ML20141H805
| ML20141H805 | |
| Person / Time | |
|---|---|
| Issue date: | 04/22/1997 |
| From: | Thomas C NRC (Affiliation Not Assigned) |
| To: | Boger B NRC (Affiliation Not Assigned) |
| References | |
| NUDOCS 9705270128 | |
| Download: ML20141H805 (13) | |
Text
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April 22,1997 i
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MEMORANDUM TO:
Bruce A. Boger, Director i
Division of Reactor Controls and Human Factors FROM:
Cecil O. Thomas, Chief Human Factors Assessment Branch Division of Roactor Controls and Human Factors
SUBJECT:
ANNUAL REPORT ON THE EFFECTIVENESS OF TRAINING IN THE 4
NUCLEAR ' INDUSTRY FOR CALENDAR YEAR 1996 Attached for your information and use is the Human Factors Assessment Branch's 4
" Annual Report on the Effectiveness of Training in the Nuclear Industry for Calendar Year 1996." The report is based on the 'NRC's (1) review of licensee event reports and inspection reports for training-related issues, (2) observations of the INPO accreditation process and (3) review of the results of operator licensing activities. The report concludes
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that INPO accreditation continues to be an acceptable means of ensuring the training requirements contained in 10 CFR Parts 50 and 55 are being met. Although NRC monitoring has provided some indications of limited specific weaknesses in training programs, overall, all indicators suggest that the indtstry is implementing training programs in accordance with the regulations.
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ANNUAL REPORT -
ON THE EFFECTIVENESS OF TRAINING i
IN THE NUCLEAR INDUSTRY FOR
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1 ANNUAL REPORT i
ON THE EFFECTIVENESS'0F TRAINING IN THE NUCLEAR INDUSTRY FOR CALENDAR YEAR 1996 i
BACKGROUND i
The history of NRC regulation of training in the nuclear industry dates to the.
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1982 Nuclear Waste Policy Act which required the NRC to provide guidance on the instructional requirements for workers at nuclear power plants. To meet.
this directive, the Commission published a policy statement on training in i
March 1985 which endorsed the performance-based training accreditation process managed by the Institute of Nuclear Power Operations. When issuing the policy statement, the Commission deferred rulemaking to allow the industry to continue its efforts to upgrade their training programs. After an initial two-year period, evaluations of the accreditation process concluded that it was generally effective in bringing about improvements to the training programs so rulemaking was not ir.itiated.
In November 1988, an amended policy statement on training was issued to reflect the existing Commission views on training in the nuclear industry.
In response to a 1990 court decision, 10 CFR 50.120, " Training and Qualification of Nuclear Power Plant Workers," was issued in April 1993 and became effective in November 1993. This rule requires that training programs be established, implemented and maintained using a systems approach to
, training (SAT) for nine categories of non-licensed workers at nuclear power INIF8 1996 Annual Report On Training 1
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plants.
10 CFR 50.120 complements the requirements for SAT-based training for i
the requalification'of licensed operators contained in 10 CFR Part 55, which
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was issued in 1987.- 10 CFR Part 55 allows facility licensees to have an i
i operator requalification program content that is derived using a SAT-based process or which meets the requirements outlined in.10 CFR 55.59.(c) (1) through (7).
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In'accordance with its Memorandum of Agreement with INPO, the NRC monitors
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INPO accreditation activities as part of its assessment of the effectiveness of the industry's training programs. The NRC also monitors selected j
performance areas of its licensees as part of its assessment. This report j
summarizes the NRC a:sessment of the effectiveness of the industry's training programs for calendar year 1996.
EC R ITORING OF TRAINING i
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Ti;.4PC monitors industry performance in implementing the training i
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requ',rements of 10 CFR Parts 50 and 55 by (1) reviewing Licensee Event Reports (LERs) and inspection reports for training-related issues, (2) observing the accreditation process, and (3) participating in, inspecting, and reviewing the i
results of operator licensing activities. Guidance for administering examinations _ for licensed operators is contained in NUREG 1021, " Operator Licensing Examiner Standards," Revision 7, Supplement 1, June 1994. Guidance for inspecting the aspects of the operator training programs unique to requalification is found in Inspection Procedure 71001, " Licensed Operator Requalification Program Evaluation."
In addition, the NRC, for cause, INFB 1996 Annual Report On Training 2
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verifies compliance with the requirements for SAT-based training through its inspection program and has done so when appropriate using Inspection Procedure l
41500, " Training and Qualification Effectiveness," which references the guidance in NUREG-1220,
" Training Review Criteria and Procedures." The Human Factors Assessment Branch (HHFB) in the NRC's Office of Nuclear Reactor i
j Regulation has the programmatic responsibility for ensuring that utilities implement training requirements for all covered personnel in an acceptable manner.
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Training Issues in LERs and Inspection Reports i
a Several aspects of human performance are continually monitored and documented g_
in the Human Factors Information System (HFIS) by HHFB during its on-going 2
reviews of LERs and inspection reports and through its on-site human f
performance investigations of operational events.
Twice each year, in support of the Senior Management Meeting process, HHFB compiles the available human performance data from HFIS for all plants, including training data, and identifies those plants where human performance may be an issue.
l A review of training issues contained in LERs and inspection reports was conducted for calendar year 1996 using HFIS data. This review revealed that, l
for calendar year 1996, the number of LERs that cite training as a
' contributing factor increased by 17% over that of calendar year 1995.
Figure 1, " Training-Related Contributing Factors in LERs," shows the number of cited training issues.
5 MFB 1996 Annual Report On Training 3
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f During calendar year.1996, the number of human performance items in inspection
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reports that are identified as having a training contributing factor increased by 17% over calendar year 1995. A breakdown of these contrituting factors is shown in Figure 2, " Training-Related Contributing Factors in Inspection i
Reports." Of particular interest in Figure 2 is the increase in the number of instances where less than adequate-worker knowledge is identified as a contributing factor. These worker knowledge deficiencies may be a. reflection of continuing systems approach to training (SAT) process problems which are I
also indicated in. Figure 2.
Given the maturity level of most industry 1
training programs, the SAT process elements related to trainee evaluation and program effectiveness evaluation are the areas most closely linked to j
performance deficiencies.
4 The NRC can inspect facility training programs at any time to verify j
satisfactory implementation of the training requirements in 10 CFR Parts 50 j-and 55. However, based on the NRC's continued confidence in the accreditation i
process, training inspections are only conducted when sufficient cause is t
identified. Three "for-cause" training-inspections were conducted during j
calendar year 1996 -- at Zion, Braidwood and River Bend.
e j-j The Zion inspection was initiated based on human performance data in HFIS j
. which suggested a potential training program problem in the area of
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. maintenance. The results of the inspection, which are documented in
~ Inspection Report 50-275/96-06 and 50-304/96-06, indicated weaknesses in the b
areas. of trainee evaluation and program evaluation. Of particular note in the area 'of trainee evaluation were weaknesses related to the determination of INFB 1996 Annual Report On Training 4
initial task mastery and the conduct of continuing training to maintain skills.
In the area of program evaluation, weaknesses included the failure to use feedback to determine program effectiveness and the level of task degradation prior to action.
A training inspection of the maintenance training program was conducted at Braidwood, another site owned by the same utility, to determine if the weaknesses related to trainee evaluation and program evaluation identified at Zion were indicative of generic utility-wide problems. The results of the Braidwood inspection were documented in Inspection Report 50-456/96-09 and 50-457/96-09. Braidwood's performance in the areas of trainee evaluation and program evaluation was good and the observed performance for maintenance training was satisfactory.
I A third training inspection was conducted at River Bend in response to 1
observed poor performance during an emergency plan drill as well as poor results on a licensed operator requalification examination. The results of the River Bend inspection were documented in Inspection Report 50-458/96-24 and indicated a weakness in the conduct of trainee evaluations. The licensee's training staff did not detect that crew behavior was potentially
- masking individual weaknesses. Additionally, improved performance trending could have helped identify crew and operator weaknesses before they were manifested 'as less than adequate performance in the simulator. The team concluded that, overall, the processes for trainee and program evaluation, as applied to operations personnel, were satisfactory.
4 NNFB 1996 Annual Report On Training 5
Since training inspections are reactive in nature, none are scheduled for calendar year 1997. However, HHFB's current budget includes support for up to l
four training inspections by Branch members.
Observation of the Accreditation Process An important aspect of monitoring training is the observation of INP0 Accreditation Team Visits and the National Nuclear Accrediting Board (NNAB).
NRC observed one Accreditation Team Visit and all 10 meetings of the NNAB during calendar year 1996. As a result, the NRC was able to observe the presentation of training programs from 34 plants to the Board for accreditation renewal. The NRC observers were drawn from all levels of the NRC and included representatives from headquarters and three of the four NRC regions.
'l The NRC continues to note the rigorous review received by the training programs during the accreditation team's on-site evaluations as well as the in-depth questioning by the Board of the accreditation evaluation results when the programs are presented. Of particular note were comments of the NNAB observers related to NNAB's questioning of INP0 staff, which many NRC observers cited as evidence of the independence of the NNAB from INPO. Based on these observations, the NRC continues to have a favorable assessment of the accreditation process. The NRC has no formal mechanism for learning of the accreditation status of training programs following the utility presentation to the NNAB. When communicating accreditation status to the utilities, INP0 i
MIFB 1996 Annual Report On Training 6
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encourages the utilities to share the new accreditation information with the
'NRC, however, the licensees are not required to do so.
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i At least annually, the NRC meets with INP0's Training and Education organization to exchange information related to training in the nuclear 4
industry. During these meetings, NRC representatives discuss the observations made by NRC observers to INPO-lead Accreditation Team Visits and the NNAB.
Data sheets collected from NRC observers of the NNAB meetings during calendar year 1995 raised the question of whether INP0 had created a new accreditation category, " renewed with concerns," for programs presented to the NNAB for accreditation renewal.
Since this appeared to be a change in the accreditation process, the NRC discussed the status of programs that were
" renewed with concerns" at the Annual INP0/NRC Coordination meeting which was held at NRC headquarters in February 1996. As a result of the discussion, INP0 denied that a new accreditation category had been created and reaffirmed that the NNAB has available only three accreditation options - renewal, i
probation and withdrawal.
Additionally, the NRC and INP0 agreed to continue to explore the best way for the NRC to gain information on evolving trends in training and to be sensitized to INP0's expectations in those areas. As a result of the discussion, INP0 agreed to discuss recurring training-related issues contained in its annual weakness letter with NRC personnel visiting the INPO offices.
Resident inspectors continued to review all INPO plant evaluation and accreditation reports'in accordance with the NRC's Field Policy No. 9, "NRC Review of INPO Documents," to ensure that significant safety issues receive IMIFB 1996 Annual Report On Training 7
appropriate follow-up..No safety-significant training issues were identified 4
in calendar year 1996 as'a' result'of resident ins.pectors' reviews of accreditation reports.
-Results of Operator Licensing Activities The implementation of_ SAT-based training requirements in the licensed operator training programs is reviewed by HHFB during its routine monitoring of reports detailing operator candidate initial examination and operator requalification inspection results. Any training-related issues identified are incorporated
-into the HFIS database and reflected in the overall information on training.
Licensee emphasis on licensed operator training programs has attempted to improve the overall training for that group of personne'1. However, inspection report information shows that SAT-based training process problems are still being identified in operator training programs.
This fact, together with the 1
l number of items in inspection reports attributed to " inadequate training,"
suggests that on-going monitoring of training program results is needed to I
ensure continued acceptable performance by operators.
Furthermore, results of inspection of licensee requalification programs indicated that additional i
focus in this area is warranted for selected licensees.
CONCLUSIONS The combination of HHFB activities used to monitor industry performance in the area of training has indicated that INPO. accreditation continues to be an acceptable means of ensuring that the training requirements contained in
-IntFB 1996 Annual Report On Training 8
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10 CFR Parts 50 and 55 are being met. Although NRC monitoring has provided some indications of limited specific weaknesses in. training programs, overall, all indicators suggest that the industry is successfully implementing training programs in accordance with the regulations. Monitoring of selected performance areas will be continued with emphasis being placed on identifying j
SAT process problems and assuring that they are appropriately resolved.
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