ML20236Q214

Annual Rept on Effectiveness of Training in Nuclear Industry for CY97

ML20236Q214
Person / Time
Issue date:	07/31/1998
From:	NRC (Affiliation Not Assigned)
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ML20236Q210	List: ML20236Q208 ML20236Q214
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NUDOCS 9807200070
Download: ML20236Q214 (17)

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ANNUAL REPORT l ON THE EFFECTIVENESS OF TRAINING IN THE NUCLEAR INDUSTRY FOR CALENDAR YEAR 1997 l

July 1998 i

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TABLE OF CONTENTS TOPIC EAGE Background 1 NRC Monitoring of Training 3 Training issues in LERs and inspection Reports 4 Observations of the Accreditation Process 7 Results of Operator Licensing Activities 9 Conclusions 12 Figures Figure 1: Overall Human Performance vs Training 13 Figure 2: Human Performance issues vs Training issues 14

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l-ANNUAL REPORT ON THE EFFECTIVENESS OF TRAINING IN THE NUCLEAR INDUSTRY FOR CALENDAR YEAR 1997 BACKGROUND The history of NRC regulation of training in the nuclear industry dates to the 1982 Nuclear j

Waste Policy Act which required the NRC to " promulgate regulations, or other appropriate Commission guidance" on the instructional requirements for workers at nuclear power plants.

To meet this directive, the Commission published a policy statement on training in March 1985 endorsing the performance-based training accreditation process managad by the Institute of Nuclear Power Operations (INPO) while affirming the NRC's responsibility for evaluating l

licensees' training efforts. In issuing the policy statement, the Commission deferred rulemaking 4

to allow the industry to continue its efforts to upgrade their training programs. The policy statement requested the staff ensure that the industry's training program improvements were effective by closely monitoring the process and its results by (1) recommending NRC representatives to the National Nuclear Accrediting Board, (2) having a staff member attend and observe National Nuclear Accrediting Board meetings and (3) by periodically observing

! accreditation team site visits. Evaluations of the accreditation process concluded that the process was generally effective in bringing about improvements to the training programs so rulemaking was not initiated at that time.

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in response to a 1990 court decision,10 CFR 50.120, " Training and Qualification of Nuclear Power Plant Workers," was issued in April 1993 and became effective in November 1993. This i

rule requires that training programs be established, implemented and maintained using a I systems approach to training (SAT) for nine categories of non-licensed workers at nuclear power plants. As requested by the Commission,10 CFR 50.120 complements the i requirements for SAT-based training for the requalification of licensed operators contained in 10 CFR Part 55, which was issued in 1987. In addition to the SAT-based training requirements of 10 CFR 50.120,10 CFR Part 55 allows facility licensees to have an operator requalification program that is derived using a SAT-based process or which meets the requirements outlined in 10 CFR 55.59 (c) (1) through (7).

As specified by the policy statement, NRC and INPO entered into a Memorandum of Agreement. The Memorandum of Agreement allows the NRC to monitor and observe, as part of its assessment of the effectiveness of the industry's training programs, INPO accreditation l activities, accreditation team visits and National Nuclear Accrediting Board meetings. The NRC l

also monitors selected performance areas of its licensees as part of its assessment. Based on i

these assessments, the NRC conducts for cause training inspections using inspection Procedure 41500, " Training and Qualification Effectiveness," which references NUREG-1220,

" Training Review Criteria and Procedures." This report summarizes the NRC assessment of the effectiveness of the industry's training programs for calendar year 1997.

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H0HB 1997 Annual Report On Training 2 L

NRC MONITORING OF TRAINING The NRC monitors industry performance in implementing the training requirements of 10 CFR Parts 50 and 55 by (1) reviewing Licensee Event Reports (LERs) and inspection reports for training-related issues, (2) observing the accreditation process, and (3) participating in, inspecting, and reviewing the results of operator licensing activities. Guidance for administering examinations for licensed operators is contained in NUREG 1021, " Operator Licensing Examiner Standards," Interim Revision 8, February 1997. Guidance for inspecting the aspects of the operator 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 appropriate using Inspection Procedure 41500, " Training and Qualification Effectiveness," which references the guidance in NUREG-1220, " Training Review Criteria and Procedures." The Operator Licensing and Human Performance Branch (HOHB)in the NRC's Office of Nuclear Reactor Regulation has the programmatic responsibility for ensuring that utilities implement training requirements for all covered personnel in an acceptable manner. The Human Factors Information System (HFIS) contains more than 4 years of information on human performance issues which have been documented in inspection reports, examination reports and licensee event reports (LERs). Training is one of the seven human performance areas for which HOHB has programmatic responsibility and for which information is documented in HFIS. The information is monitored by HOHB during its ongoing Reviews of LERs, examination reports, and inspection reports and through its on-site human performance investigations of operational events. At least twice each year, HOHB compiles H0HB 1997 Annual Report On Training 3

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the available human performance data from HFIS for all plants, including training data, and identifies those plants where human performance may be an issue. This report references only the HFIS-identified issues specifically related to training.

Training issues in LERs and inspection Reports Review of 1997 inspection reports was completed, however, ongoing improvements to the HFIS database prevented 1997 inspection report data from being available for analysis to support this report. However, a review of training issues contained in LERs was conducted for calendar year 1997 using HFIS. This review revealed that for calendar year 1997 the number of human performance related LERs that cite training as a contributing factor decreased by 47%

compared to calendar year 1996, from 137 to 72. Figure 1 shows the number of human I

performance related LERs has varied over the past 3 years Figure 1 also shows the contribution of training related LERs to the total on each of those years. The data indicates that there has been an overall decrease of 31% in training related LERs over the last 3 years.

Figure 2 compares the total number of human performance issues identified in LERs with the number of training issues in LERs and shows a decrease in both groups. HOHB analysis indicates that the decrease in training related LERs reflects an industry-wide decrease in the overall number of LERs being written by licensees. Analysis of the LER details indicates that licensees attributed more than 90 percent of the training issues in human performance LERs to having provided training that was less than adequate for ensuring successful performance on the job. The HOHB analysis also notes that, desp'te a decrease in the total number of training-l H0HB 1997 Annual Report On Training 4 l

as related LERs being issued, the average number of training findings in each training-related LER has remained constant at 1.5 per LER for the past three years.

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, based on the NRC's continued confidence in the accreditation process, training inspections are only conducted when sufficient cause is identified. Two "for-cause" training inspections were conducted during calendar year 1997 - at Millstone and St. Lucie.

I The Millstone inspection was initiated based on long-term problems in the operator initial licensing and requalification training programs that suggested overall weaknesses in the implementation of the SAT process. An inspection of the technical training programs was conducted in June 1997. The results of the inspection, which are documented in Inspection Report 50-245/97-202,50-336/97-202, and 50-423/97-202, indicated that trainees had not '

been properly evaluated to assess mastery of tasks and that training program effectiveness had not been conducted. Based on that information, the overallimplementation of the systems approach to training for the technical training programs at Millstone site was determined to be generally inadequate to ensure continued qualification of technical and non-licensed personnel to successfully perform in-plant work. An apparent violation of 10 CFR 50.120 was identified conceming the failure to properly implement the systems approacn to training as described in l

10 CFR 55.4. The letter transmitting the combined inspection report 50-245/97-202,50-336/97-202, and 50-423/97-202 stated that the licensee's failure to implement the systems i approach to training is being considered for escalated enforcement action in accordance with l

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.- l the " General Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy,  !

NUREG-1600. However, Notices of Violation have not yet been issued to the Millstone site related to this issue. i

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A training inspection of the maintenance training program was also conducted at St. Lucie in September 1997. Worker qualification issues were identified by a quality audit conducted by the licensee. The audit results suggested that problems with the qualification of non-utility workers used during outages co"Id also apply to ut;lity workers as well. The results of the St. l l

Lucie inspection were documented in inspection Report 50-335/97-11 and 50-389/97-11. The i

inspection of the maintenance training programs found that the licensee failed to implement a l systems approach to training by allowing the evaluation and task qualification of workers '

through the " Conduct of Maintenance" administrative procedure. The " Conduct of i

Maintenance" procedure did not require that qualification be based on specifications and objective-based criteria. The failure to implement a systems approach to training was cited as a  ;

Level IV violation of 10 CFR 50.120. Florida Power and Light concurred with the violation in i

December 1907. The licensee's corrective actions included a revision to the procedure. The procedure, which previously allowed unqualified prwonnel to be assigned work based on supervisory oversight, will now require workers without specific task qualifications to work under the direct supervision of a qualified person.

Reactive training inspections will be conducted as needed in calendar year 1998.

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i Observation of the Accreditation Process An important aspect of monitoring training is the observation of INPO Accreditation Team Visits and the National Nuclear Accrediting Board (NNAB). NRC observed 13 meetings of the NNAB during calendar year 1997. As a result, the NRC was able to observe the presentation of training programs from 34 plants to the Board for accreditation renewal. The NRC observers were drawn from all levels of the NRC and included representatives from headquarters and each of the four NRC regions. An NRC senior human factors analyst observed an accreditation team visit at the Byron Station in February 1997 and later observed the Accrediting Board meeting when the results of the team visit were presented.

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 1997 were several comments from the NRC

. observers about the NNAB's emphasis on instructor issues. Those issues included instructional skills weaknesses and limited instructor continuing training. Other noted areas of emphasis included Reviews of training program content and weak implementation of the SAT process.

l These areas were noteworthy since they reflected weaknesses identified by the NRC in training l

inspections conducted since 1996. 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. While the NRC has no formal mechanism for teaming of the accreditation status of training programs following the utility presentation to the NNAB, INPO encourages the utilities to share the new accreditation information with the NRC. Once they H0HB 1997 Annual Report On Training 7 i

have received the results of the Accrediting Board, many licensees provide the information to NRC's resident inspector. However, the licensees are not required to do so.

t Feedback from the observation of the accreditation team visit to Byron Station indicated that the team was effective in confirming or disputing licensee identified strengths or weaknesses and worked to ensure that any additional strengths or weaknesses were identified and verified by j

more than one source. The NRC observer found the observation to be informative and felt that the team was effective in following up on weaknesses identified in the course of the visit.

Additionally, NRC resident inspectors continued to review all INPO plant evaluation and accreditation reports in accordance with the NRC's Field Policy No. 9, "NRC Review of INPO t

Documents," to ensure that significant safety issues receive appropriate follow-up. No safety-significant training issues were identified during calendar year 1997 as a result of resident inspectors' Reviews of accreditation reports.

At least annually, the NRC meets with INPO's Training and Education organization to exchange information related to training in the nuclear industry. During these meetings, NRC representatives discuss the observations made by NRC observers to INPO-lead Accreditation Team Visits and the NNAB. The 1997 meeting was held at the INPO Headquarters in Atlanta,

! Georgia on February 27. Data collected from NRC observers of the NNAB meetings during calendar year 1996 as well as observations by INPO on Accreditation Team Visits raised questions regarding the operator knowledge of fundamental topics as discussed at the meeting.

The NRC provided clarification on a systematic continuing operator training program regarding the need for completion of " required manipulations" as described in 10 CFR 55.59(c). If H0HB 1997 Annual Report On Training 8 1

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licensees have developed their operator requalification program using the SAT process, then the specific control manipulations in 10 CFR 55.59 are not required. The NRC further emphasized that changes to the SAT developed program content are within the control of the facility. The NRC also initiated discussions on the quality of as-submitted operator requalification examinations under the Part 55 pilot program. After some consideration, the NRC and INPO agreed that further attention was warranted. Additionally, INPO discussed plans to test revised methods for conducting accreditation team visits.

Results of Operator Licensing Activities The implementation of SAT-based training requirements in the licensed operator training ,

programs is reviewed by HOHB during its routine monitoring of reports detailing operator l

candidate initial examination and operator requalification inspection results. Any training-related issues identified are incorporated into the HFIS databass and reflected in the overall information on training. Licensee emphasis on licensed operator training programs has attempted to improve the overall training for that group of personnel. However, inspection reports continue to identify SAT-based training process problems. Additionally, evaluations of licensees' implementation of operator examinations during FY 1997 was reported in SECY 043," 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 included the development and administration of the simulator portion of the operating test; the objectivity and thoroughness of the licensee's evaluators in identifying operator strengths and weaknesses; the i

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quality of the written examination which had notably improved; and the effectiveness of the training feedback system in providing input to upgrade requalification training. Examples of the weaknesses relating to the adequacy of the requalification written examinations and operating test included deficiencies in the use of command and control, communication, and procedures by the crew and individuals; inadequate procedures, resulting in poor operator performance; technical and administrative errors in written questions; repetitive use of test items from week to week; inadequate operating test pass / fail criteria; and the use of nondiscriminatory or improperly validated job performance measures (JPMs) for the plant walkthrough inspection portion of the operating test. Examples of the weaknesses relating to the licensee's examination administration practices included failing to evaluate individual operator performance during the dynamic simulator scenario portion of the operating test; retuming operators to licensed duties without adequate remediation and reevaluation after they failed the examination; and failing to conduct annual operating tests of alllicensed operators. The regional staff follows up the site-specific weaknesses in subsequent requalification program inspections and uses the information to assess overall plant performance. Although all of the requalification program inspections resulted in satisfactory evaluations, the licensed operator requalification training program at D.C. Cook exhibited multiple weaknesses in areas such as the individual evaluation process; examination test item development; and the remediatien and reevaluation of operators who fail the examinations. As a result of these weaknesses and programmatic findings from the July 1997 initial examination, a follow-up inspection of the operator programs and the technical and maintenance training programs was scheduled for January 1998 to assess the adequacy of the facility licensee's corrective actions in operator l licensing and their implementation of the SAT process in the non-operator programs.

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.s The staff noted a potential generic issue related to the experience required of operator license applicants. Facilities are not required to provide detailed information regarding the training or experience of applicants if they certify that the applicant was trained in an accredited training program developed using a systems approach to training. However, selected Reviews of applications indicated that some applicants had insufficient responsible power plant experience to be eligible for a senior reactor operator license. The NRC explored ways to make facility licensees aware of the issues related to applicant eligibility until a final resolution can be achieved. Additionally, changes to the INPO program guidelines for operator training programs were evaluated by the NRC to determine the impact they may have had on facilities' understanding of the experience requirements for operator candidates. The issue of applicant eligibility was added to the agenda for the next INPO/NRC coordination meeting scheduled for February 1998.

CONCLUSIONS The combination of HOHB activities used to monitor industry performance in the area of training i

- has indicated that INPO accreditation continues to be an acceptable means of ensuring that the  !

training requirements contained in 10 CFR Parts 50 and 55 are being met. Although NRC monitoring has provided some indications of limited specific weaknesses in training programs, overall, all indicators suggest that the industry is successfully implementing training programs in  :

accordance with the regulations. HFIS data indicates some changes in the number of training related issues being identified. However, the trends over the past 3 years indicate that some H0HB 1997 Annual Report On Training 11 L

4 variance occurs from year to year. Monitoring of training-related issues will be continued to ensure that they are appropriately resolved by the Regions and licensees.

Continued observation of the National Nuclear Accrediting Board meetings is planned for 1998.

However, the number of observations will be reduced to reflect the continued favorable 1

assessment of the accreditation process. The number of meetings to be observed in 1998 has been reduced from all meetings, normally from 10 to 12 each year, to a minimum of eight.

One Accreditation Team observation is planned for 1998.

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