ML20149B910

Submits Observations of INPO Accreditation Board 851114 Meeting W/Utils Re Plant Training Programs.Salem Electrical & Mechanical Maint Training Programs Not Ready for Review & Should Not Have Been Accredited

ML20149B910
Person / Time
Site:	Salem, Surry, 05000000
Issue date:	12/30/1985
From:	Booher H, Zwolinski J Office of Nuclear Reactor Regulation
To:	Russell W, Thompson H Office of Nuclear Reactor Regulation
Shared Package
ML082310270	List: ML20147E043 ML20147E230 ML20147E891 ML20149B547 ML20149B580 ML20149B610 ML20149B730 ML20149B865 ML20149B910 ML20149B916 ML20149C035 ML20149C100 ML20149C123 ML20149C204 ML20149C246 ML20149C262 ML20149C346 ML20149C469 ML20149C534
References
FOIA-87-787 NUDOCS 8601140591
Download: ML20149B910 (13)

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UNITED STATES 1

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'J DEC 3 01985 MEMORANDUM FOR: William T. Russell, Director Division of Human Factors Technology i

Hugh L. Thompson, Jr., Director

.j Division of PWR Licensing-A FROM:

Harold R. Bocher, Chief Maintenance and Training Branch Division of Human Factors Technology John A. Zwolinski, Director i

BWR Project Directorate #1 Division of BWR Licensing

SUBJECT:

INP0 ACCREDITATION BOARD MEETING OBSERVATIONS FOR SALEM AND SURRY On November 14, we attended the subject INP0 Accreditation Board meeting as NRC observers. The plant-training programs being presented to the Board were Public Service Electric and Gas, Salem (TECH STAFF & MGR, CHEM, RAD TECH, MECH, ELEC); and Virginia Electric Power, Surry (NLO, R0, SR0). This report describes our observations, based on attendance at the Board meeting and from independent review of documentation. Selected concerns are presented in this report regarding the accreditation process.

-l We note that previous reports by other NRC observers have been generally favorable regarding the Board's professionalism in reviewing utility programs a

'l seeking accreditation.

However, these reports stressed some important limitations to the Board activities.

For example, the Board depends to a j

great extent on the assurances of the INP0 accreditation staff that i

objectives and criteria are met.

It certainly is not clear that the Board pursues a line of questioning that allows an independent assessment of the 1

quality of the INP0 process. Also, the Board members are not able to review in great depth what the utility training program actually consists of and frequently accredits programs prior to full implementation (Persensky, June 10, 1985, and Booher, October 17,1985).

These inherent limitations combined with questions raised by recent staff reviews on post-accreditation plant visits have raised some concerns whether the five elements considered essential by the Comission are actually being met by the accreditation process.

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l William T. Russell,

4 Reports by NRC observers and staff observations during INP0 team visits to utilities applying for accreditation indicate that the initial INP0 plant visits are well executed and thorough and that training program weaknesses are generally well documented.

Further, one on one contacts with a variety i

of knowledgeable training professionals also confirm the observations contained in previous reports regarding quality and completeness of the INP0 site visit team. Particularly encouraging in the past was the fact that the INP0 team's initial plant visits seemed to identify weaknesses in utility training programs that were consistent with the original INPO published accreditation objectives and criteria (82-011).

If a utility had, in fact, j

1 implemented a training program which met those objectives and criteria, we believed it would very likely also meet the five elements considered by the NRC staff to be essential to an acceptable training program, i

s During this observation, there was the opportunity to take a critical look at the accreditation process between the time of the INP0 initial plant visit (when weaknesses and recommendations are documented) and the Board decision to accredit the training program. This opportunity presented itself because during the INP0 initial plant visit, one of the utilities (Salem) showed

'i major deficiencies on two of its training programs (Electrical and Mechanical l

Maintenance). These deficiencies, documented by INP0 in their accreditation report to the Board, were sufficiently ambiguous that the NRC staff could find that these programs would not meet the intent of the Commission's five 1

elements.

L; l j The following conclusions have been developed based on our independent l

readings and observations of both meetings:

'd 1)

Based on INP0 objectives and criteria and the information provided to the Board, it was not evident that the Salem electrical and mechanical l I lj maintenance training programs:

l, a) were ready for accreditation review by the Board, and l j b) should have been accredited by the Board.

2)

The Board appears to rely too heavily on the results of the INP0 data acquisition process and utility assurances that programs are ready for I

accreditation.

The line of questioning we witnessed did not appear to l

detennine, independently, the quality of the utility programs or of the l.

INPO review process itself.

I 3)

It is our opinion that some utility personnel training programs, l'.

particularly those which do not require licensing of personnel, especially maintenance, are being accredited based on the program to be implemented (future plans) rather than actual implemented status.

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4)

Noting the above, it is evident that INP0's and the Board's concept of "Systematic Approach to Training" is different from that of the NRC staff as endorsed by the NRC Policy Statement.

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1 In view of these concerns, we believe it to be important to continue to j

conduct post-accreditation reviews.

Should others observe like weaknesses, it would be our opinion that the number of reviews to be conducted be i

reevaluated and possibly increased to assure proper sampling of nonlicensed programs, especially those designed for personnel involved in maintenance and surveillance activities.

It does remain clear that NRC should ensure the

j proper degree of management attention to ensure programmatic succes.

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1 John. Zwolinski, Director BWR Pr ject Directorate #1 Division of BWR Licensing I

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Harold R. Bocher, Chief J

Maintenance and Training Branch Division of Human Factors Technology E

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t MEMORANDUM FOR: William T. Russell, Director Division of Human Factors Technology 4

l Hugh L. Thompson, Jr., Director Division of PWR Licensing-A i

i FROM:

Harold R. Bocher, Chief Maintenance and Training Branch i

Division of Human Factors Technology John A. Zwolinski, Director BWR Project Directorate #1

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Division of BWR Licensing

SUBJECT:

INP0 ACCREDITATION BOARD MEETING OBSERVATIONS FOR i

SALEM AND SURRY On November 14, we attended the subject INP0 Accreditation Board meeting as i

NRC observers. The plant training programs being presented to the Board were i

Public Service Electric and Gas, Salem (TECH STAFF & MGR, CHEM, RAD TECH, MECH, ELEC); and Virginia Electric Power, Surry (NLO, R0, SRO). This report l j describes our observations, based on attendance at the Board meeting and from independent review of documentation. Selected concerns have been raised with

!i the accreditation process that apparently were not evident during previous l

NRC Board observations.

Previous trip reports by NRC observers and staff observations during INPO team visitt, to utilities applying for accreditation indicate that the initial i

INPO plant visits are well executed and thorough and that training program weaknesses are generally well documented. Further, one on one contacts with 1

a variety of knowledgeable training professionals also confirms the observations contained in previous reports regarding quality and completeness of the INPO site visit team. "articularly encouraging in the past was the fact that the INPO team's initial plant visits seemed to identify weaknesses

.i in utility training programs that were consistent with the original INPO published accreditation objectives and criteria (82-011).

If a utility had, in fact, implemented a training program which met those objectives and criteria, we believed it would very likely also meet the five elements considered by the NRC staff to be essential to an acceptable training l

program.

I Previous trip reports by NRC observers have also been generally favorable regarding the Board's professionalism in reviewing utility programs seeking accreditation. However, these reports also stressed some important limitations to the Board activities.

For example, the Board depends to a great extent on the assurances of the INPO accreditation staff that

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objectives and criterie are met.

It certainly is not clear that the Board pursues a line of questioning that allows an independent assessment of the Also, the Board members are not able to review quality of the INP0 process.

in great depth what the utility training program actually consists of and frequently accredits programs prior to full implementation (Persensky, June j

10, 1985, and Bocher, October 17,1985).

.i These inherent limitations combined with questions raised by recent staff reviews on post-accreditation plant visits have raised some concerns whether the five elements considered essential by the Commission are actually being

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met by the accreditation process.

During this observation, there was a unique opportunity to take a more critical look at the accreditation process between the time of the INPO initial plant visit (when weaknesses and recomendations are documented) and 4

the Board decision to accredit the training program. This opportunity presented itself because during the INP0 initial plant visit, one of the j

utilities (Salem) showed major deficiencies on two of its training programs y

(Electrical and Mechanical Maintenance). These deficiencies, documented by 1

INP0 in their accreditation report to the Board, were cf such an extent that NRC staff could find that these programs would not meet the intent of the Comission's five elements.

l The result of the Board meeting - i.e., accreditation of all programs i

proposed by the two plants - was discouraging and causes several concerns (addressed in more detail in the enclosure):

Based on INP0 objectives and criteria and the information provided to 1) the Board, it was not evident that the Salem electrical and mechanical j

maintenance training programs:

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.l a) were ready for accreditation review by the Board, and j

b) should have been accredited by the Board.

2)

The Board appears to rely too heavily on INP0 and utility assurances that programs are ready for accreditation. The line of questioning does not appear to determine independently the quality of the utility programs or of the INPO review process itself.

i It appears that some utility personnel training programs, particularly i

3) those which do not require licensing of personnel, especially maintenance, are being accredited based on the program to be implemented (future plans) rather than actual implemented status.

Because of the above, it is evident to us that INP0's and the Board's 4) concept of "Systematic Approach to Training" is significantly differentIn from that of the NRC staff as endorsed by the NRC Policy Statement.

particular, the importance of the logical sequence of the elements, i.e., completing the analysis and learning objectives steps before design and implementation, seems to be missed.

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In view of these concerns, we believe it to be very important to continue to conduct post-accreditation reviews. Should this pattern continue and the general perception evolve that the accreditation process is superficial in nature, it would be our opinion that the number of reviews be increased to assure proper sampling of nonlicensed programs, especially those designed for j

personnel involved in maintenance and surveillance activities.

1 i

s John A. Zwolinski, Director BWR Project Directorate #1 Division of BWR Licensing I

Harold R. Booher, Chief Maintenance and Training Branch Division of Human Factors Technology

Enclosure:

i Detailed Comments i

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i Enclosure i

INP0 ACCREDITATION 80ARD MEETING NOVEMBER 14, 1985 I

DETAILED COMMENTS 1-i i

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Salem Electrical / Mechanical Training Programs t'l The chronology for INPO Accreditation of the Salem Training Programs (TECH STAFF & MGR, RAD TECH, CHEM, MECH, ELEC) is as follows:

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INP0 Plant Visit Sept. 9-13, 1985

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9 Accreditation Report -

First Oraft Oct. 4, 1985 I

Utility Response Oct. 30, 1985 3

Board Meeting Nov. 14, 1985 N

t The INP0 final Accreditation Report, the Utility Self-Evaluation Sunnary d{ '

Report, and the Utility Response to INP0 reconnendations were reviewed on November 13, 1985, the day before the Board Meeting.

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RESULTS OF INP0 PLANT '!! SIT A

The initial INP0 plant visit on Sept. 9-13, 1985, found the following major deficiencies in meeting accreditation objectives and criteria for a

the electrical and mechanical programs.

Objective 4:

The tasks required for competent job performance are identified, documented, and included in the training programs, as appropriate, The job analysis for the electrical aM mechanical job positions was not complete; consequently, all tasks required for competent job perfomance had not been identified, documented and included in the training programs.

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i-Under Objective 4, INP0 stated that "significant" tasks were missing from the electrical and mechanical task lists for which there was no 1

There is no mention of how many significant training program coverage.

tasks were missing under Objective 4, but under Objective 5 the following statement appeared:

"The Salem-identified tasks were compared to an INPO ' tasks important enough to be analyzed' listing, and 45 per

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cent of these INPO tasks were not identified in the Salem listing."

INP0 also made a statement under Objective 5 which applies to 4

Objective 4 as well:

"The task list and resultant skills and knowledges l

taught is of a reactive nature which only identifies the skills and knowledges that have been required.

It doet not identify the skills and knowledge that may be required by the maintenance personnel in the immediate future."

Objective 5: Training program content provides the trainee with the l,5 knowledge and skills needed to perform functions associated with the I,

position for which training is being conducted.

The training program content which needed to be completed depended on

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f, the development of an accurate task list, and task analysis of those "significant" tasks missing under Objective 4 I

Objective 6: Learning objective that identify training content and define satisfactory trainee performance are derived from job performance recuirements.

No learning objectives were provided because the job analysis was not complete.

INPO made no recomendations but referred to the problem raised under Objective 4

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Objective 7: Lesson plans or other training guides provide guidance and structure to ensure consistent conduct of training activities.

INPO raised the following problems:

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i Lesson plan content exceeded the scope of lesson objectives.

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Lesson plans did not identify instructor activities.

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Lesson plans used for combination classroom and laboratory j

instructor did not include objectives and completion criteria for the 1

i laboratory exercises.

Content of the lesson plan / laboratory exercise did not address the' l

laboratory training.

! :i l 'i Objective 9:

In plant training or on-the-job training (0JT) is

!.i effectively presented, and trainee performance is evaluated i

1 I 1 consistently.

INP0 identified the following problems:

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OJT qualifications cards may not include all job-related tasks.

I j Specific tasks were not identified for each job position.

Specific performance criteria for task qualification was not i

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Specific direction was not provided to OJT evaluators to ensure the 1

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OJT was implemented in a consistent manner.

4 Evaluation methods were not in place to evaluate the effectiveness l

of the OJT program.

B.

UTILITY RESPONSE, INP0 RESOLUTION, AND BOARD QUESTIONS The utility response, INPO resolution and Board questions to arrive at the accreditation decision were as follows:

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i Objective 4: The statement by INPO to the Board for resolution of job l

analysis and task identification was:

"The job analysis for the mechanical and electrical maintenance area has l

been revised. A list of program materials that require revision has

.I been developed.

INP0 staff requested that a revision schedule be 1

provided with the utility responses."

The utility maintained that 95% of their training materfals supported the training program and the remaining 5% would be completed by June 1986.

In the material provided to the Board and in the discussions which followed, INP0 did not clarify how they resolved which "significant" tasks were missing. The team leader mentioned "a couple" I

of tasks were missing. One of us (Bocher) raised a point of clarification on the apparent discrepancy between the 45% of INP0 tasks

-i not identified and the 5% mentioned by the utility. The answer j

presented by the INP0 team leader was that INPO's task list did not match Salem's task list because of the way the tasks were named.

The 1

utility now claims to have 100% of the tasks identified. No questions were raised regarding the issue identified by INPO under Objective 5 it {

about not identifying "skills and knowledge that may be required by the l

maintenance personnel in the immediate future."

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Objective 5: There was no discussion regarding adequacy of training program content since INPO made no recommendations regarding the content l

itself. Again no questions were raised about the utility not identifying "skills and knowledges that may be required by maintenance personnel in the immediate future."

Objective 6: There were no recommendations nor Board questions regarding whether there were any learning objectives under preparation 1

or if there was any schedule to be met.

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i Objective 7:

INP0's statement to the Board was: "The electrical maintenance lesson plans have been reviewed by the Salem training staff 1

and a matrix for training material revision has been developed. The

-i INPO staff reviewed several of the revised lesson plans."

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w In the utility's response of Oct. 30, 1985, sample 3 of lesson plans i

j were provided and the statement made that 10% had been revised. The Board asked no questions regarding adequacy of lesson plans and why so j

few were in place.

INP0's statement to the Board was: "The maintenance Objective 9:

qualification card has been revised to include all appropriate tasks.

Tasks have been identified by job position and performance criteria I:

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established for each task.

Procedural controls are in place for implementation of the 0JT program and instruction is scheduled for each

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OJT trainer."

1 The Board asked no questions regarding problems originally raised by

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INP0.

1 C.

SPECIFIC CONCERNS OF NRC OBSERVERS i

It is not evident how the Salem programs in electrical and mechanical i

maintenance training were ready for accreditation in view of the major

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deficiencies reported to the utility only 6 weeks earlier. The job analysis was incomplete, significant tasks were not clearly identified,

[J no learning objectives were provided, lessons plans were inadequate, and there were major problems with the OJT program. Although the utility provided examples and procedures to demonstrate they knew how to do

'l these activities, there was no pretense of having a fully implemented program.

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1, It is not evident how the Board could have accredited the electrical and t

maintenance programs unless programs can be accredited well in advance f

j of full implementation. No questions were asked about how the glaring j

discrepancies were resolved in such a short period of time. No questions were raised about how it was possible to have 95% of the 2

training materials complete when acceptable learning objectives and j

lesson plans were essentially nonexistent. No questions were r.sked about how the objectives of OJT, for example, could possibly be met when i

the OJT program described in the October 30, 1985, response could only have been in place a few weeks. How could INP0 and the Board know, since the program was just initiated, that 0JT is "effectively presented" and trainee performance is "evaluated consistently?"

,i Since there were still major holes in the electrical and mechanical i

,j programs at the time of accreditation, it was evident that the Board's i 'I approval must have been based on INPO and/or utility assurance that the The j

programs would be effectively implemented sometime in the future.

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.l accreditation of these programs was not conditional, however, upon satisfactory demonstration at some future date, l

II. General Concern j

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In view of the above, we have a general concern that the Board does not

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l fully appreciate what is meant by a "Systematic Approach to Training" I

(SAT). The conventional understanding of SAT is that the elements lq considered essential to an acceptable training program are pursued in a logical sequence. The job analysis must be done before the task analysis, from the task analysis the learning objectives are developed, and the training delivery system is developed from the learning To backfit an existing program by tracking from a task list objectives.

I to existing training materials, then go back and fill in the analyses to match the program already in place defeats the logic of the systems l

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f approach and is ng consistent with the Commission's Policy Statement.

It would appear that taking the time necessary to fully develop programs j

that truly implement the systems approach prior to granting

'I accreditation would be more appropriate.

It appears that INP0 and the Board use no benchmarks for determining differences in degree of implementation or completeness of systematically derived training 1

With no such distinctions being made and no conditions programs.

J proposed for the accreditation decision, there may be a tendency for l

industry progress to be forestalled by the Board's approval of incomplete programs.

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