ML18054A391
| ML18054A391 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 10/11/1988 |
| From: | Wambach T Office of Nuclear Reactor Regulation |
| To: | Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| References | |
| NUDOCS 8810180233 | |
| Download: ML18054A391 (19) | |
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Docket No. 50-255 Mr. Kenneth W. Berry Director, Nuclear Licensing Consumers Power Company 1945 West Parnall Road Jackson, Michigan 49201
Dear Mr. Berry:
October 11, 1988
SUBJECT:
REPORT ON POST-ACCREDITATION REVIEW AT PALISADES Between May 24 and May 26, 1988, the NRC staff of the Human Factors Assessment Branch, with support from the Office of Research and Region III, conducted a post-accreditation review at Palisades Plant. This review is in accordance with NRC policy as stated in SECY-85-1, "Policy Statement on Training and Qualifications of Nuclear Power Plant Personnel," which states that the NRC will continue to closely monitor the accreditation process and its results.
These reviews are not compliance reviews but rather a review to monitor the effectiveness of the INPO accreditation program.
The staff reviewed the licensed operator and mechanical maintenance training programs.
The staff's report is now completed and will be forwarded to INPO.
In addition, a copy of the report is enclosed for your information.
Enclosure:
As stated DISTRIBUTION
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Thomas V. Wambach, Project Manager Project Directorate* III-1 Divisi-0n of Reactor Projects - lit, IV, V
& Special Projects
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 Docket No. 50-255 Mr. Kenneth W. Berry Director, Nuclear Licensing Consumers Power Company 1945 West Parnall Road Jackson, Michigan 49201
Dear Mr. Berry:
O~tober il, i988
SUBJECT:
REPORT ON POST-ACCREDITATION REVIEW AT PALISADES Between May 24 and May 26, 1988, the NRC staff of the Human Factors Assessment Branch, with support from the Office of Research and Region III, conducted a post-accreditation review at Palisades Plant. This review is in accordance with NRC policy as stated in SECY-85-1, "Policy Statement on Training and Qualifications of Nuclear Power Plant Personnel," which states that the NRC will continue to closely monitor the accreditation process and its results.
These reviews are not compliance reviews but rather a review to monitor the effectiveness of the INPO accreditation program.
The staff reviewed the licensed operator and mechanical maintenance training programs.
The staff's report is now completed and will be forwarded to INPO.
In addition, a copy of the report is enclosed for your information.
Enclosure:
As stated
. Sincerely,
~y 1~ ?K~'-tfi;L Thomas V. Wambach, Project Manager Project Directorate III-1 Division of Reactor Projects - III, IV, V
& Special Projects
.Mr. Kenneth W. Berry Consumers Power Company cc:
M. I. Mi 11 er, Es qui re Sidley & Austin 54th Floor One First National Plaza Chicago, Illinois 60603 Mr. Thomas A. McNish, Secretary Consumers Power Company 212 West Michigan Avenue Jackson, Michigan, 49201 Judd L. Bacon, Esquire Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201 Regional Administrator, Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137 Jerry Sarno Township Supervisor Covert Township 36197 M-140 Highway Covert, Michigan 49043 Office of the Governor Room 1 - Capitol Building Lansing, Michigan 48913 Mr. Gerald B. Slade Plant General Manager Palisades Plant 27780 Blue Star Memorial Hwy.
Covert, Michigan 49043 Resident Inspector c/o U.S. Nuclear Regulatory Commission Palisades Plant 27782 Blue Star Memorial Hwy.
Covert, Michigan 49043 Palisades Plant Nuclear Facilities and Environmental Monitoring Sect ion Office Division of Radiological Health P.O. Box 30035 Lansing, Michigan 48909
POST-ACCREDITATION AUDIT OF TRAINING PROGRAMS AT PALISADES NUCLEAR POWER PLANT A.
Introduction l.O Background.
On May 24 through 26, 1988, the NRC staff conducted a post-accreditation audit of training at Palisades.~ Ten Palisades training programs*have received INPO accreditation. The Mechanical Maintenance and licensed Operators training 'programs were the subject of this review.
2.0 Approach.
Prior to the on-site review, NRC staff selected the two programs for review and informed the utility. Five tasks for each program were selected from the utility's task listing and the utility was infonned so that the materials assoc.iated with those tasks were available for review.
One additional task for each program was idel'ltified on site during the review.
The remainder of the review consisted of document review, interviews and interactions with both training and operat1ons staff and management, and classroom observations to answer the questions in the NRC's "Training Review Criteria and Procedures" (NUREG-1220, June 1986). The utility briefed the NRC review team on the general approach to training development at Palisades and explained their approach to analysis. The NRC review team consisted of two training and assessment specialists from DLPQ/NRR, one Nuclear Engineer frnm the Office of Research and two subject matter experts from Region III.
3.0 Criteria. The criteria used by the staff to audit the implementation of performance-based training programs are taken directly from the "Commission Policy Statement on-Training and Qualification of Nuclear Power Plant Personnel" (50 FR 11147) of March (0, 1985.
In its Policy Statement, the NRC states that the following five elements are. essential to acceptable perfonnance-based training programs:
- (1) Systematic analysis of the jobs to be performed, (2) Learning objectives that are derived from the analysis and that describe desired performance after training, (3) Training design and implementation based on the learning objectives, (4) Evaluation of trainee mastery of the objectives during training, and (5)
Evaluation and revision of the training based._on the performance of trained persgnnel in the job setting.
4.0 Documentation~ To support its review, the NRC requested that the following types of documentation be provided by the facility:
0 Instructions/procedures related to:
Systematic methods used to analyze jobs, Training organization goals, objectives, and plans, Responsibilities/authority of training organization personnel, Methods for evaluating/selecting instructional materials, methods, and media, Methods for organizing/sequencing training, Methods for keeping training programs current, Maintenance of training records, Selection of cal"ldidates for training and the granting of waivers/
- exemptions from training, Evaluation of training programs, and Training, qualification, and evaluation of instructors.
0 Task lists for the jobs being reviewed 0
Documentation related to:
Development/validation of task lists~
Selection of tasks for formal training,
Analysis of tasks, Analysis of on-the-job performance problems and industry events, and Evaluation/audits of the trainin~ prograrn(s).
0 Roster/organization c~art for the training organization 0
Training schedule The above documentation is the type normally associated with participation in the INPO accreditation process.
5.0 Scope of Audit. The programs audited and the tasks selected for review within those programs were:
PROGRAM (1) Licensed Operator
- Task selected on site.
TASKS 0
Direct auxiliary feedwater system surveillance tests (SRO) 0 Initiate and terminate emergency boration 0
Respond to loss of DC power (£0P-3) 0 Respond to loss of instrument air (ONP-7.1) 0 Operate the control rod drive system to bring the reactor critical 0
Perform a nonnal primary coolant pump shutdown (2) Mechanical Maintenance 0
Operate cranes-overhead and mobile (e?0-204) 0 Repair safety and relief valves (806/008) 0 Disassemble, repair, replace, and reassemble mechanical seals (807/20f) 0 Don radiation protective clothing (820/207)
- 0 Prepare and load metal oxides and dry solid wastes for shipping (819/003)
- 0
- '* See notes on next page.
Complete standard company forms, e.g.,
tagging (821/026)
- *
- 0 Repair heavy equipment (820/0C7)
- The licensee was infortne<f of each of the first five selected tasks by the NRC Team Leader on April 21, 1988. The licensee was infonned of the sixth selection after the team arrived on site. Despite this advanced notification, three planned tasks were not available to be reviewed, for three different reasons.
The licensee's personnel infonned the staff, after they had arrived on site, that Tas~ 819/003 was no longer the responsibility of the mechanical maintenance department; 820/007, nRepair heavy equipment," was performed by vendors; and 821/026 dealt not with tagging as state~ in the task list, but with miscellaneous company forms, and was perfonned by supervisors. A substitute task, chosen on site (820/007 "Repair heavy equipment") WCl.s also unsuitable for review since it was done by vendors. Although vendor tasks were not reviewed, the licensee has standards for vendor conducted training such that vendor conducted training would meet the same criteria as licensee conducted training. Even with the successful selection of another task (820/204 "Operate Cranes - Overhead and Mobile) these cumulative
- difficulties led to only four instead of the ~ntended six mechanical maintenance tasks heing audited. The staff suggested to the licensee that, when the NRC provides a list of tasks to be audited in advance of the visit, the licensee cross-check them as soon as possible with the cognizant department *heads to ensure that they are available and relevant.
In
. addition, the licensee should provide the NRC staff with the same _task list
- that is used in the plant so that the NRC will be better prepared when choosing the one task that is not announced in advance.
B.
Results of Review The following discussion of the review findings parallels the elements of the Conmission's Polky Statement on Training and Qualification.
-- 1.0 Systematic Ana*lysis of* Jobs to be Perfonned 1.1 Discussion. Analysis methods, procedures and products were reviewed using the documentat;on described in Section A.4 iibove to detennine whether:
0 A systematic method was used for identifying the tasks that make up job(s) being evaluated.
- 0 A systematic method was used for selecti~g tasks for which training is provided.
0 Tasks requiring initial training only and those requiring continuing training were differentiated.
0 Analysis of tasks chosen for training was adequate for development of learninQ objectives.
0 Approved procedures are implemented so that analysis information is kept corrent as job performance requirements change.
1.2 Findings.
The Palisades training department started their efforts toward INPO accreditation by conducting a needs analysis. This phase of the analysis is an ongoing effort that continues to receive input from the evaluation and feedback loops that are part of a systematic approach to training. Once the need for traini~g in specific areas has been established, job and task analyses are performed.
Data is gathered-from job incumbents, vendors, and any other source that is relevant to particular jobs. (Palisades has a committee whose function it is to determine which industry indicators are relevant, e.g., LERs, SOERs).
The INPO Task Data Base was used as the basis for the Palisades Licensed Operator and Mechanical Maintenance Technician positions. The task list for the Licensed Operator programs*was made plant specific by initially surveying plant operations personnel. Tasks were rated for frequency, difficulty and criticality. The task list survey data was then reviewed during consensus meetings and verification meetings attended by hcth subject matter experts and instructional technologists. Jt was determined that a survey should not be used as the first step for developing the maintenance task list. Consensus and verification meetings were held as a first step to develop a plant-specific task list. At that point, maintenance personnel were surveyed and the* tasks rated for frequenc.v, difficulty and. criticality.
The resulting task lists for each program are cross referenced to
existing traininQ materials. If the tasks are not located in existing material, they are scheduled for task analysis.
If training material already exists, a decision is made with respect to its adeq1Jacy.
l-F the material is judged to be adequate through review by subject matter experts and instructional technologists, it is cross referenced to the plant-specific task list. If revisions are necessary, the material enters the design phase of the program.
Tasks requiring initial training only and those requiring continuing training are differentiated throuQh the use of a decision tree based on survey data related to task ratings.
Tasks are analyzed to the knowledge ar.d skill level by subject matter experts.* A quality check of the analysis 1s performed by subject matter experts and instructional technologist.
The quality checks must ~e performed by.subject matter experts other than those who performed the
- origina*1 analysis. Procedures are in place to ensure that analysis information 1s kept current as ~ob performance requirements change.
Data bases and documentation were available that demonstrated appropriate iMplementation of these procedures.
2.0 Development of Learning Objectives 2.1 Discussion. Learning objectives were reviewed *for the subject programs to determine whether:
0 There are learning objectives for each of the tasks selected for review *
. -0 Learning objectives are derived from or related to the knowledge, skills and abilities needed for successful job perfonnance.
0 Each learning objective states the job performance behaviors expected of trainees upon completion of training.
0 Each learning objective states the job perfonnance-based conditions under which the trainee actions will take place.
0 Each learning objective states the specific job performance-based standard for successful performance of the objective.
- 0 Written procedures reouire modification of learning objectives when related job performance requirements changes.
2.2 Findings.
Each task selected in the licensed operator trainin£ program was supported by learning objectives derived from the knowledge, skills, and abilities needed for the successful performance of the trainee. Each program plan had clearly stated terminal,learning objectives. All objectives stated the job perfonnance behaviors expected upon the completion of training. The learning objectives were derived from or related to the skills, knowledge, and abilities thP.t enable the trainee to perform all the t&sks selected for this review.
Performance-based conditions for classroom objectives were provided in a format such as "9iven the proper dra~ing *.*
11 There was no clear distinction between initial RO programs and continuing classroom training RO and SRO programs.
In fact, the same classroom material is used for both purposes.
For the mechanical maintenance program, there were learning objectives for each of the tasks selected for audit, and these learning objectives were derived from the knowledges, skills and abilities needed for successful job performance.
In one case, the learning objective specified the expected behavior as performance "to the satisfaction of the instructor,"
a behavi~r not job performance based, and which cannot be reconciled.
The licensee stated that this was an exception to the norm, and recognized a need to modify this learning objective.
In one case, the learning objectives for a particular subtask made no reference to the job-performance requirement for removal/replacement of a component, although learning objectives in other subtasks did make such reference. The staff believes that development of an OJT component, or incorporation of a cross-reference to other subtasks-, would enhance this task.
3.0 Design/Implementation 3.1 Discussion. Using the documentation described in Section A.4 above, the design and implementation of performance-based training was reviewed to determine whether:
0 0
0 0
0 0
0 0
0 0
- There is a ~ritten plan that clearly and specifically states the training organization's goals,,objectives, plans and relationships with other parts of the facility's organization.
Responsibilities and authority of training organization personnel are clearly stated in writing.
There are documented qualification and training requirements for the training staff that address both subject matter and instructional skills anti knowledge appropriate for specific*assignrnents.
There is evidence that the appropriateness of instructional settings has been evaluated.
The organization and sequencing of the initial training programs are based upon the relationships amon~ learning objectives.
The organization and sequencing of continuing training is based upon the relationships am~ng learning objectives.
Lesson plans are available that provide for consistent training
- del hery.
There is evidence that the appropriateness of existing instructional materials has been evaluated based upon identified trainee needs and learning objectives.
Training is being conducted in an adequate manner as determined through application of training observation checklists.
There_ are ~dequate methods established for maintaining training records.
3.2 Findings. Extensive procedures are in place that clearly and specifically state the training organization's goals, objectives, and plans. Relationships with.other parts of the Palisades organization are
- made clear in Nuclear Operations Department Standards, Plant
~dministrative Procedures and Nuclear Training Procedures.
Responsibilities and authority of training department personnel ar-e also detailed in these documents.
In addition, every member of the training organ;zation has individual goals that must be met.
Qualification and training requirements are documented for the training staff. These requirements address both subject matter and instructional skills and knowledge appropriate to the subject areas taught.
In instructional skills training program has been developed at Palisades and is required for all instructors. Documentation was available to demonstrate that these requirell'lflnts have been met. There are procedures in place that provide for evaluation of instructional settings. These procedures are implemented during the analysis phase of the training program as part of the function of the consensus co1T1Y1ittee.
This evaluation is also part of the decision tree used for differentiating tasks for training and continuing training and is validated by subject matter experts against surveys of bClth students and instructors.
The organization and the sequencing of the RO and SRO training programs were based upor. relationships among learning objectives.
Functional and basic object~ves were stated first, followed by dependent*
and complementary objectives in an appropriate sequence. There was evidence of plant personnel sequencing review and documentation.
lesson plans were available for the six tasks reviewed.
Each contained a cover sheet to provide general infonnation on the lesson plans (e.g.,
title, list of classroom and training materials) and the reviewer's signature. learning objectives, and training materials were included not
- only in the lesson plans but also in the student handouts. References were made to objectives and training aids where appropriate. The
~imulator exercise guideline provided the instructor detailed instructions on how to assist the students to achieve the tenninal and enabling objectives and objective standards against which to measure trainee performance.
In general, there is evidence that the appropriateness of instructional settings has been evaluated in the development of the mechanical
- maintenance curriculum.
Two exceptions were noted in this audit. First, emergency evacuation of the crane on the refueling floor was only discussed and described; never demonstrated or performed.
Second, "hands-on" training with certain equipment lacks realism because trainees are not provided with certain equipment (e.g., gloves, hearing protection, face masks, anti-Cs clothing) that would be used on the job. Interviews with maintenance mechanics personnel indicated that the availability of such equipment would provide better preparation.
The appropriateness of e~isting training materials~was evaluated during the analysis phase of the training programs. Subject matter experts and instructional technologists reach consensus as to the quality and completeness of the material.
As previously mentioned, this evaluation is done at the task level. If the materials are aceptable, they are cross referenced to the plant-specific task list. If the existing materials do not meet standards for instructional design and content they are redesiQned to meet those standards.
Continuing classroom training for POs and SROs was observed. Using the observation checklist, it was determined that the training was conducted in an adeQuate manner by a competent instructor.
Interviews with the operations personnel indicated that the initial training as well as the simulator programs are very successful.
Operators stated, however, that the continuing/requalification classroom program shou.ld be improved by using a knowledge-based approach and focusing on integrated plant operations.
A review of the training records indicate thorough record keepinp for the trainees. Individual training records are kept on computerized forms showing all courses that the individual has successfully completed.
Class records are kept on microfiche and include attendance, tests, test results, test QA, individual performance, and result critiques.
A subject matter expert (SME) in mechanical maintenance observed a classroom session for a course lasting four hours.
The instructor was technically competent and had a good co11111and of the material. However, the SME
- concluded that the four hour duration was insufficient to cover the material and address all learning objectives *. This observation was confirmed by student evaluations of the course, and by the instructor's report.
As a result of the inadequate class length, the lesson sumnary as prescri~ed in the lesson plan was not accomplished. In addition, students were required to correct and grade their own papers, a violation of the licensee's
~rocedures. (For a further discussion on this subject, sef Section 4.?
of this report).
4.0 Trainee. Evaluation 4.1 Discussion. The methods for and use of trainee evaluations were reviewed using the documentation described in Section A.4 above to detenni.ne whether:
0 0
0 0
0 0
Exemptions from training are based upon performance-based testin~ or other objective evaluation methods.
Trainee evaluation is appropriate to job perfonnance requirements and training objective~.
Trainee performance is evaluated regularly during the training program and prompt, objective feedback provided on a regular basis.
Trainees who perform below minimum standards are provided remedial training, retested, and removed from the training program if minimum standards are not met.
Job incumbents who perform below minimum standards during requalification or continuing training are rem0ved from associated job duties and provided remedial training.
Appropriate precautions are taken to preclude compromise of test contents.
- 4.2 Findings. There are approved procedures in place that describe how individuals may be exempt from training.
Jn most cases, certification of comparable experience is considered acceptable although there is a provision for performance-based testing.
In the RO program trainee performance is evaluated regularly and feedback is provided promptly.
(Corrected exams and correct results are provided to the students within two days to one week after t~e test.) Student weaknesses are fed back to the training program.
Trainees who perform below minimum standards are provided remedial tra-ining and are retested. Document reviews showed that job incumbents who perfonn below standards during requalification or continuing training are *removed from their associated job duties and are provided remedial training.
There were several generic weaknesses with the mechanical maintenance program in t~e area of trainee evaluation. These are discussed individually below.
Trainee evaluation was no~ always appropriate to the job performance requireme~t and training objectfves.
In one case, an enabling objective required trainees to identify components on three different t~pes of _
.. valves. Test items, however, consistently tested only one of these valves, and always* the same valve.
Although the staff found evidence that prompt, automatic feedback was provided to trainees, there was no evidence that such feedback was proceduralized, or that it provided meaningful information concerning job-related "satisfactoryn vs "unsatisfactory" performance.
Although trainees who perform below the minimum standard are not given credit, remediation is not automatic; in fact, retraining is conducted only at the reouest of the individual's supervisor. There is no provision for removal from the training program.
- The NRC staff conducted interviews with four members of the mechanical maintenance staff, as well as with mana~ement. There was general agreement that no one had ever fail~d a training course, nor received remediation. Management indicated that this spoke highly of the program; the interviewees indicated that it might be due to minimum standards which are set too low, or to specific test questions which are dropped if they might make the difference between a passing and a failing grade.
The method used by the licensee for the accreditation of an individual's performance was also of concern to the staff. The maintenance mechanics interviewed indicated that a "buddy system" was used for such accreditation in an OJT setting. The system works as follows:
an accredited mechanic is asked to observe the performance of the individual seeking accreditation, and then to sign-off on his behalf.
~ore often than not, an interviewee stated, the already accredited individual does the job, while the trainee observes. Since the experienced individual is not a trained instructor, he may or may not do a good job 1~ explaining and demonstrating the work.
Nontheless, due to
- operation cf the buddy system, the trainee becomes accredited.
Finally, the issue of "grandfathering" is a potential problem in the area of trainee evaluation. Grandfathering permits those individuals with prior work-related experience to initial those jobs for which they consider themselves qualified. The individual's supervisor is then expected to review this checked list, and to indicate agreement or c'isagreement with the credit taken. *In reality, according to the interview results, the supervisor is not in a position to question or challenge such claims, and the result is that an individual is grandfathered for essentially any activity that he or she has checked.
The licensee stated that the issue of grandfathering.was no longer of concern, since it only took place when the current accredited pr~gram was first 1n;tiated.
Procedures clearly describe precautions to preclude compromise of test results. There are an adequate number of questions in the test bank for the licensed operator program to ensure that examinations can be varied
- from one administration to the next. Review of previously administered tests from the RO/SRO program indicated that questions are not repeated too frequently. However, review of several tests from the mechanical
- maintenance program indicated that insufficient precautions were taken to preclude compromise of test contents. The staff reviewed three different exams prepared for each of three different courses.
In the case of two of these courses, the staff fou~d a nearly 50 percent overlap in identical questions across exams.
Further, in the case of one course, although there were three different course handouts prepared which showed exploded views of three different components, the $.ame one handout was
.used, with identical components to be identified, in all three versions of the course exam which the staff examined.
An SME observed mechanical maintenance classroom training, and found that trainees were given their own e~ams to score. This obviously could result in a compromise of exam integrity, and reduces the value of feedback received. Although the license~'s management indicated that
- this was *an isolated incident thaf would be corrected, the interviews with mechanical maintenance personnel indicated that self grading/correcting of papers is a common occurrence.
5~0 P~ogram Evaluation 5.1 Discussion. Training program evaluation methods were reviewed using the documentation described in Section A.4 above to determine whether:
0 0
0 0
P. method is in place to systematically evaluate the effectiveness of trainin9 programs and to revise the programs as required.
Examinatio~ and operating test results are evaluated so that tests are improved and feedback is provided* to improve training.
Instructor critiques of training are used for program evaluation.
Trainee critiques of training are used for program evaluation.
0 0
0 0
- On-the-job experiences are solicited from job incumbents and used for program evaluation.
Feedback from supervisors about job perfonnance is solicited fer program evaluation.
Both internal and external training program audits/evaluation findings arE used for program evaluation.
The perfonnance of each member of the training staff is objectively evaluated on.a regular basis.
5.2 Findings. There are extensive procedures in place to ensure that the effectiveness of training programs is systematically evaluated and that the training proqrams are revised as necessary. Aggregate trainee test scores are evaluated and item analyses are conducted on test questions.
A number of computer printouts were examined that demonstrated the analysis of past examinations.
J~ addition, implementation of changes to improve questions and/or training, as necessary, was reviewed through documentation and computer tracking systems.
Both instructor and trainee critiques of training are required by procedure. A number of such documents were reviewed to ensure implementation of these procedures.
On-the-job experiences of job incumbents and feedback from supervisors about job performance problems are solicited and required by procedure.
The initial feedback ;s sought through surveys with rating scales. A place is also provided for additional corrments.
When the survey results indicate problems or when there are too many "not app11 cable" cormients, follow up interviews are conducted to clarify or enhance the data. At present, Palisades is in the process of self-evaluation for all accreditable programs, including requalification training for licensed O,.Perators. This utility has made the decision to submit all of its programs for evaluation at the same time for the second round of INPO accreditation. Procedures require that each member of the training staff be evaluated annually. Staff members are evaluated annually against criteria related to both subject matter and instructional skills. A number of documents were provided that demonstrated appropriate and timely implementation of these procedures.
- C.
SUM~ARY OF FINDINGS The Palisades Licensed Operator and Mechanical Maintenance training programs were developed from a task analysis that identified skills and knowledges from which learning objectives were derived. Existing training material was also analyzed to determine its adequacy and applicability to tasks selected for training. Tasks for continuing training were ider.ti~ied.during the analysis phase through use of survey ratin~s of tasks for difficulty, frequency, and criticality.
The staff identified several concerns during its review of the Mechanical
- Maintenance program tasks.
Among the concerns were inappropriate sign-offs for on-the~job training tasks, lack of "hands-on" training for some tasks, apparent lack of job performance feedback, inadequate precautions to prevent compromise of examinations, insufficient time to cover necessary course material, and difficulty in retrieving records and training material because of multiple locations at which training is
.conducted. The principal concern in the licensed operator program is that the location of the Palisades simulator at Midland limits its availability as a training tool.
The Palisades programs contain all five elements of performance-based training. - The tracking system for updating task analysis information for the Licensed Operator training program is particularly comprehensive.
Overall training procedures are extensive and generally well implemented.
The training facilities, materials, and evaluation methods that were observed indicated management's colll!'litment to training.