IR 05000458/1990020
| ML20056B248 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 08/21/1990 |
| From: | Gagliardo J, Vickrey R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20056B247 | List: |
| References | |
| 50-458-90-20, NUDOCS 9008280002 | |
| Download: ML20056B248 (11) | |
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APPENDIX
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC' Inspection Report: 50-458/90-20'
Operating License: NPF-47 D'ocket: 50-458 L
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Licensee: GulfStatesUtilities(RBNG)
P.O. Box 220
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St. Francisville, Louisiana 70775 i-L Facility Name: RiverBend'$tation(RBS)
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, Inspection At: RBS, St. Francisville, Louisiana 70775 i
Inspection Cond ted:- July 23-26, 1990 l
U N Inspector:
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( R. 4/. Vickrf,. Reactor Inspector, Operational Date
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Programs action Division of Reactor Safety
Accompanied By:
R. M. Pelton, Human Factors Analyst, Procedure and Training i
Section, Human Factory Assessment Branch, Division of
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Licensee Performance and Quality Evaluation, Nuclear Reactor Regulation-B. Brett, Consultant, Science Application International Corporation Approved:
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dp E. Gagliardo, Section Chief, Operaticnal Date'
' Programs Section, Division of Reactor Safety-
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- Inspection Summary inspection Conducted July 23-26. 1990 (Report 50-458/90-20)
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c-AreasInspefed:. Routine, unannounced inspection of training and qualification
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effectivenet
.Results:'.Wi> in the. area. inspected, no violations or deviations were
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identified. Several individual items and areas of weaknesses were identified that warrant management's attention.
Individually these weaknesses may not
. affect the' quality and effectiveness of training, but collectively they are
'significant and indicate a pattern of performance that is of concern.
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9008290002 900822 PDR ADOCK 05000458 Q
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The' principle weakness was the excessive turnover rate of experienced
instructors. This problem had caused a heavy wo"kload on the remaining staff and had adversely affected the quality of work. Licensee management agreed-i with the inspectors and shared <their concern '.egarding the high turnover rate of instructors. Management assured the in;pectors that action would be taken to rectify this problem.
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DETAILS t
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PERSONS CONTACTED
- D. L. Andrews, Director Nuclear Training K. Banes, Planning and Scheduling Specialist B. J. Chustz, Supervisor, Maintenance Support
- T. C. Crouse, Manager Administration
- W. L. Curran, Site Rr.s esentative
'J. C. Deddens, Senior Vice President
- L. A. England.. Director, Licensing M.S.Feltner,LicensingEngineer
- J. R Hamilton, Director, Design Engineering G. K.' Henry, Director. Quality Operations
- D..N. Lorfing, Supervisor, Nuclear Licensing
- R. C. Lundholm, Operations Engineer
- W. H. Odell, Manager, Oversight T. F. Plunkett. General Manager, Oversight and Business System C. A. Rohrmann, Training System Coordinator
- W. M. Searcy, Senior Quality Assurance Engineer J. P. Schippert, Assistant Plant Manager, Operations, Radweste, and Chemistry
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J. E. Spivey, Senior Quality Assurance Engineer / Audit Coordinator
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- K. E. Suhrke, General Manager Enginacring Administration
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- J. C. Maher, Engineer, Licensing The inspectors contacted other licensee personnel during the inspection.
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-* Denotes' attendance at exit interview conducted July P6, 1990.
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TRAINING AND OUALIFICATION EFFECTIVENESS (41500)
The licensee's training activities were inspected using oortions of the guidance in NUREG-1220 " Training Review Criteria and Procedures." In evaluating the strengths of the licensee's training program, emphasis was not directed towards any particulcr area. The areas reviewed were selected based on the scheduled i
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training at the time of the inspection and the inspector's background and
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knowledge in the subject areas.
Interviews were conducted with training department coordinators, instructors, and students.
Inspection activities also included:
o A tour of the training facilities; t
o A review of selected training department procedures, records, and j
instructions;
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o An audit of training presentations and associated lesson material; o
A review of previous licensee's quality assurance audits and associated training department corrective actions; and
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A review of outstanding training material review (TMR) checklists and training material discrepancy reports (TMDRs).
2.1 Tour of the Training Facilities
The inspectors conducted a tour of the training facilities with a primary focus on training aid equipment and the status of training using this equipment.
Arecs included in the tour were the simulator and the laboratory (180), and facilities for electrical, mechanical, chemistry, instrumentation and control radiation protection. Electrical and mechanical equipment mockups appeared limited. Some of the equipment that was available was not in use since lesson plans had not yet been developed to make use of the equipment. The licensee had been supplementing some of these areas through vendor taught training classes.
These classes had been primarily arranged as a result of identified needs through training review group meetings for the associated disciplines. Although vendor training supported individual development for e uipment knowledge, it did not s
include other plant features and procedural requirements that were unique to the licensee's application. The inspectors observed that the simulator appeared i
to be updated to current plant status. The licensee had accomplished this through an informal " Plant Status for Simulator Training" data sheet. This data sheet provided training with a detailed account of plant status and changes to support training needs.
2.2 Review of Licensee's Quality Assurance Audits and_ Associated Training
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Department Corrective Actions The inspector reviewed the licensee's Quality Assurance Audit 90-01-I-PTQL/TRAG, conducted January 16 through February 5,1990. Although the training department
had taken corrective action on some of the previous report findings, there were i
some actions that were not completed, and some other corrective actions had not been found to be satisfactory. The audit indicated that a number of weaknesses might be present and suggested that the overall training and certification program warranted improvement. These findings were supported by quality assurance finding reports (QAFRs) within the audit.
It would appear from these overall findi1gs that the training department may be operating at a marginal staffing and/ar experience level.
2.3 Review of Outstanding Training Material Reviews (TMR) Checklists and Training Material Discrepancy Reports (TMDRs)
The inspector reviewed the status of outstanding THRs and TMDRs and the methods l
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l of control for these. Over the past 6 months, the licensee had been maintaining
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a total backing of approximately 500 TMRs and TMDRs. The rate of opening and closing the THRs and TMDRs was about 100 per month. Of this backlog approximately a
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10 percent were items identified in years 1986 and 1987. A large percentage of these were related to system description lesson plans which were in an inactive status. During the review of a small sample of 1986 TMDRs that were being tracked as open the inspector found that the lessen plans had been revised in i
1988 and that some Tt1DRs were removed f rom the lesson plan packages. Although the action to revise the lesson plans appeared completed, TMDRs apparently had
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-5-not been formally closed out or logged into the tracking system. The inspectors also noted that the licensee did not follow the specific process outlined in Procedure TAP-5-005, " Configuration Management of Training systems," in closing generic issues identified in industry experience documents. This process would have had the coordinator issue a THR for a routing mechanism (tracking r,.ethod)
and evaluator tool. This TMR then would have been closed out with the issuance of the TMDRs. Although the inspector found no technical response deficiencies, the inconsistencies in the tracking, closeout, responsibility, and accuracy of the tracking system certainly should be evaluated by the licensee.
2.4 Audit of Training Presentation and Review of Training Materials
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The inspectors observed three simulator training sessions which included practice and evaluated scenario lessons for licensed operators and for members of the technical staff and system engineers. The operator scenarios cbserved and reviewed by the inspectors were SPS-005-1, "Unisolable Steam Leak Outside Primary With an Injured Man," and SPS-014-0, " Loss of Normal Service Water."
The lesson plans contained a summary, crew turnover information, directions to the evaluator and console operator, operator actions, and instructions for use of the evaluation standard. The lead instructor did a good job of orchestrating the scenarios and subsequent critiques. All instructors and
eva hators participated in the critiques and made use of the simulator for demonstration purposes to support areas of discussion. During one l
demonstration the simulator failed to exhibit the expected response, but the
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lead instructor stated that a simulator problem report had been submitted to correct the problem. The inspectors observed portions of one of five simulator j
sessions being taught to system engineers with Lesson Plan SET-508-01,
" Simulator Training." This training was being conducted in conjunction with I
classroom training for each session. The course was designed to provide an I
overview of plant startup, shutdown, and plant responses to various transients.
Discussions with the system engineers abent the course revealed that they were i
very pleased with the hands-on-training concept at4 the instructional support the training department had provided in this area. The lesson provided the appropriate objectives and techniques for instructor support.
i 2.5 Review of Selected Training Department Procedures. Records, and Instructions
Various records, documents and materials were reviewed to determine how well training procedures were followed and to assess the overall cuality of those products.
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During the review of job task analyses (JTA) worksheets for maintenance tasks, j
the inspector noted that standards for task performance were not included.
l Standards were required by River Bend training procedures and were an especially i
important element of the JTA data. The standards provided the basis for evaluating j
task performance in the training leb and during on-the-job-treining (0JT).
These standards are critical in establishment of a performance-based training
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Thus, it had been 4 or 5 years since some of the JTA results were updated.
This appeared to be an excessive time. JTA data were not reviewed frequently to reflect changes in procedures for existing tasks and for the addition of new tasks in a job area. Training materials could then be updated to ensure that the training accurately reflected job requirements in the plant.
There was no maintenance task-to-maintenance training course lesson plan matrix which cross referenced maintenance tasks to training course lesson plans.
Consequently, no one in the maintenance training department could tell the inspectors which tasks were trained in which courses. When the link between the JTA and the training courses was broken, the ability of the training organization to ensure that training accurately reflects current job requirements in the plant was weakened significantly.
The radiation protection technician lesson plans were in the procedure specified format and appearedsto be adequate to ensure consistency of instruction. The NC0/ nuclear equipment operator (NED) lesson plans, however, were not in the procedure specified format.
In discussions with the technical training coordinator, it was learned that the emergency plan (E-Plan) lesson plans for NCOs and HE0s had been selected for conversion to the computer-based training (CBT) format. When reviewed as CBT scripts, the E-plan lesson plans did lend themselves for, easy conversion to CBT. However, with the uncertainty of the date of conversion to CBT and to ensure consistency of instruction, additional review of lesson plans may be warranted.
The training records for 12 operations and training department personnel were reviewed. The inspector found the records to be easy to use, to be complete, and to have been reviewed annually as required.
Generally, lesson plans for maintenance training were well organized end
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followed the format set forth in the training procedures. However, the conditions portion of the learning objectives for laboratory training did not recognize special conditions associated with task performance in the nuclear plant environment (e.g., es low as reasonably achievable (ALARA) considerations, requirements for protective clothing that impedes task performance, etc.). As noted above, incorporation of these f actors into laboratory training would have significantly increased the validity of that training.
If these features are incorporated into the lesson plans, learning objectives will need to be changed.
Lessoi; plans for instructor training were reviewed. The lesson plans were well organized and followed the format set forth in the training procedure. Content of the training was sufficient to yield qualified instructors.
Program evaluation reports (PERs) were the means by which training system effectiveness was evaluated. As specified by the pigram evaluation training procedure, PERs were generated for individual training courses.
It should be noted that the procedure did not specify the frequency with which courses were C
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7-to be evaluated. PERs filed since 1986 were reviewed in the following areas:
mechanical, electrical -I&C, chemistry, fire protection, and technical staff and management. Results of the review were as follows:
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o Only one PER had been filed this year.
o Only one PER was-filed in 1989.
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o The vast majority (approximately 81 percent) of PERs were done by the
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maintenance training department.
o All but one PER was beced soltly on survey or questionnaire data. More objective means such as analysis of test scores were not used.
Implementation of the program evaluation procedure had been less than v uorous and had relied on subjective indicators to the exclusion of more objective methods.
Feedback on training effectiveness was an essential element of systematic approach to training (SAT). The program evaluation procedure was the formal mechanism for obtaining that feedback.
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The inspector reviewed the evaluations for five operations instructors selected at random. Procedures required each instructor to be evaluated in each i
instructional setting in which the instructor was qualified at least once per calendar year. While evaluation identified weaknesses appeared to be acted upon, one simulator instructor and one classroom instructor had not been evaluated in calendar 1989. The evaluations were missed because of an apparent failure of the instructor evaluation tracking system.
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2.6 Interviews With Training Department Coordinators, Instructors, and Students l
Within the training departirent, interviews were conducted with a training coordinator, two instructors, and an instructional technologist. All of the individuals demonstrated a grod, general understanding of the SAT process and the particular responsibilities of their job positions. Highlights of each interview are provided below, j
l A training coordinator for maintenance and quality assurance training was
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interviewed, and the following points were noted:
o A primary objective of the department was to move more fully toward a performance-based training program. Job proficiency would be demonstrated via " hands-on" task performance rather than paper-and-pencil tests.
o To date, OJT had been the principle means of providing hands-on training experience and qualification. River Bend was trying to replace all OJT
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with-laboratory training.
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o The maintenance training lab was small and represented only some of the i
equipment in the plant.
In order to expose workers to a broader range of equipment, vendors had been contracted to bring in equipment and conduct
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special training classes.
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strain on the training program because intrnductory training classes had to be offered more frequently.
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The movement toward a more performance-based maintenance training program with emphasis on the laboratory as the qualification environment was considered admirable and consistent with the orientation of SAT. Use_of vendor equipment was a creative solution to the problem of exposing personnel to a variety of
equipment.
A maintenance training instructor was interviewed. The interview focused on how well the actual job environment was represented during training. Of particular concern was the extent to which ALARA considerations and task performance moderating factors, such as protective clothing and presence of obstructions, were incorporated. The following points were noted:
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o The maintenance laboratory training generally had a " workbench" orientation to denonstrate task proficiency. The worker performed the task on a piece of equipment that was placed in the open on a table or on the floor free of obstructions and obstacles, o
ALARA considerations were not stressed (ALARA training was provided as part of general employee training, but not incorporated into the laboratory training) and there was no requirement to perform the task i
while wearing protective clothing or dealing with other encumbrances (in the past there had been attempts to create environments with piping and obstacles, however, this had been the exception rather than the rule).
o The standard for task completion was simply performing all task steps properly. No time or other constraints were applied.
ALARA considerations and the requirement to perform tasks while wearing protective clothing are significant factors that distinguish maintenance L
activities in the nuclear plant environment from other industrial environments.
It is important that these factors be incorporated into introductory maintenance
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training so that personnel new to the nuclear environment become acquainted with the full range of variables that come to play maintenance task performance.
Finally, more stringent performance evaluation standards needed to be e ployed that included time and other important dimensions of performance. This was particularly true for tasks that could expose workers to radiation. The need to minimize performance times for these tasks should have been reflected in the L
evaluation standards. To be valid, these standards should have reflected the l
effects of factors such as protective clothing on performance times.
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An instructor with responsibility f or training engineering department personnel was interviewed. The focus of the interview was on a JTA of engineering job
positions that was being conducted. The following points were noted:
o The instructor had done an excellent job of delineating the various engineering groups and activities in the plant. Some 24 groups had been identified.
o Coordination with the plant had been good and support from the plant in terms of subject matter assistance and management support was good, o
Accepted practices for conducting JTA were being employed, and a thorough listing of tasks should result, o
The instructor's knowledge of some of the finer points of the JTA process such as techniques for analyzing difficulty importance, and frequency (DIF)
dataandusingthatdatatoallocatetasksfortrainingwasalittle weak, and more technical support from the department's instructional technologists could have been used. This was not a deficiency on the instructor's part.
The engineering position JTA was an excellent initiative that was being executed well.
It was, however, a major undertaking that was apparently
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understaffed.
An instructional technologist was interviewed. The focus of the interview was on the engineering position JTA and the use of instructional technologist in the training department. The following points were noted:
o The instructional technologist role in the engineering JTA was advisory, lie had not personally conducted any part of the analysis, o
An important part of the instructional technologist job was conducting instructor training. There were two phases of instructor training:
general instructor skills (e.g., platform presentation skills, student interaction skills, etc.) and the systematic approach to training, o'
The most significant problem facing the training department was personnel turnover and a shortage of personnel.
More direct instructional technologist involvement in the engineering JTA would provide a quality product. The training provided to instructors was sound.
The perception that training department personnel turnover and shortages was a problem was consistent with the comments of others and the observations by the inspection team.
In addition to the interviews with training department staff, interviews were conducted with four personnel from operations as well. The interviews included one NE0, two senior reactor operators, and one shift supervisor.
Issues of i
concern raised by all four were generally similar. These are listed below:
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Many operations instructors were not experienced enough in plant operations. The current licensed operator instructors, while qualified and experienced as instructors, lacked commercial BWR operating experience. Only one instructor had connercial N R operating experience prior to joining the licensed operator training group. This had led to a credibility problem with the operation staff.
o The high turnover rate arcng instructors had resulted in an instructor staff who were inexperienced as trainers, o
Instructional materials'did not have sufficient depth, perticularly for requalification training where experienced operators were looking for more detail. The material was just a review of " HOT" license training. The workload of the instructional staff, apparently caused by the lack of connercial BWR operational experience and the shortage of instructional staff, had started to impact the quality of training at River Bend training center. Lesson plans did not always reflect n.odifications to systems in the plant prior to the use of the lesson plan. The level of
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detail, in the existing lesson plan, was a challenge to the lesser experienced instructors at River Bend.
o Operators also believed the instructional staff needed to spend more time in-plant which would help. raise their operational awareness and level of operational experience, o
The workload of the staff had prevented the simulator staff from developing new, challenging simulator scenarios, in many cases, simulator scenarios had been performed several times. Operators also identified several simulator fidelity problems associated with the simulata malfunction (ystem, the simulator ventilation systems, low-voltageloss of DC pove annunciator s and the lack of ability to steam cool the primary.
o Operators stated that operations management involvement was adequate.
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Senior reactor operators were used to walk through simulator scenarios, and operations was in the training material review and concurrence chain.
The inability to ecquire and retain seasoned instructors with substantial operations experience was significantly affecting the quality of operator
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training. Also, a shortage of trainers prevented instructional materials from being updated in a timely manner and as a result the instructional staff was overworked. Simulator deficiencies prevented significant portions of the system from being used in training.
No violations or deviations were identified in the review of this program area, i
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EXIT INTERVIEW The inspectors met with the licensee representatives (denoted in paragraph 1)
on July 26, 1990. The inspectors summarized the inspection purpose, scope, and findings. The licensee acknowledged the comments and agreed that the inspection team findings were valid indicators of a declining quality trend in training and responded that the lack of retention of experienced and qualified instructors was a significant contributing factor and concern.
The inspectors expressed the need for the licensee to take timely corrective action of these concerns to prevent further decline of overall training quality. The licensee did not identify any specific information as proprietary to the inspectors.
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