ML20149C123

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Forwards Final Rept on post-accreditation Audit of Training Programs Conducted on 860624-26.Strong Mgt Commitment to Training Improvement Exists at Facilities.Issuance of INPO Guidance Will Help to Improve Job Incumbent Training
ML20149C123
Person / Time
Site: 05000000, Salem
Issue date: 08/08/1986
From: Russell W
Office of Nuclear Reactor Regulation
To: Strahm K
INSTITUTE OF NUCLEAR POWER OPERATIONS
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ML082310270 List:
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FOIA-87-787 NUDOCS 8608190210
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  • August 8, 1986 Mr. Ken Strahm Institute of Nuclear Power Operations Suite 1500 1100 Circle 75 Parkway Atlanta, Georgia 30339

Dear Mr. Strahm:

Enclosed is the final report from the staff's post-accreditation audit at Salem conducted in June 1986.

Based on staff observation, it appears that a strong management commitment to training program improvement exists at Salem.

Also, it is apparent that there is an effort to continually update and revise the training programs and task lists based on feedback and experience.

As in most of the other programs reviewed to date, deficiencies identified through use of the NRC Training Review and Criteria and acknowledged by the utility are:

an incomplete task analysis which would identify XSAs to serve as a basis for deriving learning objectives and a failure to identify which tasks are appropriate for continuing training.

In contrast to programs reviewed at other utilities, the learning objectives at Salem were complete and easily traced to tasks and test items.

As we have discussed, I believe that NRC issuance of the final rule on Operator Licensing will result in utilities applying performance-based training concepts to continuing training (i.e., requalification training).

Your plan to issue INP0 guidance related to continuing training will help to I

improve job incumbent training.

If you have any questions about the staff's training review activities, please contact me.

l Sincerely, ori Signed By yILL f. T. BU'9 l

l l

William T. Russell, Director l

Office of Nuclear Reactor Regulation

Enclosure:

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4 POST-ACCREDITATION AUDIT OF TRAINING PROGRAMS AT SALEM A.

Introduction 1.0 Background.

On June 24 through 26, 1986, the NRC staff conducted a l

post-accreditation audit of training at Salem. All 10 of the eligible Salem training programs have received INP0 accreditation.

The Salem SRO and mechanical maintenance training programs were reviewed.

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 informed so that the materials associated with those tasks were available for review.

One additional task for each program was selected on site during the review. The remainder of the review consisted of document reviaw, interviews and interactions with both training and operations staff and management, and classroom and simulator 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 Salem and explained their approach to analysis.

The NRC review team consisted of three training and assessment specialists from NRR and two subject matter experts from Region I.

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 20, 1985.

In its Policy Statement, the NRC states that the following five elements are essential to acceptable performance-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 personnel in the job setting.

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2 4.0 Documentation.

To support its review, the NRC requested that the following types of documentation be provided by the facility:

  • 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 of training,

- Methods for keeping training programs current,

- Maintenance of training records,

- Selection of candidates for training and the granting of waivers / exemptions from training,

- Evaluation of training programs, and

- Training, qualification, and evaluation of instructors.

  • Task lists for the jobs being reviewed
  • 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 training program (s).

  • Roster / organization chart for the training organization
  • Training schedule The above documentation is the type normally associated with participation in the INP0 accreditation process.

5.0 Scope of audit.

The programs audited and the tasks selected for review within those programs were:

PROGRAM TASKS (1) Senior Reactor Operator

' Evaluate system leakage that is not covered by Technical Specifications or that is covered by Technical Specifica-tions but does not exceed the maximum permissible leak rate

  • Verify that post-maintenance retest requirements have been satisfied

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  • Align the 4ky buses to the station power transformers
  • Take corrective action for loss of coolant (2) Mechanical Maintenance
  • Test electric motors (e.g.,

megger, check amperage, rotation, etc.) on bench

  • Repair air operated valve operator
  • Withdraw in-core instrumentation thimbles for refueling reactor
  • Perform hydrostatic test on condenser / heat exchanger tubes

Results of Review The following discussion of the review findings parallels the elements of the Commission's Policy Statement on Training and Qualification.

1.0 Systematic Analysis of Jobs to be Performed l

1.1 Discussion.

Task analysis methods, procedures and products were reviewed using the documentation described in Section A.3 above to determine whether:

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  • A systematic method was used for identifying the tasks that make up job (s) being evaluated.
  • A systematic method was used for selecting tasks for which. raining is provided.
  • Tasks requiring initial training only and those requiring continuing training were differentiated.
  • Analysis of tasks chosen for training was adequate for development of learning objectives.

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  • Approved procedures are implemented so that analysis information is kept current as job perfonnance requirements change.

1.2 Findings. Tasks for the Senior Reactor Operator (SRO) position at Salem were identified using the INPO generic task listing for the control room operator (CRO) position. The INP0 generic task analysis for the SR0 position was not available at the time that Salem was generating its SRO task inventory.

The INP0 CR0 generic task list was compared to a similar plant (i.e., McGuire) CR0 task list, and was reviewed by subject matter experts and by job incumbents to derive the Salem SR0 task list.

Position descriptions, technical manuals, regulatory requirements, Technical Specifications and procedures were also reviewed and compared against the task listing.

Knowledges, skills, and abilities were not identified from a task analysis, nor was a differentiation made between tasks requiring initial training and tasks requiring continuing training. The utility stated that all SR0 tasks have the potential to be included in continuing training.

Selection of tasks for SR0 continuing training is based on regulatory requirements, Training Review Group recomendations, and results of assessment tests prior to each offering of the continuing training program.

A plant-specific task list was developed for the mechanical maintena'nce positions which identifies for training all relevant tasks derived from plant work orders.

The identification of tasks for continuing training is not done from task analysis information using information about task consequences, frequency, or decay in performance over time but is done by instructors and the Training Review Group.

Knowledges and skills have not been identified for tasks.

Procedures are implemented to ensure that the task inventories for all job positions are being reviewed and revised as appropriate, to incorporate lessons learned through operating experience, plant modifications and other changes. The Nuclear Training Review Group reviews the task inventories at a minimum of every 5 years according to procedures but the task inventory had, in fact, been recently revised (i.e., less than a year since originally derived).

The training department has created a computerized job task inventory which allows for continual updating and use of task data.

2.0 Development of Learning Objectives 2.1 Discussion.

Learning objectives were reviewed for the subject programs to determine whether:

  • There are learning objectives for each of the tasks selected for review.
  • Learning objectives are derived from or related to the knowledge, skills and abilities needed for successful job performance.

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  • Each learning objective states the job performance behaviors expected of trainees upon completion of training.
  • Each learning objective states the job performance-based conditions under which the trainee actions will take place.
  • Each learning objective states the specific. job performance-based standard for successful performance of the objective.
  • Written procedures require modification of learning objectives when related job performance requirements change.

2.2 Findings.

For both the SRO and Mechanical Maintenance programs each task selected for review was supported by written learning objectives documented in lesson plans.

The learning objectives were written to support the task statements as they appear in the Salem task inventories and, therefore, have not been derived from identified knowledges, skills, and abilities that enable the trainee to perform the tasks.

The learning objectives describe the actions, conditions, and standards for task performance.

Where individual learning objectives did not contain actions, conditions, and standards, lesson plans did include a statement specifying the general conditions and standards under which training would occur.

Learning objectives are part of the lesson plans which are reviewed by instructors prior to each course offering and are reviewed and updated as part of the periodic program evaluation performed by the training department program review group.

3.0 Design / Implementation 3.1 Discussion.

Using the documentation described in Section A.3 above, the design and implementation of performance-based training was reviewed to determine whether:

  • There is a written plan that clearly and specifically states the training organization's goals, objectives, plans and relationships with other parts of the facility's organization.

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  • Responsibilities and authority of. training organization personnel are clearly stated in writing.

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  • There are documented qualification and training requirements for the training staff that address both subject matter and instructional skills and knowledge appropriate for specific assignments.
  • 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 among learning objectives.

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  • The organization and sequencing of continuing training is based upon the relationships among learning objectives.
  • Lesson plans are available that provide for consistent training delivery.
  • 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 detemined through application of training observation checklists.
  • There are adequate methods established for maintaining training records.

3.2 Findings. The Administrative Policies Manual clearly and specifically states the training organization goals, objectives and plans.

Training department goals are evaluated annually.

Responsibilities of training department personnel are specified in the Administrative Policies Manual and programs are in place to ensure that training staff visit the plant to evaluate training effectiveness and obtain feedback.

There is currently no written procedure to ensure both technical and instructional qualification of the training staff.

However, training staff technical skills and instructional skills competence are verified during the personnel recruitment process, are enhanced or maintained through training and retraining, and are regularly evaluated. Also, new procedures governing technical and management training are being implemented for training department staff.

l General procedural guidance exists describing selection of instructional settings.

Instructional settings appropriate to learning objectives are based on subject matter and instructor expertise and are evaluated l

I through the feedback process.

For new training. programs, hands-on I

training is always preferred when feasible.

The organization and sequencing of training has been detennined by subject matter experts.

For mechanical maintenance, sequencing was detemined partially during l

l review of preliminary task lists when tasks were identified as level I, l

II, or III craft jobs. A written procedure in the Instructional l

Development Manual generally describes considerations for sequencing training material. One apparent error of training sequencing was identified for SR0 training of transients prior to systems training.

There is no formal method for determining the organization and sequencing of continuing training. Student texts are often used as the basis for topic sequencing. Lesson plans were prepared for training courses which listed learning objectives, references, training material, student handouts, and classroom requirements.

There is evidence that appropriateness of instructional materials has been evaluated and t-

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> revised to address learning objectives and trainee needs.

Plant and industry events are reviewed and included in appropriate training classes.

Classroom and simulator training, as observed, were conducted satisfactorily.

Although the system for storage and retrieval of training records was somewhat cumbersome, trainee records, class records, and training evaluations were available.

4.0 Trainee Evaluation 4.1 Discussion. The methods for and use of trainee evaluations were reviewed using the documentation described in Section A.3 above to determine whether:

  • Exemptions from training are based upon performance-based testing or other objective evaluation methods.
  • Trainee evaluation is appropriate to job performance requirements and training objectives.
  • 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 removed from associated job l

duties and provided remedial training.

  • Appropriate precautions are taken to preclude compromise of test contents.

4.2 Findings.

Exemptions from or waivers of training are allowed according to training procedures and have occasionally been granted for l

instructors. Waivers of training requirements must be approved by the station general manager or discipline manager based on an employee's I

background records or examination.

Trainee evaluations are based on written tests which are closely related to instructional objectives. Written exams for current course offerings are controlled to prevent compromise.

Trainees in the final 12 week phase of on-the-job maintenance training receive weekly supervisory evaluations which are general performance evaluations not directly related to learning objectives.

Trainees receive regular evaluations during training and receive remedial training and retesting or are removed from the program if minimum standards are not met. Job l

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. incumbents can and have been disqualified to perform certain duties if found to be deficient during evaluations and must be requalified upon successful completion of remedial training. A qualification summary report is generated for use by plant sup3rvisors to ensure assigning independent duties only to personnel who are currently qualified.

5.0 Program Evaluation 5.1 Discussion.

Training program evaluation methods were reviewed using the documentation described in Section A.3 above to determine whether:

  • A method is in place to systematically evaluate the effectiveness of training programs and to revise the programs as required.
  • Examination 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 evaluction.
  • Trainee critiques of training are used for program evaluation.
  • On-the-job experiences are solicited from job incumbents and used for program evaluation.
  • Feedback from supervisors about job performance is solicited for program evaluation.
  • Both internal and external training program audits / evaluation findings are used for program evaluation.
  • The performance of each member of the training staff is objectively evaluated on a regular basis.

5.2 Findings.

Salem has recently implemented the Performance Evaluation of Training Effectiveness and the On the Job Evaluation programs to provide feedback about job performance problems for training program t

enhancement.

In addition, an internal program review is conducted every 2 years for each training program which results in recomendations and actions for training program changes as appropriate.

The Training Related Occurrence Committee reviews Licensee Event Reports, incident reports and other lessons learned through operating experience for inclusion in training as appropriate. Quality assurance audits of training are also performed.

l Currently, no formal aggregate evaluation of trainee test performance is l

done to identify program weaknesses, but there are plans to begin such analyses to provide program feedback.

No formal instructor critiques of t

training for program review were done but instructors are responsible l

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-g-for review and modification of lesson plans as necessary prior to each Input to training program modifications is solicited course offering.

during regular informal meetings between plant staff and training department personnel.

Trainee critiques of training are formally solicited at the conclusion Trainee of training and as a 90-120 day follow-up to training.

critiques are reviewed and action plans for resolution of problems are Feedback from supervisors of trainees is developed as necessary.

similarly solicited 90-120 days following completion of training.

Follow-up training critiques are not solicited from participants in continuing training or any course less than 1 month in duration.

Training request forms are available to all plant personnel for use in recomending training changes. Training staff receive regular evaluations of their performance, including observations and individual development plan review and revision.

C.

Sumary of Findings The findings from the post-accreditation training audit at Salem indicate that comprehensive task inventories have been developed and The major used as the basis for developing good learning objectives.

weakness identified was the lack of documented knowledges, skills and abilities (KSAs) derived from a task analysis to use as the basis for Tasks for ensu' ring completeness of learning objectives and training.

continuing training were not identified from an analysis of consequences, frequency and decay over time.

The facility is clearly comitted to provide the maximum amount of hands-on training possible, as indicated by the extensive training equipment and facilities The training department is in the process of converting from available.

a cumbersome manual record-keeping system to an autwated records system and is planning to make better use of course and trir4e records for program evaluation.

Solicitation of post-traininr -

M from participants in continuing training is one import m -

St of program evaluation and feedback that is not done at Salen.

Mn vents i

interviewed were positive about the benefits of Wm 4 i..,;ng and

<s m Muing to bear witness to the fact that the training progr -

improve. A strong management comitment to trair, orcgraer.riprovement is evident at Salem.

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