <br />9.132e-5 months <br /> of requalification training be provided annually, but does not make this training mandatory for individuals who have satisfactorily completed the previous written
requalification examination.
Discussions with responsible Training Department supervisors indic'ated that in fact, al 1 licensed operators are required to attend requalification training:
and that the procedure was written to not require individuals who had satisfactorily completed the previous requalification examination to not make up training that they missed due to illness, vacation, or other reasons.
The procedure also allows for each hour of simulator time to be counted as two hours of requalification training time.
Responsible Training Department supervisors indicated that there was a revision in progress that addressed the above items, as well as other items such as not addressing 10CFR50 Appendix B and incorrect 10CFR55 requirements.
In interviews, operators indicated that feedback and communications had improved both within the operations organization, and between the operations and training organizations.
The Plant Manager and Operations Manager have lunch every Wednesday with the crew that is in requalification training that week.
They discuss management initiat'ives and emphasis, and solicit feedback from operators on issues of interest to them, including training.
At the Plant Managers initiative the Trainirig Department has begun to provide responses to operators who provide training feedback to let them know that their issues have been addressed.
Some operators interviewed were not aware of this practice.
Some operators interviewed indicated that while the quality of instruction had improved considerabl during
.the past several years that there were still some instructors whose instructional skills were inadequate.
An example given was of an instructor standing in front of the class for an extended period of time and reading from a procedure, a copy of which was provided to the students.
In general, operators felt that the remaining contract instructors were the best of the group that had been brought in during 1986, and in many cases compared favorably with FP5L instructors.
They indicated that past problems with contract instructors teaching to the plants that they came from rather than Turkey Point no longer existed; although, they also indicated that contract instructors didn't get into the plant enough to stay as familiar with it as they should.
In interviews, licensed operators indicated that they felt that there was insufficient time provided to adequately cover the extensive amount of material presented in requalification lectures.
They indicated that for requalification weeks that were devoted to classroom lectures,
.the entire 8-hour day was often spent in classroom lectures.
Often materials were distributed during the lectures that were only partially addressed during the lecture, but which were
"testable."
Students were expected to study these materials after hours.
These inter view perceptions were also supported by the inspection team's review of the draft requalification schedule for the 1989/1990 cycle.
The second day of classroom training in this schedule (July 16, 1989)
was selected at random.
The total planned time for completing the lesson plans
'cheduled.for 'this day is 8-10 hours, which does not include any addi,'tional'ime for emphasizing any of the eight tasks scheduled to
also be addressed that day.
The same lesson plans used for initial training are generally used or requalification training.
Training Department supervisors indicated that unless o'therwise indicated on the schedule, instructors are expected to cover all the learning objectives identified in these lesson plans.
Operators indicated that this practice often results in material being covered with which they are already proficient in through their routine job duties, while other material with which they are not familiar is not covered in sufficient depth.
In i nterviews, licensed operators indicated that since the Turkey Point Plant-specific simulator had become operational on Nay 2, 1988, they had been provided only two-weeks of requalification training time on the simulator.
They indicated that this amount of time had been insufficient for them to become proficient in responding to all the scenarios which the simulator was capable of providing.
As an example, some individuals who had failed the NRC administered requalification operating test, indicated that the first time that they had seen a multiple casualty on the simulator was during their operating test.
Plant management agreed with licensed operators that, in retrospect, simulator time for
'requalification training had been insufficient.
They indicated that a.conscious decision had been made to give a priority for simulator training to an initial licensed operator class (Group XI).
This group had been provided more than seven weeks of simulator training time and had a high success rate on the NRC licensing exam (10 of 11).
The draft requalification schedule for the 1989/1990 cycle, dated April 27, 1989, has five weeks of simulator training scheduled for each shift.
Trainee Evaluation The inspection team discussed the development of an examination that was administered during the inspection with the individual who developed the examination.
This examination addressed the topic of radiation protection for an initial licensed operator class.
This course is the first one to make use of the automated test item data bank, which has test items cross-referenced to the associated learning objective and text reference.
This data bank allows the instructor to specify the learning objectives to be tested, and to then select from 'he test items that address that learning objective, or alternately allow for a
random selection of the related test items.
The individual who developed the subject examination was found to be knowledgeable of examination development methods and also of the subject matter for which he was responsible.
However, when asked to identify the policies or procedures which provide direction to test developers on examination construction, after considerable searching of the Administrative Guidelines, he concluded that there were none.
Subsequent discussions with Training Department supervisors confirmed this.
The subject instructor indicated that the principal guidance provided to him was that there were three-hour exams, given approximately weekly, and six-hour comprehensive exams given less frequently, and that from 25 to 40 questions should be included for a three-hour exam.
A review
of the test items for this exam indicated that some learning objectives were addressed by two or three test questions, while the majority of learning objectives were not evaluated by the examination.
Test items were reviewed related to the five licensed operator tasks selected for this evaluation.
While these test items had not yet been integrated into the test item data bank discussed above, they were cross-referenced to the applicable learning objectives, and were judged by the team to be consistent with these learning objectives.
Discussions with licensed operators and Training Department supervisors, and a
review of Training Department policies and procedures and selected training records indicated that waivers of licensed operator training requirements are not permitted.
Reviews of completed written examinations, and discussions with instructors and students indicated that for initial licensed operator training programs, students are provided with an answer key immediately after completing the examination.
Graded examinations are generally returned to the students within two days, and time is set aside in the training schedule for examination review.
For written requalification examinations, students don't receive feedback until their next requalification cycle (generally five weeks).
The exception to this statement is if a student fails the examination.
These students and their supervisors are notified immediately, remedial training needs are identified, and the student-has up to
days to re-take the examination.
For individual requalification rotation examinations administered at the end of each requalification week, there is no requi rement that operators be removed from shift if they fail the examination.
However, there is a written requirement that individuals who fail the annual operating test, or biennial written examination be removed from shift until they are provided remedial training and are re-examined.
The inspector's review of 12 student files indicated that those students whose scoring was below minimum standards during initial or requalification training were removed from job duties.
Documentation regarding how students were retrained and retested was available in the files evaluated.
Discussions with operators and Training Department supervisors, i,ndicated that licensed operators have been removed from shift and provided remedial training for examination failures, and in at least one case,
.because the shift supervisor determined that an operator was not proficient on the control boards.
The Plant Manager and Operations Manager have removed several supervisors from operations..crews during the past 'year because they were not considered to be good, role models.
They also indicated that they have informed operations personnel that they will continue to remove people from shift duties who do not meet expected standards of conduct, and if necessary they will shut down one or both units if that means that they have insufficient.numbers of operators to
safely staff both units.
Interviews with operators confirmed these statements.
In interviews, licensed operators indicated that they had not been adequately prepared for the examination methods used during the NRC administered requalification examination.'everal individuals indicated that they had never been exposed to an open-reference written examination prior to the NRC exam, and that as a result they did not make good use of their time because they even looked up information which they were certain of because of the availability of the references.
Several individuals also indicated that they hadn't seen a
JPH prior to the NRC requalification examination.
Static simulator exercises or evaluations had not been used by the licensee for requalification training, nor had most licensed operators participated in simulator exercises or evaluations involving multiple casualties or other comprehensive emergencies such as a station blackout, or loss of off-site power.
Plant management attributed these inadequate preparations to a combination of factors, including:
an agreement with the NRC not to make any JPMs available to operators until a large enough sample was provided for the requalification examination, not starting preparations for the exam early enough, and as discussed earlier, the priority given to use of the simulator by an initial licensed operator class, which limited simulator time for requalification to two weeks per shift during the past year.
Mhatever the reasons for these inadequate preparations, the inspection team concluded that responsible managers had not planned well for these NRC requalification examinations.
The most recently completed initial licensed operator training class (Group XI) started with 30 students.
Twenty two of these students completed the training course, but only 11 were recommended for the NRC operator licensing examination by a
contractor practice examination.
Of these 11,
passed the subsequent NRC licensing examination.
The percentage of candidates passing the NRC licensing examination was high, much higher than the plant's average over the past several years in the 60-percent range.
However, 50-percent of the students being screened out of the program by the contractor practice licensing examination is indicative that the licensee's own trainee evaluation methods had not been effective in identifying substandard student performance.
The licensee did a comprehensive
',
post-training evaluation of the Group XI licensed operator training class, and published a
report describing the results of.this evaluation in November 1988.
Principal reasons identified in this report for the high failure rate on the contractor practice licensing examination were inadequate fundamentals training for individuals without previous training or experience in this area, and grade averaging methods which overstated the students performances The training program for the curr ent initial licensed operator training class (Group XII) has been expanded to provide additional time for fundamentals trai'ning, and procedures for determining grade averages have been revised to not include re-examinations in the students overall grade averag Program Evaluation The inspection team concluded that program evaluations are being conducted at Turkey Point,'ut the evaluation findings are not always appropriately resolved.
Details to support this conclusion are provided below.
Administrative Guideline AG018 describes the evaluation methodology in place at Turkey Point.
It includes methods for systematically evaluating the training programs and for revising the programs as required.
The inspection team found documented evidence that such evaluations are taking place on a routine basis after each class, after each training cycle, and on an annual and biennial basis for full program evaluations.
Documentation included completed analyses of examinations,
.completed instructor critiques, trainee critiques, surveys of job incumbents, job performance feedback from supervisors, and the results of internal and external evaluations.
Overall, the evaluation process contains most of the essential elements of a
good program evaluation.
One weakness, described in section 2,d, was the evaluation of instructor technical competence.
Otherwise, the Program Evaluation process was well-defined and had been properly executed.
However, the results of these evaluations were not overtly acted upon.
Several evaluations were done during the last year:
Non-Licensed Operator Training Program Evaluation, Licensed Operator Training Evaluation, Post Training Evaluation for Initial License Training Program (Group XI), and the 1989 Training Assessment.
Each of these evaluations resulted in valid findings and recommendations.
In many cases these recommendations went virtually unheeded because they were not entered into an action plan or into the existing tracking system that is used to track open items.
This weakness in the feedback loop should be corrected so that the valuable insights and recommendations that are being generated by the program'valuations are not lost.
The licensee should provide mechanisms for ensuring that evaluations are properly considered and acted upon.
Although other evaluation mechanisms such as trainee feedback were more effectively used, it often seemed (to trainees)
that the process was very selective or hit-and-miss because recommendations were not always acted upon.
The licensee should provide feedback to the evaluators (trainees, incumbents, supervisors, instructors, and training evaluators)
regarding their recommendations.
This feedback should include reasons underlying decisions not to take action as well as those that do result in actions being taken.
This will alleviate the perception of some operators that their critiques are not acted on.
Administrative guideline, AG-001 requires that a formalized process is used to evaluate the instructional and technical skills of all instructors.
Mhile a formal objective procedure is used, a formal process is not used to evaluate the technical skills of -the, instructors.
Presently, all 9 files evaluated contained documents
stating that instructors were technically competent because they, hold operator licenses.
This is not a formal objective evaluation.
Similarly, 7 of the instructor's files did not contain specific courses taken to complete the technical skills training requirements.
Furthermore, the completion of instructor training requirements are not monitored in a timely manner.
Many documents to the 1988 continuing training requirements relating to in-plant activities, on-shift activities, and simulator training requirements were not checked until April, 1989.
Subsequently, it was noted that the in-plant and/or on-shift activities as required by AG-001 were not completed by four instructors.
These instructors were removed from duty until this requirement was completed.
In general, the instructors files did not contain the.details necessary to reflect adequate instructor training and evaluation.
3.
Exit Interview An exit interview was conducted on May 5, 1989, with those persons indicated in paragraph
above.
The inspectors described the areas inspected and discussed in detail the inspection results.
Proprietary in ormation is not contained in this report.
Dissenting comments were not received from the licensee.
Item number Status Description/Reference Paragraph 250, 251/89-23-01 OPEN 250, 251/89-23-02 OPEN IFI - Task analysis have not been completely analyzed and training materials have not been updated to reflect the results of these reviews, paragraph 2.a.
IFI - Training files lack the details to determine how instructor training requirements were met, also administrative instructions are vague concerning documentation of instructor training requirements, paragraph 2.d.
4.
Acronyms ANPO ATWS ECG EOP FPSL INPO IMA JPM LOCA NPO NUREG NRC OJT OT Associate Nuclear Plant Operator Anticipated Transient Without Scram Exercise Control Guide Emergency Operating Procedure Florida Power 5 Light Institute of Nuclear Power operation Independant Management Appraisal Job Proformance Module Loss of Coolant Accident Nuclear Plant Operator Nuclear Regulation Nuclear Regulatory Commission On-The-Job-Training Overtime
. S/G SRO SNPO TSAR Reactor Operator Systematic Approach to Training Steam Generator Senior Reactor Operator Senior Nuclear Plant Operator Training SYstem Action Request