ML20196K379
| ML20196K379 | |
| Person / Time | |
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| Issue date: | 06/30/1999 |
| From: | NRC |
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| NUDOCS 9907080308 | |
| Download: ML20196K379 (16) | |
Text
e ANNUAL REPORT ON THE EFFECTIVENESS OF TRAINING t
IN THE NUCLEAR INDUSTRY FOR CALENDAR YEAR 199'8 June 1999 9907080308 990606 C
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d TABLE OF CONTENTS i
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i TOPIC PAGE
Background
1 NRC Monitoring of Training '
3 Indicator 1: Training-Related HFIS Data 5
Figure 1 - HFIS 3 Year Trend 5
Figure 2 - 1998 HFIS Training Data 6
Figure 3 - 1998 HFJS Work Practices Data 7
Indicator 2: For-Cause Training inspections 8
Indicator 3: Operator Licensing Examination Report Findings 10 Indicator 4: Monitoring the Accreditation Process 11 Observing Accreditation Activities 11 Coordinating Activities with INPO 13 Conclusions 14 l
1 ANNUAL REPORT ON THE EFFECTIVENESS OF TRAINING IN THE NUCLEAR INDUSTRY FOR
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CALENDAR YEAR 1998 BACKGROUNQ The history of NRC regulation of training in the nuclear industry dates to the 1982 Nuclear Waste Policy Act (NWPA) 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 j
statement on training in March 1985 which endorsed the performance-based training accreditation process managed by the Institute of Nuclear Power Operations (INPO). When issuing the policy J
statement, the Commission deferred rulemaking to allow the industry to continue its effc
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upgrade their training programs. After an initial two-year period, evaluations of the accredtoon process concluded that it was generally effective in bringing about improvements to the training programs so rulemaking related to the training of non-licensed personnel was not initiated. In May 1987,10 CFR Part 55 was revised to incorporate several new requirements and endorsements.
The 1987 changes included removing instructor certifications, endorsing Regulatory Guides 1.8 on personnel training and 1.149 on the simulator certifications, requiring operating examinations to be conducted on a simulator, and establishing the operator requalification training program. In November 1988, an amended policy statement on training was issued to reflect the existing Commission views on training for non-licensed workers at nuclear power plants.
In response to a 1990 court decision requiring a rule on training to satisfy the NWPA,10 CFR 50.120, " Training and Qualification of Nuclear Power Plant Workers," was issued in April 1993 and I
became effective in November 1993. This rule recognizes that the safety of nuclear power plant IOLB 1998 Annual Report On Training 1
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l operations and the assurance of general public health and safety depends on personnel performing at adequate levels. The 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 plants. The systematic determination of job performance qualification requirements and the provision for periodic retraining enhances public confidence in the ability of workers to perform successfully when required. The Code of Federal Regulations,10 CFR 50.120, complements the requirements for SAT-based training for the requalification of licensed operators contained in 10 CFR Part 55, which was issued in 1987.10 CFR Part 55 allows facility licensees to have an 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).
4 10LB 1998 Annual Report On Training 2
NRC MONITORING OF TRAINING
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Public health and safety depends on proper operation, testing and maintenance of a nuclear power plant's systems and components by nuclear power plant personnel. Successful performance by nuclear power plant personnel is assured by having workers achieve and maintain job-task qualification through the SAT-based training and continuous re-training required by 10 CFR Parts 55 and 10 CFR 50.120. The overall implementation of a systems approach to training is monitored by INPO as part of their accreditation reviews conducted at nuclear power plants and is reflected in the status of accreditation throughout the industry as a whole. Therefore, indications of favorable job performance and successful SAT implementation provide a reasonable assurance that the training of nuclear power plant workers is adequate to maintain public health and safety.
The NRC monitors four training-related activities as indicators of worker performance and SAT implementation. The NRC monitors worker performance by reviewing Licensee Event Reports (LERs) and inspection reports for training-related issues, inspecting training programs when an appropriate cause is identified, and administering, inspecting, and reviewing the results of operator licensing activities. The NRC monitors SAT implementation requirements by reviewing the effectiveness of the accreditation process administered by INPO. These four activities were j
selected because they provide for an efficient and effective assessment of industry activities with minimal impact to licensees. Although each activity can provide plant-specific information, the
-information is used in the composite for this report to assess the overall effectiveness of training in the nuclear industry.
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J Guidance for administering examinations for licensed operators is contained in NUREG 1021,
" Operator Licensing Examination Standards." Guidance for inspecting the aspects of the operator j
training programs unique to requalification is found in inspection Procedure 71001, " Licensed
. Operator Requalification Program Evaluation." In addition, the NRC, for cause, verifies compliance with the requirements for SAT-based training through its inspection program and has done so when i
appropriate using inspection Procedure 41500, " Training and Qualification Effectiveness," which references the guidance in NUREG-1220, " Training Review Criteria and Procedures." The Operator Licensing, Human Performance and Plant Support Branch (IOLB)in the NRC's Office of IOLB 1998 Annual Report On Training 3
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Nuclear Reactor Regulation has the programmatic responsibility for ensuring that utilities implement training requirements for all personnel addressed by 10 CFR 50.120 and 10 CFR Part 55 in an acceptable manner.
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1 1
INDICATOR 1: Training-Related HFIS Data Issues in LERs, inspection Reports and Examination Reports
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i Several aspects of worker performance are continually monitored and documented in the Human 1
Factors Information System (HFIS) by IOLB during its ongoing reviews of LERs, inspection reports, and operator licensing examination reports and through its on-site human performance d
investigations of operational events. Twice each year, in support of the regional plant performance reviews, IOLB compiles the available human performance data from HFIS for all plants, including training data, and identifies those plants where power plant worker performance may challenge a licensee's ability to operate safely.
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Figure 1-HFIS 3 Year Trend f
i CATEGORY CODES so, !,
l 1. Communication 1
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- 2. Human System Interface l
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- 4. OrganizationalIssues a 201 j h
- 5. Procedures 10 ~l I l !
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- 6. Work Factors
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- 7. Training
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7 Human Performance Categories 9
1996 1997
[ 1998 Figure 1, HF/S 3-Year Trend, shows the relative contribution of various categories of human performance issues to the overall industry total, in 1998, a total of 13,755 human performance items were identified in LERs, inspection reports and examination reports. Of that total,1066 items were related to training. Over the last three years, the contribution of training has remained relatively constant at approximately 7% for the industry as a whole. In addition, a review of the 1998 IOLB 1998 Annual Report On Training 5
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data indicates that the number of training-related items for each licensee is clustered tightly near the industry mean. No trends or patterns were noted with regard to any particular Region or with regard to any specific reactor type.
Figure 2 - 1998 HFIS Training Data l
CAUSE CODE _S_:
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- 1. No training g
- 2. Training LTA 40 V 7
- 3. SAT process problems n;i i
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- 4. Task qualifications 3a _
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- 5. Individual knowledge LTA kh/ g
- 6. Simulator fidelity LTA J
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fy
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2-3-
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6-Causes of Training issues Figure 2,1998 HF/S Training Data, shows the breakdown of the 1066 training-related items into i
their specific causes. The graph in Figure 2 shows thet the causes of training-related issues are concentrated in two distinct areas: Training less than adequate (LTA)' and Individual knowledge less than adequate (LTA)2 This pattern is true for both LERs and Inspection Reports.
Approximately three-quarters of the individual knowledge deficiencies are linked to continuing training versus initial training. This proportion is most probably the result of a stable work force. In addition, the large contribution from deficiencies in training content and individual knowledge may also reflect weaknesses in licensee monitoring of worker performance. Training program evaluation, as equired by 10 CFR 50.120, has been documented as a weakness during NRC for-cause inspections of training over the past two years. When work type could be identified from the ITraining was provided and was attended by the worker but content was incorrect or incomplete.
2Complete and accurate training was received by the worker but the worker was unable to perform successfully on the job.
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report information, training knowledge deficiencies were most often identified during the performance of maintenance and repair work.
The graph in Figure 1 (page 4) also shows an increase of 10 percent in the relative contribution of Work Factors from 1996 to 1997. This can be explained, at least in part, by a change in the HFIS coding scheme at that time. In addition, a relationship may also exist between the number of individual knowledge deficiencies and an increase in the number of work factor issues in 1997 and 1998. " Work Practices" and " Awareness and Attention" are the two areas under the category of Work Factors. The area of " Work Practices" incorporates the issues due to worker performance and was reviewed for possible links to training issues as described below.
Figure 3 - 1998 HFIS Work Practices Data CAUSE CODES j
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- 1. Briefings, preparation or turnover LTA p
, 2. Skill of craft LTA i
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- 3. Decision making / questioning attitude LTA il.'!
' 4. Team interactions LTA i
- 5. Work untimely i
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i 6. Non-conservative action g 3o a 7-i
- 7. Tag outs LTA
- l l 8. Housekeeping LTA 10 O
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8 Causes of Work Practice lasues Figure 3,1998 HFIS Work Practices Data, provides a breakdown into the individual causes for the 3418 items (total number of HFIS items = 13,755) identifis i m this area in 1998. The largest contributor," Skill of the craft less than adequate," may be linked to training. The inability of the workerto perform successfully when called upon may be the result of missing or insufficient initial or continuing training. Given the stable workforce throughout the industry, the large contribution from this area is most likely the result of inadequate continuing training due to weak implementation of program evaluation. As part of program evaluation, licensees are required to monitor worker 10LB 1998 Annual Report On Training 7
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d performance on-the-job to identify when refresher training may be needed to maintain competency and skills. Inadequate monitoring of worker performance can result in increased risks due to the impact of reduced worker abilities when operating, maintaining and testing plant equipment, i
including safety-related equipment.
Based on the HFIS training data, recommendations for follow-up of training and work practices
. issues at specific sites were made to the Regions as a normal part of the plant performance review process and were used by the Regions to more effectively focus inspection resources. From an industry perspective, HFIS data identified only three instances from the 105 plants nationwide where the number of training-related items varied significantly from the industry mean. The deficiencies causing those variations were not considered programmatic and therefore did not increase risk or reduce public health and ' safety.
t INDICATOR 2: For-Cause Training inspections NRC Inspection of Licensee Training Programs The NRC can inspect facility training programs at any time to verify satisfactory implementation of the training requirements in 10 CFR Parts 50 and 55. However, the NRC had found, through inspections conducted prior to the implementation of 10 CFR 50.120 that training programs accredited and implemented consistent with the industry-wide objectives would be in compliance with the requirements contained in Patts 50 and 55 to have SAT-based training programs.
Therefore, training program performance indicators are monitored in lieu of routine inspection.
When the number or type of training-related human performance issues have the potential to be the result of training-related deficiencies, inspections of training programs are conducted. Three "for-cause" training inspections were conducted during calendar year 1998 - at D.C. Cook, Wolf Creek, 1
and Millstone to assure worker performance was adequate to maintain safety.
The Cook training inspection was conducted in January 1998 and focused on the training of maintenance personnel. The inspection was to follow-up on generic training issues identified by NRC inspectors during an operator requalification inspection in March 1997 and a large number of 10LB 1998 Annual Report On Training 8
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failures in the initial operator licensing examination administered in August 1997. The results of the inspection were documented in Inspection Report 50-315/98-003 and 50-316 /98-003 and indicated that the maintenance training programs were adequate but, like the operations training programs, had weaknesses in the areas of continuing training and program evaluation. In the Engineering Support Personnel training program, the licensee had failed to maintain the systems approach to training as required by 10 CFR 50.120. This failure was evidenced by deficiencies in training program content that were significant enough to require the cancellation of initial training and resulted in newly hired system engineers not being able to complete training and qualification requirements in a timely manner. The licensee had identified the problem and was implementing corrective actions and, as a result, a non-cited violation was documented in the report. The corrective actions included the conduct of a needs and a job analysis which resulted in a complete revision of the training materials. The licensed operator training program was also reviewed during the January 1998 inspection and it was determined that the program was being implemented in accordance with the requirements of 10 CFR Part 55. A subsequent inspection was conducted in December 1998 to follow-up on the specific training issues identified during the operator requalification inspection in March 1997. The results were documented in Inspection Report 50-315/98-023 and 50-316/98-023 and indicated that the completed and proposed corrective actions were adequate to address the previously identified training problems. Overall, while some weaknesses were identified in the implementation of SAT at D.C. Cook, the programs were adequate to ensure worker performance would support safe operation.
Engineering support personnel training, maintenance training, and emergency preparedness training at Wolf Creek were evaluated during a training inspection conducted in February 1998. The inspection was focused on determining the contribution of training to identified worker performance issues. The results were documented in Inspection Report 50-482/98-002 and indicated that each of the three programs-reviewed effectively addressed the evaluation of training mastery and program feedback and that the programs were adequate to ensure worker performance would support safe operation of the plant.
An inspection of the Millstone Unit 3 technical training programs was conducted in March 1998.
The training programs were evaluated as part of the assessment of the readiness of Millstone Unit 3 10LB 1998 Annual Report On Training 9
to restart. The inspection was also a follow up to training issues identified by the NRC in June 1997.
Overall, the 1998 inspection of the training programs determined that the implementation of the systems approach to training for the technical training programs had improved since June 1997 and was adequate to ensure continued qualification of technical and non-licensed personnel and to l
support safe operation of the plant. The inspection results were documented in inspection Report 50-423/97-083.
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From an industry perspective, the for-cause training inspections conducted in 1998 suggested a possible programmatic weakness. However, a follow-up review of the inspection findings confirmed site specific weaknesses at the individual sites but did not indicate any industry-wide worker performance weaknesses that would increase risk or reduce public health and safety.
INDICATOR 3: Operator Licensing Examination Report Findings Results of Operator Licensing Inspection Activities The implementation of SAT-based training requirements in the licensed operator training programs is reviewed by IOLB 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. The evaluation of licensees' implementation of operator requalification examinations during FY 1998 were reported in SECY 99-056, " Annual Status Report on the Administration of NRC's Requalification Program and the Initial Operator Licensing Examinations." In general the programs were found to be adequate but with site-specific strengths and weaknesses. Examples of the strengths remain the ability of licensees to develop and administer the simulator portion of the operating test; the ability of the licensee evaluators to identify operator strengths and weaknesses; 1
and the effectiveness of the training feedback system in providing input to upgrade requalification training. Examples of the weaknesses are related to the adequacy of the requalification written examinations including the repetitive use of test items; the use of nondiscriminatory or improperly validated job performance measures (JPMs) for the plant walkthrough inspection portion of the operating test; and to the failure to conduct annual operating tests of alllicensed operators. The l
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regional staff follows up the site-specific weaknesses in subsequent requalification program inspections and uses the information to assess overall plant performance. In general, the training staffs at nuclear power plants are successfully implementing all aspects of a SAT-based training program for operators, including the conduct of operator evaluations.
From an industry perspective, inspections of licensed operator examination activities identified four recurring issues. The recurring issues suggested possible programmatic weaknesses. However, the follow-up review of the inspection findings confirmed site specific weaknesses but did not indicate any programmatic weaknesses. The implementation of SAT-based training in the operator programs was' adequate to assure public health and safety.
I INDICATOR 4: Monitoring the Accreditation Process Observing Accreditation Activities and Coordinating Activities with INPO in accordance with its Memorandum of Agreement with INPO, the NRC monitors INPO accreditation activities as an indicator of the overall effectiveness of the industry's implementation of the systems approach to training to assure that workers can perform adequately. The NRC monitors accreditation in lieu of conducting inspections to assess compliance with the SAT requirements contained in 10 CFR 50.120 and 10 CFR Part 55. Monitoring training program effectiveness through a review of the accreditation process increases NRC efficiency by focusing Agency l
resources on the inspection of licensee training programs only when problems have been identified I
through routine monitoring.
Observing Accreditation Activities Observations of INPO Accreditation Team activities and the National Nuclear Accrediting Board (NNAB) meetings are key activities in assuring that training programs accredited and implemented with the INPO objectives would be in compliance with the SAT requirements contained in 10 CFR 50.120 and 10 CFR Part 55. NRC staff attended 11 meetings of the NNAB during calendar year 1998. As a result, the NRC was able to observe the presentation of training programs from 30 plants to the Board for accreditation renewal. The NRC staff observers were drawn from alllevels of 10LB 1998 Annual Report On Training 11
g the NRC and included representatives from headquarters and each of the four NRC regions. One of
. the NRC observers from Headquarters had also observed the on-site accreditation team activities leading up'to the meeting with the Board. The NRC observer found that the INPO team was professional in all its interactions with the licensee, worked well together, identified licensee strengths and weaknesses, and corroborated their own findings. The observer also noted that the
= team was particularly effective in supporting its conclusions with facts.
The NRC observers continue to note the rigorous review documented in the Accreditation Team reports and the in-depth questioning by the Board of the accreditation evaluation results when the programs are presented.' Of particular note in 1998 were several comments from the NRC observers about the NNAB's emphasis on instructor issues. About half of the observers noted issues related to the qualification and evaluation of instructors. One other area of emphasis noted by the observers was that the Accrediting Board focused on the weak implementation of the SAT process during several of the sessions. This emphasis was noteworthy since it reflected weaknesses identified by the NRC during for-cause training inspections conducted since 1996. A summary of NRC Accrediting Board observations was discussed with INPO at the February 25, 1999 coordination meeting.
The NRC observers also noted several positive aspects of the Board's review activities. Among those aspects were the willingness of the NNAB to challenge the accreditation team leader to defend team findings and NNAB member efforts to establish the relationship between past problems and current ones. Based on the range of questions and the depth to which weaknesses were probed, the NRC continues to have a favorable assessment of the accreditation process. The continued favorable assessment resulted in a decision to reduce the number of Accrediting Board meetings to be observed by the NRC in 1999. However, the remaining NRC observations of accreditation activities in 1999 will be focused on monitoring the impacts of changes INPO is making to the conduct of accreditation visits on the NRC's ability to assess the effectiveness of the implementation of the SAT process through accreditation.
- When they have received the results of the Accrediting Board, licensees generally provide the j
'information to NRC's resident inspectcr. However, the licensees are not required to do so.
. Additionally, NRC resident inspectors continued to review INPO plant evaluation and accreditation reports in accordance with the NRC's Field Polict No. 9, "NRC Review of INPO Documents," to 10LB'1998 Annual Report Dn Training 12 i
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ensure that significant safety issues receive appropriate follow-up. No safety-significant training issues were identified in calendar year 1998 as a result of resident inspectors' reviews of accreditation reports.
i Coordinating Activities with INPO At least annually, the NRC meets with INPO's Training and Education organization to exchange information related to training inthe nuchar industry. During these meetings, NRC representatives also discuss the observations made by NRC observers to INPO-lead Accreditation Team Visits and the NNAB. The 1998 meeting was held at the NRC Headquarters on February 25. Data sheets collected from NRC observers of the NNAB meetings during calendar year 1997 as well as
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observations by INPO on Accreditation Team Visits and NRC insights gained during the conduct of licensed operator examinations and inspections were used to identify the topics for discussion.
Topics included operator knowledge of fundamental topics and operator experience and eligibility requirements. As a result of the discussion, both the NRC and INPO committed to continue to monitor the issue of operator knowledge. Discussion on eligibility indicated that changes to
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accreditation guidance on operator qualifications may have resulted in some unintended
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interpretations by the industry as to the appropriate eligibility guidance to use. Both the NRC and INPO agreed to continue to explore the various ways to ensure that the industry was informed of the problem and was aware of the appropriate guidance. On July 8,1998, INPO issued a letter to the industry to clarify the work expenence prerequisites contained in the National Nuclear Training Academy guidelines. On October 1,1998, the NRC issued Information Notice 98-37,
- Eligibility of Operator License Applicants." During the February,1998 coordination meeting INPO also discussed proposed changes to the accreditation visit program to accommodate more frequent reviews of training programs and the NRC discussed licensed operator continuing tra'ining inspections and for-cause training inspections.
From an industry perspective, no generic or programmatic weaknesses were identified in the exploration of SAT issues by the Accrediting Board. In general, the accreditation process assures that the systems approach to training is being successfully implemented at nuclear power plants.
The NRC assessment of the accreditation process indicates that continued accreditation remains a reliable indicator of successful SAT implementation and contributes to the assurance of public health and safety by ensuring that nuclear power plant workers are being appropriately trained.
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f CONCLUSIONS The 1998 IOLB monitoring of industry performance in the area of training provided some indications of limited specific weaknesses in training programs, all indicators suggest that, overall, the industry is successfully implementing the required SAT-based training programs in accordance with the regulations. Monitoring of licensee performance will be continued with emphasis on identifying any training issues that may be related to instructor competency or that may provide more definitive links between inadequate program evaluation and an increase in the number of work practice issues.
The information from HFIS data and INPO monitoring did not suggest any progammatic issues and therefore no follow-up was conducted. The issues associated with training inspections and operator licensing program inspections were reviewed for generic weaknesses requiring an industry-wide response. However, the identified weaknesses were found to be site-specific and, therefore, did not require additional action from the NRC on an industry level.
The 1998 activities monitoring the effectiveness of the INPO accreditation process continued to provide confidence that accreditation is an acceptable means of ensuring that the training requirements contained in 10 CFR Parts 50 and 55 are being met. The NRC has determined that monitoring of the accreditation process will be reduced in 1999 to reflect the continued favorable assessment. HFIS data continues to provide adequate information to identify instances where the number of training issues at a specific plant varies significantly from the industry as a whole.
Therefore, no changes in monitoring are planned in that area. The number of and causes for training inspections as well as the instances of repeat issues identified in inspections of licensed operator examinations will be monitored to identify emergent issues. If necessary, the Agency will make the industry aware of significant trends through Agency generic communications or through the coordination meetings with INPO.
The assessment of worker performance, as evidenced by HFIS data, training inspection results and operator licensing program results was favorable. The assessment of systems approach to training implementation, as evidenced by accreditation process reviews was also favorable. The results indicate that the training of nuclear power plant workers is adequate to support safe operation, testing and maintenance of the plants and provides reasonable assurance of continued public health and safety.
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