ML20149C262
| ML20149C262 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Crystal River |
| Issue date: | 12/18/1986 |
| From: | Roe M Office of Nuclear Reactor Regulation |
| To: | Persensky J Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML082310270 | List: |
| References | |
| FOIA-87-787 NUDOCS 8612230330 | |
| Download: ML20149C262 (5) | |
Text
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December 18, 1986 MEMORANDUM FOR:
cting Chief iaintenance and Training Branch, DHFT FROM:
Mary Louise Roe, Engineering Psychologist Personnel Training Section Maintenance and Training Branch, DHFT
SUBJECT:
OBSERVATION OF INP0 ACCREDITATION TEAM VISIT AT CRYSTAL RIVER 3 1
Introduction
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During the week of September 8-12, 1986, I was the NRC observer during the INP0 Accreditation Team Evaluation of six training programs at Crystal River 3 (CR3). The programs that were evaluated against Revision 1 of INP0 Criteria 85-002 are:
- Instrument and Control Technician
- Mechanical MaintenanceJachnician ---
- Electrical Maintenance Technician
- Radiation Protection Technician
- Technical Staff and Managers The Accreditation Process The INPO Team Visit at CR3 was conducted in the same manner as described in previous trip reports. The formal entry meeting was conducted on Monday morning. At this time, the INP0 Team Manager, John Hanson, described the purpose of the visit as a review of CR3 training programs against INPO Criteria 85-002. The Team Manager then introduced the members of this team i
(Enclosure).
The members of the observation team were well prepared and qualified to be participants. The team members from INP0 had prior experience in conducting reviews, while the peer evaluators were members of the training staffs at their respective plants.
Peer evaluator participation is encouraged by i
utilities in that this working observation provides evaluators an opportunity to acquire additional information regarding training program development through insight provided by this experience.
The review was thorough and conclusive.
Following the entrance meeting on September 8, the activities of the day were to establish a pattern of documentation review and discussions between team members and the CR3 training staff.
Each program was evaluated for process and content with the yg-f 7 N?
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1 i exception of the Technical Staff and Managers Program which was evaluated for process only.
During the following week, this program was to be reviewed for conten; along with the Chemistry Technician Program to be reviewed for both process and content. No NoC observer was in attendance the following week.
Results During the exit meeting on September 12, 1986, the Team Leader presented findings as follows:
l Job Performance Manuals (JPMs) tad Instrumentation and Co. trol, Electrical and Mechanical Mainta,na'nce, and Radiation Protection Programs The Instrument & Control and Electrical and Mechanical Maintenance Prcgrams have no core of perfom-only tasks. Some tasks have only JPM sign-offs. A concern was raised as to how the knowledge items are trained and evaluated. Guidance for JPMs conflicts with Training Department Procedure (TDP) 104. Sign-offs of tasks are allowed without training signature authority. The "or" standard allows sign-off-without training whicn is designed for grandfathering.
Program entry-level may be too high for hiring practices. The I&C Program has been modified to compensate through teaching at an adjusted rato The practice of pretesting electricians has also been used for compensation in the Electrical Maintenance Program.
For all programs, instructions or training for evaluators (observers) is needed.
In the Health Physics area, some procedures in the JPM identified as acceptance criteria have not been written. The JPM has not been approved or implemented. Sequencing of tasks in the JPM is not always appropriate, i.e., from simple to complex. Tasks and secuencing should be identified prior to independent perfomance.
3 Plant and Industr. Events have received timely distribution, but continuing training could miss these events.
l In the I&C Program, sequencing of training is also not always l
appropriate. Training for mitigating core damage was taught before l
systems in order to meet an NRC requirement.
I The Mechanical Maintenance Program needs additional guidance as to what should be done for the plant-specific portion of training (labs).
Long term contract technicians in the HP Program are not participating in continued training. Nuclear Waste Technicians have not had tt.ir positions analyzed for training as this is a new position previously l
held by contractors.
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Shift Operating Technical Advisor (S0TA/STA)
Program development has just been started. The job analysis has been completed, however. there are no unique learning objectives to STAS, and materials have not been analyzed.
t Technical Staff and Managers The process evaluation determined that the JPM has not been approved, and will not be implemented until 1/1/87.
(A follow-up was to occur during the next week for content evaluation.
It appeared that there j
were no unique learning objectives.)
Training Materials More accuracy is required in the task to training matrices.
Organization and Management Training System Development (TS0) has been identified as the systematic
.i approach to training (Program Development Manual no longer used.) There are no procedures and the JA, TA, and JPMs are not in accordance with TSD.
With respect to exam security, some answer keys were missing. Also, the same exam was used for five cycles on I&C requalification.
Structured in-plant activities for the training staff to maintain l }
technical qualifications are not effective as they are just getting I !
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started.
The staff should gain familiarity with TSD work philosophy and practices.
Initial training is incomplete for Instructors who should be trained in Training System Development and Criterion Referenced Instruction, in training procedures, the training process, and learning objective and lesson plan development.
Instructors should receive training for observers (0JT). They should participate in vendor training for new equipment (FPL said they do in practice).
1 The process of program evaluation is not used and insufficient guidance has been provided.
l 1 The Nuclear Operation Tracking System (NOTIS) is a good system and appears to work well.
Conclusions
- The INPO Evaluation Team including peer evaluators all had appropriate qualifications for the program areas they were evaluating.
- til document reviews and interviews were thorough.
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It is apparent that the INP0 team was composed of individuals dedicated to reviewing the training process as it is conducted at CR3. The findings of the review indicate that the programs were not ready for accreditation.
In the written report to follow this evaluation, the findings and recommendations for further program development will be provided for incorporation into the training program prior to its being submitted to the Accrediting Board.
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,vb du f w u Mary Lduise Roe Personnel Training Section Maintenance and Training Branch, DHFT
Enclosure:
As stated i
cc:
W. Russell B. Boger j
PTS Staff i
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Enclosure Members of the Crystal River 3 Accreditation Team September 8 - 12, 1986 4
John Hanson - Team Leader Paul Manning - Team Manager Assistant for Systems J. D. Cantrell - Team Manager Assistant for Programs Ev0dators Cully Boudreaux Harold Johnson John Miller Louis McClure i
Jerry Olson Steven Pembleton l
John Richmond l
Mark Shares Pat Wilson i
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