ML20149C204
| ML20149C204 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie, Crystal River, Duane Arnold, 05000000 |
| Issue date: | 11/07/1986 |
| From: | Rowsome F Office of Nuclear Reactor Regulation |
| To: | Persensky J, Russell W Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML082310270 | List: |
| References | |
| FOIA-87-787 NUDOCS 8611170042 | |
| Download: ML20149C204 (22) | |
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UNITED STATES
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' NUCLEAR REGULATORY C' MMISSION j *[h.,
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NOV 7 1986 MEMORANDUM FOR:
William T. Russell, Director Division of Human Factors Technology Julius J. Persensky, Section Leader Personnel Training Section Maintenance and Training Branch Division of Human Factors Technology FROM:
Frank H. Rowsome, Chief Human Factors Issues Branch Division of Human Factors Technology
SUBJECT:
OBSERVATIONS ON THE INP0 TRAINING ACCREDITATION BOARD MEETING 0F JULY 23 AND 24,1986 I attended the INPO Training Accreditation Board meetings on July 23 and 24, 1986, as the NRC observer.
The training programs under review for accreditation were-for the non-licensed operator (NLO), R0, and SR0 positions for Duane Arnold (Iowa Electric Light and Power), Crystal River Unit 3 (Florida Power Corporation), and St. Lucie Units 1 and 2 (Florida Pcwer and Light).
The Accreditation Board was composed of Forrest Remick Chairman),
4 1
John Griffin, Ed Jones, William Kimel, and Don Schnell absent for St. Lucie).
In addition to the INP0 team leader who presented the results of the staff evaluation, INP0 attendees included Ken Strahm and Walt Coakley.
i Additional INPO staff members were non-participant observers:
Wayne Hollinger, Phil McCullough, Ron Ceravolo, and Walter Popp.
In each case, the INP0 team leader gave an introduction to the Board before the utility representatives were invited in. This entailed background l
information on the plant, the utility organization, the history of the training upgrade effort at the facility, and the experiences of the INP0 team in their assistance / evaluation trips to the facility. The Board directed a number of questions to the INPO team leader on these subjects.
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Next, the utility representatives were invited to join the meeting. These included one or two vice presidents, a senior manager from plant operations, the manager in charge of training, and the training specialist.
Following the introductions, the INP0 team leader went through the sumary report section by section. These were organized along the lines of the criteria in "The Accreditation of Training in the Nuclear Power Industry," September 1985, criteria, INP0 85-002, Revision 1.
In each case, all the Board members participated in asking questions; some were fielded by the INPO team leader, some by the utility representatives, and occasionally by Ken Strahm or Walt Coakley.
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- I Multiple Addressees NOV 7 1986 Enclosed are the agenda, notes on each case, the organization chart for each utility, and INP0 hand-outs on:
"Assist Visit (mini-evaluation) Criteria,"
and "SER [Self Eveluation Report] Review Tracking."
My general observations follow:
1.
All three utilities have clearly committed the resources and made the organization changes necessary to develop an excellent training program.
1 All have staffed up, all have invested in upgrading the curriculum and established diverse and redundant feedback loops to verify that the training is effective, all are building greatly enlarged training facilities, and have plant-referenced simulators on order.
2.
In each case, the Self Evaluation Report prepared by the utility against INP0 criteria were of material value to the utility in identifying deficiencies. This was particularly true of the two utilities that submitted after the Revision 1 INP0 guide was available, and less true of FPC whose filing preceded the detailed INP0 criteria.
3.
In each case, the INP0 assistance / evaluation teams were thorough in their search for additional deficiencies, had been of material value to the utility in upgrading the training program, and were thoroughly familiar with the current status of the training program.
4.
Forrest Remick twice expressed the concern that the INP0 writeup on each lii:ensee's training evaluation was hard for the Board to use to make up its own mind, although it is an effective summary of the INPO staff review.
I, too, had the same feeling in reading the reports'the night before.
Impressionistic evaluation is lacking.
b 5.
In each case, all the Board members were active in asking questions and had clearly read the material.
They seemed highly conscientious and serious about their accreditation function. They displayed a high level of respect for the INP0 staff evaluations, but I felt this was deserved and appropriate.
6.
The process seems to be a thorough check on whether the institutional, administrative, and procedural machinery is in place for a sound training program.
I think it highly unlikely that a training program with significant deficiencies would be accredited.
In one case, FPC, the training program required four assistance / evaluation trips by the INP0 staff team, and the upgrading to INP0 standards had apparently been a long and painful process on both sides. Nevertheless, both the INP0 staff documentation and the Board meeting convinced me that FPC now has a sound training program and that the few residual areas for improvement identified and plans and resources in place to finish the job.
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Multiple Addressees g7 1986 i
7.
Checks and balances to assure that the training content is appropriate and that the training is effective received a great deal of attention -
for routinely used job knowledge and abilities - by both the INP0 team and the Board. However, the training depends upon plant procedures to I
identify rarely used skills and abilities. This is a serious weak spot in the program.
It is not only possible but quite likely that knowledge, skills, and abilities that are needed only in multiple failure or severe accident contexts will not be picked up in tne training objectives.
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8.
INPO and the Board did pay some attention to experience feedback:
assuring that lessons of operating experiences are fed back into i
training objectives. However, I am not convinced that this was probed deeply enough to assure that it, too, is not a weak spot.
Following the third and last Board meeting, the Board solicited my coments.
I summarized the points abcve and added several more. My experience with availability engineering, risk analysis, and cost / benefit analysis lead me to doubt that these training upgrades will prove to be cost effective, particularly in light of the costly new training facilities and simulators.*
It appears that they are gold-plating all aspects of training without discriminating which elements of the skills and abilities warrant focused i
attention.
I believe it is well within the state of the art to use PRA, systems engineering, availability engineering, and human factors engineering to make a discrimination of those aspects of job knowledge warranting focused attention. The result could cost less and give much better assurance that the severe accident and experience feedback weak spots do not harbor serious deficiencies in training.
i Ken Strahm jumped in to defend the program. He reported that they had started down the path I was suggesting, but had concluded that:
(a) the necessary training infrastruc'.are was not there and needed to be developed, and (b) that discriminating what is really worth thorough training proved to be too difficult. He acknowledged the weak spot in depending upon procedures to identify training objectives for rarely used skills, and indicated that once the accreditation program is complete, i.e., the training infrastructure in place, they (INPO) mean to tackle the problem of upgrading procedures and the skills and abilities catalogs.
l In order to fill the weak spot associated with learning objectives for I
multiple failure and severe accident scenarios, I suggest two sources of The Board had asked the ranking vice presidents of two of the candidate utilities whether they felt that the training upgrade would be cost effective. Both said yes.
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Multiple Addressees 4-NOV 7 1996 i
perspective on the necessary training content be employed.
First, for generic perspectives, the risk-dominant accident sequences from PRAs and precursor studies should be employed. For a plant-soecific refinement, I suggest the Individual PlanfEvaluations (under discussion between IDCOR and the NRC as partial fulfillment of the Severe Accident Policy) be employed.
With these generic (and plant-specific) catalogs of risk dominant accident sequences in hand, a multi-disciplinary team composed of:
(1) experts on the systems end of PRAs, (2) operations and systems experts, and (3) human factors experts can translate the classes of important accident scenarios into critical areas for the refinement and extension of both emergency t
operating procedures, knowledge and ebilities catalogs, and learning objectives.
I suggest that this be done twice - once generically, perhaps by vendor owners groups - and once again with plant-specific material based on the IPEs. The results would be of immense value at many levels, ranging from new insights into shift staffing and the strengths and weaknesses of MMI, etc. to the other extreme: cataloging the scenarios and circumstances in which the pattern of symptoms may appear to warrant an operator action that would really be counter-productive.
If we can make substantial progress in nailing down these highly risky scenarios, then we can - at long last - truly have a basis to identify what needs focused attention in emergency operating procedures and training.
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Frank H. Rowsome, Chief Human Factors Issues Branch Division of Human Factors Technology l
Enclosures:
1.
Agenda 2.
Board Notes (3) 3.
Organization Chart (3) 4.
"Assist Visit Criteria" 5.
"SER Review Tracking"
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ENCLOSURE 1 NATIONAL NUCLEAR ACCREDITING BOARD July 23, 1986
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i 8:00 a.m.
Co ffee, juic., and doughnuts i
INPO Board Room (1505) 8:15 a.m.
Opening remarks by the chairman pro tem Forrest Remick 8:30 a.m.
Sta ff discussion Ron Fritchley l
6:45 a.m.
Board review of Ouane Arnold Energy i
Center's training programs:
Forrest Remick MLO - non-licensed operator RO - reactor operator SO - senior reactor operator / shift supervisor srA - shift technical advisor I
o INPO Team Manager presentation Ron Fritchley o Iowa Electric Light and Power Company's presentation
- Richard McGaughy, Manager, Nuclear Generation Division 4
- Dan Mineck, Plant Superintendent - Nuclear
- Gary VanMiddlesworth, Training Superintendent
- Bob Tucker, Staff Instructional Technologist 10:45 a.m.
Board deliberations l
11:30 a.m.
Lunch and Accrediting Board Business 12:30 a.m.
Staff Discussion Ashley Emin 12:45 a.m.
Board review of Crystal River QM Unit 3's training programs:
Forrest Remick
- non-licensed operator
- licensed operator
- licensed operator requalification o
INP0 Team Manager presentation Ashley Emin Florida Power Corporation's pr'esentation o
- Wally Wilgus, Vice President, Nuclear Operations
- Paul McKee, Nuclear Plant Manager 4
- Larry Kelly, Nuclear Operations Training Manager
- Steve Blake, Nuc' lear Non-licensed Operator Training Supervisor
- Dave Watson, Nuclear Operations Training AcaAmic Specialist
?:45 p.m.
Board deliberations 3:30 p.m.
Information update 4: 15 p.m.
Adjournment / Van leaves for Waverly Hotel 6:00 p.m.
Meet in the Waverly Hotel lobby to go to a local restaurant for dinner
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I RATIONAL NUCLEAR ACCREDITING BOARD T fhkf-July 24, 1986 I
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Coffee, juice, and doughnuts i
.INPO Roard Room (1505) i 8:15 a.m.
Opening remarks by the chairman pro tem Forrest Remick 8:30 a.m.
Staff discussion Ashley Erwin 1
-j 8:45 a.m.
Board review of Saint Lucie Nuclear 1
Power Plant's training programs:
Forrest Remick
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- non-licensed operator l
- reactor operator
- senior reactor operator / shift supervisor
- radiological protection technician I
o INPO Team Manager presentation Ashley Erwin o Florida Power & Light Company's presentation i
- Joe Dickey, Vice President, Nuclear Operations
- Bill Waylett, Manager, Nuclear Training
- Ken Harris, Site Vice President, St. Lucie
- John Barrow, Operations Superintendent
- Pat Fincher, Training Superintendent 10:45 a.m.
Board deliberations t
11:30 a.m.
Lunch 12:15 p.m.
Van leaves for Atlanta Airport t
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ENCLOSURE 2 y
i NOTES ON THE 1
INP0 ACCREDITATION BOARD REVIEW u
i FOR
.i' OUANE ARNOLO, IOWA ELECTRIC i
Note that these items are merely highlights of particularly interesting questions. They represent a small percentage of the board discussions, j
INP0 staff spokesman: Ron Fritchley i
l Iowa Electric is building a new training facility and has ordered or is evaluating bids with the intent to order 3 plant-specific simulator.
McGaughy [ pronounced Ma-Gaw-hee] is the equivalent of the VP-Nuclear at most utilities: the ranking manager with all-nuclear responsibilities.
Board question on selection testing - A: Very little.
Iowa's "Training System Development Manual" is exceptionally good and very plant-specific.
Iowa personnel invited in:
Roughly ?.0 people / year enter the NOL-RO-SRO up and out pipeline.
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Iowa has not had difficulty finding applicants to meet their requirement
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for one college year of physics, chemistry and calculus. Most have two to three years of college.
Iowa doesn't use selection tests; they considered it but couldn't validate them.
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Iowa asserts 90+ percent pass rate on NRC licensing exams.
Never had to fire anyone but they have the capability in the contract.
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Drop-outs absorbed in the company elsewhere.
BQ: Effect of fitness-for-duty on selection? A: No problem thus far.
Self-study packages include programed learning manuals.
i BQ: Team or individual training? A: Both - everyone trained individually but simulator time is as a team.
BQ: Off-shift requal? A: One shift per month to keep current for operators not on shift.
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BQ: Feedback from plant operators and experience? A: Operators and instructors have good rapport; lots of cross-talk.
- i Iow has Corporate Goals, e.g., mini"1ze cost to the consumer, minimize
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thr need for new production faciliti s, and Nuclear Goals, e.g., reduce Lj derendence on contractor personnel, get INPO accreditation, etc.
.j-No questions on job task analysis.
Diagnostic and team training used to be done after simulator training, now done tefore.
None of the Iowa representatives could come up with good examples of the feedback into training of NRC requirements or operating experiences at other plants.
Upgrading learning objectives, content outlines, and instructor guidelines for simulator training.
Upgrading remedial training.
Tech Specs preclude things like hands-on practice on resetting overspeed trips of turbine-driven pumps for training.
Overall impression: Both Iowa and INP0 think that their training program was unusually good to begin with, and the upgrading for INP0 accreditation particularly easy, due - in large part - to an Iowa connitment to excellence in training from the outset.
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CRYSTAL RIVER 3, FLORIDA POWER CORPORATION I
i'i Note that these items are merely highlights of particularly interesting
- i questions. They represent a small percentage of the Board discussions.
INPO team leader: Ashley Erwin d
SER May 1984; first visit April 1985.
i Erwin has been working on CR-3 tor some time.
INP0 site evaluation found records too poor to evaluate.
L NRC found problems with document audits; 70 percent failure rate for 3
requal exams in 1984 or 198f.
Training manager and deputy replaced in early 1985 by FPC; Kelly and Blake are new.
Plant evaluation in the spring:
Favorably impressed with operations.
Ken, Walt, and Ashley all report major improvement, lots of effort, and full comitment from Wilgus.
I Massive FPC effort to upgrade records and procedures. Authorization to hire fine new instructors (10-15) just issued.
a Comitment to a plant-specific simulator.
Old (1984) Self Evaluation Report is out-of-date, prepared before INPO criteria. SER would not be acceptable today but INP0 does not require l
rework of SER.
FPC personnel invited in: Wally Wilgus, Vice President Nuclear Operations; Paul McKee, Plant Manager; Larry Kelly, Training Manager of Nuclear Operations; Steve Blake, Training Supervisor for NL0s (acting for L0s as
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well); Dave Watson, Nuclear Operations Training Academic Specialist.
OIA investigation on lack of backup for training claims for R0/SR0 l
candidates discussed.
l FPC attributes high requal failure rate in 1984-1985 to preparation for essay questions: all who failed did so on written, not walk-through, predominantly those whose training was pre 1979. Not prepared for l
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3 multiple choice exams. Trainers did much better on exam. Since then, FPC has had all their R0s and 50s who hadn't just been licensed or passed a requal exam take an NRC requal exam.
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Three assistance / evaluation team visits to FPC sinca original April 1985 i
visit; most recent June 1986.
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'l CR-3 has a "check operator" who gives walk-through exams, requals. He 9}
also provides feedback to training on what is changing ir the plant and feedback on training effectiveness.
McKee has a good story on procedures. Based on ATCG plus observations of i
operators on the simulator. Claims they are well-human-factored; proud of I
them.
McKee is also proud of their SPDS.
Claims its a good one. They had it in i
1980 and used it during their NNI bus fault event in the spring of 1980.
They use it in all modes of operation including startup and shutdown.
STAS filter operating events at other plants, etc., to determine which should go into training.
General impression:
FPC really does seem to be trying hard to establish excellence.
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i ENCLOSURE 2C 1
1 NOTES ON THE INP0 ACCREDITATION BOARD REVIEW I
FOR 4
f ST. LUCIE, FLORIDA POWER AND LIGHT i
i Note that these items are merely highlights of particularly interesting questions. They represent a small percentage of the Board discussions.
INP0 team leader: Ashley Erwin.
March 1986 team visit.
New training building and simulator under construction, i
i FP&L invited in: Joe Dickey, Bill Waylett, Ken Harris, Pat Fincher, and i
John Barrow.
Continuing training: rarely practiced emergencies, plant changes -
1 upgraded.
FP&L employs Systems Approach to Training: redundant feedback loops on training content and effectiveness, l
Board questions on requal and continuing training, SAT feedback. loops, l
certification, continuing training for instructors. Good FP&L answers.
l INP0 team worked with FP&L to upgrade OJT, training objectives, training effectiveness feedback, operating experience feeaback into training, etc.
Remick Q: Containment venting for core melt? Fincher A:
E0Ps cover hydrogen purge - claims it is applicable.
Such E0Ps covered in both initial and continuing training for SR0s.
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Continuing training includes backfitting of upgrades to initial training.
FPAL says they used one of our NUREG/CR reports to transplant airlines i
know-how about "team involvement," continuing training, and simulator training.
FP&L volunteered that they use INPO NPRDS data to construct scenarios for training exercises, atta boy from Board.
FP&L's goal is to have the best-managed nuclear program in the industry.
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.t Overall~ impression: FP&L is confident, proud, but still occupied with selling-their excellence. No one turned up evidence that they have missed
' something. They appear to be in better shape than FPC, but not so good as Iowa.
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q ENCLO3URE 3 I
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CRYSTAL RIVER ORGANIZATIONAL CHART d
l Vice President
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Nuclear Ooerations i
Wallv Wilom I
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Nuclear Nuclear Operations j
-Plant Manager Training Manager tarry velly Paul McKee 5
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Plant Operations Nuclear Non-licensed Nuclear Licensed Manager Operator Training Operations Training Supervisor Supervisor Steve Blake i
j Operations Instructors Instructors Superintendent I
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Supervisor Nuclear 1
Nuclear Operations Technical Training
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Specialist i
Dave Watson
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Y DUANE ARNOLD ORGANIZATIONAL CHART E. :
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tagineers Asst. Psamt Seset. - Operations Italalag Sept.
f-and seelatemance Garv VanMisidlesworth
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Adv 8 ser a Superviser Statt aest.
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LIcassed operator Iratalog ma-3 tramad Operator Tralelag l
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ST. LUCIE ORGANIZATIONAL CHART
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touclear Operations Eclear Trafalag I
Joe Dickey Bill Waylett l
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a ENCLOSURE 4 8
Assist Visit (mini-evaluation) Criteria T,
i 1.
Has the utility developed a list of tasks selected for training based on a
,j thorough job analysis?
2.
For existing programs, has the utility compared its existing materials to I
the tasks selected for training?
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Has task analysis been performed on those tasks where existing materials
'l did not provide adequate training of the task? How much to do? Done l
when?
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4.
Have learning objectives at least one level of detail below the task statement been designed for the complete program?
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5.
Has the utility completed the upgrade of its existing training materials i
based on the comparison done in 2 above? If not, when is this scheduled for completion? How much work remains to b'e done?
6.
For programs with new materials, has the utility established a development plan to complete materials prior to the next scheduled implementation using these materials? What is the target date for completion? How much work remains to be done?
7.
If mostly new programs, has some part of each program been taught in each training setting (classroom OJT, etc.)? How much? When will the new materials be implemented?
8.
Has the utility developed and fully implemented its training systen procedu res ? How much?
9.
Has the utility used its feedback mechanisms to evaluate program effectiveness and make improvements where needed? How much?
- 10. Have all weaknesses or major deficiencies identified during the self-evalulation been corrected or have adequate action plans been established to correct these deficencies in a timely manner? What are they?
11.
Are there major activities to be performed not listed above?
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SER REI//EW TRACK /HG 1
SER I
RECEIVED a
SER REVIEWERS (SELF-EVALUATICS REVIEW ASSIGNED j
ASSIGSMENT FORM) t i
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REtIEW (SELF-EVALUATION REPORT CCMPLETED 4
RF. VIEW FORM) i 5/
REVIEW FORM T0 i
ASSIGNING I.
SECTION MANAGER st REVIEW FORM TO
- g' PROJECT GROUP COORDINATOR MANAGER-FOR THE l
APPLICABLE PLANT
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Requests for REVIEW FORMS T0 additional (SER RECOMMENDATION FORM)
DEPARTMENT MGRS information FOR APPROVAL orletters noting preliminary status I
to be initiated by D
coordinator (SER APPROVAL /
l PRELIMINARY FORM)
FINAL PREL':'. ; NARY h
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i SELF-EVALUATION REVIEW ASSIGNENT To:
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.i You have been assigned to review the following self-evaluation report:
1;t-Pl ant /Util ity Programs N
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T Type Review:
Systems Pro grams Coordinator
_. 3 Other Reviewers t
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-j (1) Obtain a copy of the SER from the appropriate shelf.
..f (21 Compl ete the attached SER Review form.
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Forward the SER Review form to your section marsger.
i (4)
If the assignment cannot be completed by the excected date, please contact your section manager.
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t F1 Systems SELF-EVALUATION REPORT REVIEW
SUMMARY
or (Form also to be used to review additional requested information) Programs ([]
I Review the self-evaluation report using the applicable Accreditation Objectives and Criteria (INPO 85-00?, Rev.1). Provide weaknesses and information needs as appropriate below with any additional comments attached.
l Complete SER Review Worksheet and attach to this sheet.
1l Recommenda tion:
. -l Reject as preliminary
["_]Schedul e assi st visit l
((] Schedule team visit 1
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Comments :
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Review completed:
1 Date Revi ewer Date Section Manager j
Following Section Manager concurrence, farward forms to Project Group Leader.
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PIIOCitAptS tes,II,5,A,I,t:,pe,t*,es,T) t-l2 1.
Is.e s s he ot ilit y developed a list of tasks selecteel t'
fue e s aisii n.3 tease.1 oss a t hor nisyh lots analysis ?
p i
ros cuisein.: pr ois r ams, has t he ut i l i t y compa r ed l eis c a s s t e ng ama t e r i a l s t s: the tasks se lec t est for t r a i r i n<3
- J l
.in l enrlieded a m.it ia in the SFR?
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t.
A.
flas t ask analysis ineen per forsned ora those tasns k
i sehese esistines materials did not pr oviale i
I
.n=le-esisa t e t r ai siin.3 of the task?
ft.
9os new prewgrans, has the utiIity desivined j'
t..o.s, T.O.s, JPMs, etc. to show how new a
l r.aterials wese developed 1:4 sed oss f lic tasks l
selected for t r.ninines ?
['
7 1
hi 4.
II.e s the ist i l i t y coseplet ed t he ugwarade of its existinas eeainen: ma s ce 6 a l s 1.ase.1 swa t he canapar ison ehme i ra
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2 annove?
f 8.
frsson Plasts 2.
NIT materials g.
1.
8.41 (;is ides
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4.
S imes I a t or a:n i.tes
- n.,
L onher sea t c : 1.s I s h.
I*
L ror pr09: aos uswte:
evision, has t see.A i I i t y f
est atslished a develogeent plan to complete mat er ials
[
prior t o t he ne m t scheduled program usise<l t hese i
mat er ial s?
9
- [ -
- s.. seas t he ut ility developed and fully laipl esment ed its t r a i ni swg systeen procedures ?
7.
Bl.a s t he ut ilit y est.itelisheit and isep t emen t eel t o eva t sate prewgr am f ee.tl. ark perhanisms i
cf f cet iveness and make improvementa where
,s..ei d,
r it.
Itave all weaknesses or major deficiencies ident i f sed dur isul the self-evaluation tseen corecceed or have adeslisat e act iori plans licen I
ese.it. fished to co rect these deficiencies in t e s c I y manne r ?
a 3
fiased on yoner review of this final SER, do you t h.it t his ut Ality is pacpared to acceive an Arr r ed s t a t ioen Team Visi t ?
1 e
t'osionent S on hack i
e
y a dac x. 1.a.-. =..au. w w,G wiu b e.J M....
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I:{,l.
SER RECOMMENOATION
- l
.4-TO:
, Department Manager 1
FROM:
, Project Group Leader Plant I
Coord ina tor Pro grams N
R S
A I
E M
C H
T
- 4 Y
Reviewers:
-lj Programs
.i t
l Systems The following recomendation has been made by the Training Programs and Training Systems reviewers concerning the above mentioned SER(s).
[ Reject as Preliminary l
Schedule Assist Visit
[ Schedule Team Visit Coments/ Weaknesses:
.i
]
d t
i i
Attachments:
Training Programs Review Sumary Training Systems Review Sumary
.1
\\ w:waab.::-
=2auu. a.:ucut.aJwa
.u.ai...-.
a..... :.a..... a.... w.
d SER APPROVAL
't 2!
Comments :
'l i
i App rova '. :
4
'3
-l Training Programs Departnent Manager
-4 b.
.I I
ii Training Systems Department Manager i
PRELIMINARY SER Actions Required:
a i
d
)
Concurrence:
Training Programs Department Manager i
i Training Systems Departnent Manager 4
I Accreditation Division Director After signatures, forward to Accreditation Support Section with a copy to the plant coordinator for follow-up action, i
I
,