ML20102A173

Forwards Response to Exam Rept,Detailing Corrective Measures & Plans for Correcting Weaknesses in Operator Licensing Training Program.Items Discussed at NRC-Region IV 840921 Meeting Incorporated

ML20102A173
Person / Time
Site:	Fort Calhoun
Issue date:	10/15/1984
From:	Andrews R OMAHA PUBLIC POWER DISTRICT
To:	Hunter D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
LIC-84-350, NUDOCS 8502080172
Download: ML20102A173 (7)

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Omaha Public Power District 1623 Hainey Omaha, Nebraska 68102 402/536 4000 October 15, 1984 L IC-84-350 yv

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l Mr. Dorwin R. Hunter, Chief Reactor Project Branch 2 i

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,ll U.S. Nuclear Regulatory Commission g

lv Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011

References:

(1)

Letter fran D. R. Hunter to R. L. Andrews, dated August 8, 1984.

(2)

Letter fran J. T. Collins to W. E. Miller, dated August 13, 1984.

(3)

Docket No. 50-285

Dear Mr. Hunter:

Examination Report - Fort Calhoun Station Operator Licensing Training Program In response to References (1) and (2) concerning the Fort Calhoun Station Operator Licensing Training Program, please find attached the District's response describing the corrective measures taken and those planned regarding training program weaknesses.

In addition, the attached response reflects those items discussed at a meeting between NRC-Region IV and the District on September 21, 1984.

The District is confident that the corrective measures described in the attached response will ensure the District meets its ulti-mate goal of achieving excellence in training programs for the Fort Calhoun Station.

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R. L. Andrews Division Manager Nuclear Production RLA/JJF/rh-C cc:

LeBoeuf, Lamb, Leiby and MacRae 1333 New Itampshire Avenue, N.W.

Wa shington, D.C.

20036 Mr. E. G. Tourigny, NRC Project Manager Mr. L. A. Yandell, Senior Resident Inspector

/E'Y2 8502080172 841015 PDR ADOCK 05000285

('g Employmengt. aua opportunity 455824

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pT7ACHMENT R

RESPONSE TO LETTER DATED AUGUST 8, 1984

. INTRODUCTION:

f0n June'5-6, 1984, three candidates from the Fort Calhoun Station were administered Reactor Operator examinations by NRC Region IV. All three of the

.candidatesifailed this examination as detailed in a letter, D. R. Hunter, NRC to

.R.DL. Andrews, OPPD, dated: August 8, 1984.

In the August 8, 1984 letter, (concern was expressed:regarding the adequacy of the Fort Calhoun Station (FCS) foperator training programs. A subsequent letter dated August 13, 1984 from J.~- T. Collins, Regional Administrator NRC - Region IV, to Mr. W. E. Miller, 0 PPD,~ reiterated the NRC's concerns on the Fort Calhoun Station operator 1

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^ training ~ programs. These concerns were also addressed at a meeting between the iDistrict and.NRC _ management September 21, 1984.

^. Before-discussing the short term efforts that have been implemented in response to the June 1984 exam results, the District offers the following

' comments regarding our commitment to the FCS operator training process.

1The: District is currently developing operator training programs that will resultiin an overall upgrade of the existing Operator Training Programs. This

- 1 effort is. aimed primarily at the development of performance based training for all operator: programs and will ultimately lead to INPO accreditation. The Ldevelopment process includes performance of a job needs analysis (i.e. Job and taskLanalysis).. defining training objectives to bound each need, structuring the

- 6 training objectives,into a logical sequence, defining the training media to be used-andLimplementationofthe-programtoincludeafeedbackmechanismfor-4

' program evaluation and improvement.. Because.this is a systematic approach and

representsfa-completeLoverhaul of the existing Fort Calhoun Station operator-itraining programs,. it does not achieve imediate results. - To better respond to e

. current concerns,'we have structured the current accreditation efforts to

achieve.some near-term improvements'in operator training.':One near-term-improvement will1be the addition of more training facilities in the form of 7

stemporary mobile units 'until long-term facility improvements can be implemented.

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s Long~ ters facility improvements are planned for:1985. ' Another near-tem w

improvement (is the. operator lesson: plans.

In order to expedite'the upgrade of..

"the operator programs,.the District.-is1 devoting a major effort to upgrade the R

lesson. plans whil_e the job and task

analysis is being conducted. 'A third-f~'

element;of the near-term efforts :is the ~ development of a formal: instructor "

' training program'which has been implemented'and is more than 50% complete at this time.T These three ' efforts.will provide.a marked ' improvement in current

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Eoperatorftraining'.. The District will also continue to press forward with the-lon<F term accreditation-process, making every effort to keep it.on schedule. Wel 4'

' bel' eve that'the development of the performance based training will be the ultimate solution to all operator. training needs. The. required resources for' QN ithis effort is'a major undertaking for the District and ' demonstrates our level of comitment to improving operator training.E In defining near-tem training

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needs we will continue :to avoid diverting. needed ' resources from the"accredita-e tion effort.-

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e, i-EVALUATION PROCESS Based upon the concerns expressed in your letters dated August 8 and

' August 13, 1984, the District initiated an evaluation to identify and correct

' the specific causes of the June,1984 experiences. This evalustion ::3s con-ducted in three separate tasks. The first task consisted of administering a questionnaire to the three candidates taking the exam to assess their percep-tions of the reason for these failures. The second task consisted of admin-istering the same exam to a large sampling of Fort Calhoun Station licensed operators in order to determine if comon weaknesses may exist and/or if there were in fact problems with certain exam questions. The third task consisted of a rigorous independent task force assessment of the existing operator training programs with specific emphasis on actual training received by the recent operator candidates.

.Since they were informal in their application, the findings from the first two tasks were used primarily as input to the more objective and rigorous task force assessment. Thus, the task force assessment represented a major effort to identify and propose solutions to training deficiencies that lead to the June 1984 examination performance.

i The third and final task represented a much more rigorous approach to objectively' identify weaknesses that may exist in the training program and what the causes of those weaknesses might be. This task was initiated by forming a four man Task Force and providing them the charter and authority to conduct a thorough investigation of all aspects of operator training programs at the Fort Calhoun Station as they specifically relate to the training provided to the June,1984 operator examinees. The Task Force consisted of the Director of Nuclear Training and the Supervisor-Training Development of Combustion Engi-neering, Inc. and the Supervisor-Training Services and P11nt Engineer of OPPD.

The two Combustion Engineering members provided independe'sce and over two

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decades of diverse nuclear training experience. The two District team members provided expertise in the management and operation of the Fort Calhoun Station.

None of the members of this Task Force have had any previous direct involvement in the conduct or administration of the Fort Calhoun Station operator training program.

_ The Task Forcs charter identified two objectives for; their assessment. The-first objective was to specifically identify the root causes for the recent R0 exam failures. The second objective was to recommend measures that could be' taken in the near-term to provide a higher degree of assuranc'e that rear-term license candidates have been properly trained prior to taking an NRC admin.

istered examination. One assumption made at the outset of this evaluation was that the current District efforts to develop and implement a performance based training program represents the ultimate solution to any weaknesses presently.

existing in.the cperator training programs.

The initial effort of the Assessment Task 1 Force' consisted of interviewing' key; personnel from the training and operations staff, review of the June 1984-examinations and review of the results from Tasks 1 and 2.. Based upon this'

. review, the Task Force then postulated a set of potential concerns for further

. investigation.

It then set about on'a detailed-data gathering effort'to provide

objective evidence to either confirm or disprove the postulated deficiencies. L

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This dataLgathering effort included tabulation of actual training received by

recent licensed candidates, characterization.of educational and experience levels of candidates entering the operator training program, tabulation of past exam performance by Fort Calhoun Station licensed operators, review of the training methods used by the training department including lesson plans and student hand-outs, review of existing pre-employment screening used in the selection of operator candidates, and assessment of the process used for defin-ing when a candidate is ready to take an operator examination. Once the data gathering effort was completed, the Task Force as a team evaluated the data to define where weaknesses existed. The Task Force attempted to support any conclusions reached with strong objective evidence. For example, it was postu-Llated that the June 1984 reactor operator candidates may not have received sufficient training on plant systems.

In order to determine the validity of

'this hypothesis the Assessment Task Force tabulated past exam performance (NRC and/or internally administered) comparing performance in'the system section of the exams to the other exam sections, tabulation of formal system training received by.the~1icensed candidates and assessment of the process used for completing the. students system study guides.. Only upon compilation and assess-ment of this' objective data was a final decision made whether or not the ori-

-ginal. hypothesis was in fact valid.

~ Based upon the root causes identified by the data gathering and team

. evaluation process, the Task Force then proposed corrective actions that could n1 be: implemented in the near-term.to provide assurance that future license candi-dates are better prepared as'well as assuring their capability to safely operate the plant. - Although.not.specifically in their charter, the Task Force also.

identified a_-number of longer term ~ actions to be incorporated into the existing

. program for. developing-performance based training.

FINDINGS-

^ ' Task I.

The three operator candidates who took the-June 1984 exam were asked to respond to a questionnaire developed and administered by. Advanced. Technology,

'Inc. under contract to the District. The operator candidates ( responses to the

questionnaire identified weaknesses in several areas.- 'In the area of Reactor

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Theory,'all three felt that insufficient instruction had been provided~ espe-x cially atsthe basic ~ 1evel.. Another ' area identified by them as a common weakness

,was the need for additional formalilectures on plant systems. A third concern

. identifie4 by all three concerned.the/ effective use of on-shift time to provide.

WN meaningful' Control-Room' familiarization. - During task three the issues identi-

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fied by the;three ' June,1984 operator candidates were evaluated in more detail.

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? Task <

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1Thesecond:taskwas'alsoperformedbyAdvancedTechnology,Inc.-Asampling

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f off moreJhan; half of-the licensed operators : presently on shift at the Fort :

Calhoun: Station were tested-using the same examination that had been given-to

- the June 198Elicensed candidates.. The objective of this testing was.to quali-tatively-identify common weakness among the existing licensed' operators on,

ishift. ?An evaluation of-the combined exam results indicated that.although there.

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.were no major weaknesses, there were some minor. weaknesses in the area of,-

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reactur tneory, practical application of thermodynamics and understanding of instrumentation and control systems.

It was also noted that all of our licensed operators fel+ che level of difficulty of this exam was higher than in previous exams; thu, this factor may have contributed to operator performance.

Task 3 The initial objective of the Assessment Task Force was to define root causes specifically related to the most recent operator examination license failures. The Task Force determined that the recent high failure rate on operator examinations appears to be due to a combination of factors. The most significant of these factors is related to the educational and experience backgrounds of recent candidates. Two of the R0 candidates had no previous steam power plant experience before being employed by the District. By contrast between 1980 and 1984 all R0 candidates but one had been previously trained in the Navy Nuclear Power Program. The single exception had previously held three R0 licenses and one SR0 license on various research reactors. Although the

. third candidate taking the June 1984 exam had previous Navy Nuclear experience, this training had been completed several years prior to training for the R0 examination. Similarly, the recent poor performance of the senior operator candidates was ~also deemed to be related to background education and experience.

A review of senior operator exam performance for upgrade candidates (i.e.,

reactor operators actually serving on an operating shift), indicated that the District's exam performance has been better than the industry average. However, for.the instant senior _ operator candidates (i.e., degreed engineers on the station staff), exam performance has been well below the industry average.

These differences in background education and experience in themselves are

-signif_icant only in that the Fort Calhoun Station training program had not been structured to account for these differences. b

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CORRECTIVE ACTIONS Tha results of the District's evaluation demonstrated that the major weakness;in existing training has been its inability to account for differences in backgrounds of individuals. Thus, the major emphasis of near-term corrective actions is'to provide a mechanism for assessing and reacting to individual training needs. The near-term corrective actions have been implemented for the

~ operator candidates scheduled for the November,1984 NRC examination. These f actions include administering detailed NRC type written and oral audit exams to define training needs; structuring classroom training to address weaknesses; and requiring the Station Manager to personally review each individual's perfomance

prior to authorizing them to take the NRC exam. The District believes that these near-tem measures will ensure that the three candidates' weaknesses will

. be directly addressed and their performance more closely monitored.

The District is also initiating several other corrective actions to be implemented for all future candidates until full implementation of performanced based training is achieved. Two key elements are to require more rigorous assessment of individual performance,to define training needs and to require

-increased management involvement in the training process. The improved perfor-g

~ mance assessments will include more structured classroom lectures with mandatory quizzes,. structured oral examinations, and additional NRC-type topic and compre-

'hensive audit examinations. These interim measures will be implemented by

-January 1, 1985.-

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'The District has also defined several longer-tem actions and/or areas for further evaluation. These include: review of the Senior Operator Programs to

-define improvements, additional entry screening criteria for operator candi-dates, and evaluation of the requalification program for effectiveness. These longer-term actions will be incorporated into the existing program for L ~

developing performance based training.

.One issue critical tolur ability to complete the actions identified ~above is the~. staffing of our. training programs. - Staffing of. qualified trainers has been an on-going process at FCS. At the beginning of 1980 one full time-trainer.

was. responsible for administering all Fort Calho Training Programs, with limited assistance l provided by other technical.

cialists. The majority.of this indiviaual's: effort centered on the admint Stion and conduct of the.

operator.trainingprograms.:Currentlyseven(7)

%e' trainers are assigned

-to:the Station Training Department with!four (4) adr

.al' openings authorized..

._0f these seven, oneLis dedicated to licensed.operati

...ining and a~second to non-licensed operator training. Additionally, two a stract trainersLare

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! assigned full: time to requalification and. initial operator training. - Additicnal

,# training personnel are authorized for 1985. EIn addition, the station organi-zation:has been restructured in that a' training' supervisor's position now reports directly to the Manager - FCS.' - This organizational realignment was implemented to provide' additional authority and emphasis for training programs..

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We'are continuing to aggressively pursue filling the open positions while not p'M sacrificing the qualification of these individuals.

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F In addition to the station training staff, a corporate Training Services Department was also authorized in March, 1984. The Training Services Department is responsible for the development of the performance based training programs and oversight of program implementation.

Currently, three of four authorized positions in this department have been filled.

CONCLUSIONS-The evaluations conducted in response to the August 8 and 13, 1984 letters clearly. identified the need for immediate improvements in FCS operator training programs. The District has implemented actions that will provide near-term improvements yet will not adversely impact our long term program to develop performance based training.

We are committed to both the near-term corrective actions and the ultimate goal of achieving excellence in tre.ining programs for the Fort Calhoun Station.

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