ML24023A623
| ML24023A623 | |
| Person / Time | |
|---|---|
| Site: | National Bureau of Standards Reactor |
| Issue date: | 09/01/2023 |
| From: | US Dept of Commerce, National Institute of Standards & Technology (NIST) |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML24023A617 | List: |
| References | |
| Download: ML24023A623 (37) | |
Text
Independent Nuclear Safety Consultant Task 04: Training Independent Assessment Report Page 1 of 37 Independent Nuclear Safety Consultant Assessment of Training at the NIST Center for Neutron Research (NCNR)
Final September 1, 2023
Independent Nuclear Safety Consultant Task 04: Training Independent Assessment Report Page 2 of 37 Contents Executive Summary...................................................................................................................... 4 Background Information............................................................................................................... 6 The Event.................................................................................................................................. 6 NCNR Staffing.......................................................................................................................... 7 The Team.................................................................................................................................. 8 Objective................................................................................................................................... 8 Methodology............................................................................................................................. 9 Acknowledgements................................................................................................................... 9 The Assessment Results............................................................................................................ 10 Performance-Based and Compliance-Based Assessments....................................................... 10 Performance-Based Assessment............................................................................................... 10 Compliance-Based Assessment.................................................................................................. 11 Objective 1............................................................................................................................... 11 Results................................................................................................................................. 11 Current Status...................................................................................................................... 11 The Gap............................................................................................................................... 11 Vulnerability.......................................................................................................................... 11 Objective 2.............................................................................................................................. 12 Results................................................................................................................................ 12 Current Status..................................................................................................................... 12 The Gap.............................................................................................................................. 12 Vulnerability......................................................................................................................... 12 Objective 3.............................................................................................................................. 13 Results................................................................................................................................ 13 Current Status..................................................................................................................... 13 The Gap.............................................................................................................................. 13 Vulnerability......................................................................................................................... 13 Objective 4.............................................................................................................................. 14 Results................................................................................................................................ 14 Current Status..................................................................................................................... 14 The Gap.............................................................................................................................. 14 Vulnerability......................................................................................................................... 14 Objective 5.............................................................................................................................. 14 Results................................................................................................................................ 14 Current Status..................................................................................................................... 15
Independent Nuclear Safety Consultant Task 04: Training Independent Assessment Report Page 3 of 37 The Gap.............................................................................................................................. 15 Vulnerability......................................................................................................................... 15 Objective 6.............................................................................................................................. 16 Results................................................................................................................................ 16 Current Status..................................................................................................................... 16 The Gap.............................................................................................................................. 16 Vulnerability......................................................................................................................... 16 Attachments................................................................................................................................ 17 : Performance-Based Assessment (performed at the site)................................ 19 : Compliance-Based Assessment...................................................................... 21 : Assessment Team............................................................................................ 32 : Contacts and Interviews.................................................................................. 36 : Reference Documents..................................................................................... 37 List of Figures Figure 1. Experience of Reactor Operators.................................................................................. 7 Figure 2. Average Experience of SROs and Reactor Supervisors............................................... 8
Independent Nuclear Safety Consultant Task 04: Training Independent Assessment Report Page 4 of 37 Executive Summary This report provides the conclusions of an independent and comprehensive assessment of the training program at NCNR-ROE which contributed to the event occurring February 3, 2021, at the NIST Center for Neutron Research. The assessment will be used to identify areas for improvement, corrective actions, and other improvement opportunities. The assessment will also be used to gauge the rigor, criticality, and overall quality of NCNRs internal self-assessment activities in this performance area. The assessment identified areas for improvement and corrective actions, and other improvement opportunities related to the NCNR-ROE training program.
The assessment was performed by a team of four independent nuclear training consultants, with operations, and nuclear training experience. The team members experience includes extensive involvement in the implementation and management in Operations and Training in Naval and commercial nuclear power.
The primary objectives of the assessment were to:
Perform a completely tailored comprehensive assessment of the training program and provide recommendations on actions to address any weaknesses and opportunities for improvement identified.
Perform an audit of NBSR training program documentation and implementation.
Compare application of training program to ANSI/ANS-15.4-2007.
Conduct analysis of training program to include metrics such as NRC license application and exam success, internal requalification success, timely maintenance of required proficiency trainings, and robust engagement of continuous learning.
Perform an independent audit of on-the-job training conducted from crew to crew to ensure that consistency and quality are maintained in accordance with training program documentation.
Perform independent audit of training provided by training program staff to ensure that consistency and quality are maintained in accordance with training program documentation.
Perform independent audit of supervisory and leadership training. Ensure that supervisors are meeting requirements as required by facility policy.
The assessment team reviewed the NCNR-ROE Training against industry standards for the conduct and documentation of nuclear training to gauge alignment with those standards. The team then conducted collegial reviews of the individual results to determine final conclusions and recommend actions to correct the identified findings.
The assessment team noted the NCNR-ROE Operations staff has implemented actions to date, such as naming a Training Program Manager, to improve the structure and rigor of the training program. Progress is evident but the lack of resources is impacting the ability to complete these actions in their entirety in a timely manner.
The overall assessment conclusion is that, while the NCNR-ROE staff has a vision for an effective training program the lack of resources prevents a timely completion of the upgrade.
Additionally, a lack of resources is impacting the desire to achieve the 5th crew concept. This presents a vulnerability to NCNR from a consistency, sustainability, and rigor perspective.
Independent Nuclear Safety Consultant Task 04: Training Independent Assessment Report Page 5 of 37 Three Positive Observations, Seven Areas for Improvement1 (AFI) and two Areas Needing Attention (ANA) were identified:
Positive Observation (PO) #1: The Assessment Team observed one classroom training session (license class review of regulatory requirements in preparation for upcoming NRC exam). The training was done well and the TPM encouraged participation by the individuals and asked probing questions to ensure comprehension of the material. Instructor and trainee engagement was positive.
Positive Observation (PO) #2: The Assessment Team observed one RX startup and shutdown (License candidate practice for upcoming NRC exam). Licensed SRO and License candidate engagement was positive.
Positive Observation (PO) #3: The NCNR-ROE Team has a vision of what the program should look like.
Area for Improvement (AFI) #1: Failure to adapt a structured and rigorous training program has resulted in inadequate employee knowledge, skills, and abilities for performance of duties.
Area for Improvement (AFI) #2: Failure to implement the standards established by ANSI/ANS 15.4-2007 has resulted in a training program which is knowledge based as opposed to performance based.
Area for Improvement (AFI) #3: Failure to provide guidance on how to fully implement training programs has resulted in inconsistencies in implementing initial license classes (from class to class) as well as implementing 24-month requal cycles.
Area for Improvement (AFI) #4: Failure to implement the requalification program as intended has resulted in a loss of Operator proficiency due to a lack of a structured program and lack of minimum knowledge criteria.
Area For Improvement (AFI) #5: Failure to implement the On-the-Job-Training established in ANSI/ANS 15.4-2007 has resulted in inconsistencies in knowledge requirements expected for license candidates and a loss of knowledge proficiency of licensed Operators.
Area for Improvement (AFI) #6: Lack of Operations training personnel has contributed to a loss of proficiency of licensed and initial licensed personnel due to the lack of a structured rigorous and sustainable program.
Area For Improvement (AFI) #7 Lack of a structured leadership training program for NCNR personnel has led to inconsistencies in application of training of supervisory personnel and is ineffective as a corrective action.
1 Area for Improvement (AFI): A performance, program, or process element that requires significant improvement to obtain desired results in a consistent and effective manner.
Independent Nuclear Safety Consultant Task 04: Training Independent Assessment Report Page 6 of 37 Area Needing Attention (ANA) # 1: Failure to implement an electronic storage system for completed documentation relating to completed training and evaluations places NCNR at risk of not being able to provide required documentation to auditors and regulators in a complete and timely manner.
Area Needing Attention (ANA) # 2: Based on employee feedback, corrective action (CAP) and Human Performance Tools (HPES) training given to NCNR personnel is ineffective. Although this observation was limited in scope (training) it raises the question of the overall effectiveness of the Corrective Action Program. NCNR management should perform an independent review of the effectiveness of the actions taken to date for the Corrective Action Program.
Background Information On August 1, 2022, a Confirmatory Order Modifying License No. TR-5 was issued by the U.S.
Nuclear Regulatory Commission (NRC). The issued Confirmatory Order documents the U.S.
Department of Commerce National Institute of Standards and Technologys (NIST) Center for Neutron Research (NCNR) completed and planned actions, as well as the commitments made by NIST to ensure the safe operation of the research reactor in the NCNR, which experienced an unplanned shutdown on February 3, 2021.
NIST committed to conducting third-party, independent assessment of six different program areas at the NCNR. One of the identified areas is Training.
The Event On February 3, 2021, the NBSR reactor was conducting a normal start up after completing a refueling on January 4, 2021. Upon approach to full power, the plant experienced a sudden drop in power level and rapid increases on several radiation monitors, including fission products monitor (RM 3-2) and the stack monitor (RM 4-1). A major scram was automatically initiated when the stack monitor reached its setpoint of 50,000 counts per minute, and an immediate activation of the confinement isolation system sealed off confinement to prevent or limit release of radioactive material from the facility. NCNR and NIST staff took emergency actions, including declaring an Alert condition, notifying the Nuclear Regulatory Commission (NRC) as required by regulations, and stabilizing the plant. The Alert declaration was subsequently downgraded based on analysis of radiological sampling revealed that the radiological conditions at the Site Boundary and at the reactor confinement exhaust stack did not meet the conditions for the Alert declaration. The emergency was terminated later that day and the staff began recovery actions.
A post event root cause analysis was conducted and one of the root causes identified was:
The training and qualification program for operators was not on par with programmatic needs.
Corrective actions included:
- 1. Require proficiency training for personnel prior to all refuelings, emphasizing the importance of latching and procedural compliance.
- 2. Develop a program for robust qualification of operators and candidates in moving fuel.
- 3. Develop a system for knowledge and skills management in the presence of personnel attrition.
- 4. Update procedures to require training for all personnel on procedure use, place keeping, and adherence.
Independent Nuclear Safety Consultant Task 04: Training Independent Assessment Report Page 7 of 37
- 5. Develop a program for robust qualification of supervisors overseeing refueling operations.
- 6. Require training for supervisors on oversight.
The assessment validated the conclusions reached by the post-event NCNR-ROE root cause evaluation regarding the Training program at NCNR-ROE.
NCNR Staffing Since 20152, a total of 15 licensed operators have either retired or left the organization. Almost every year since, several new operator candidates have been hired as replacements. A difference from previous hiring of operators with US Navy or commercial nuclear experience, is a lack of this experience with new candidates. The inability to pay a competitive salary for experienced operators is a potential contributor to this condition.
A graph of the number of operators in experience categories over the past 12 years is shown in Figure 1. The decline in experienced operators over the years, as well as the relative youth of the current staff, can be clearly seen.
Figure 1. Experience of Reactor Operators A loss of experienced operators over this period of time was a contributing factor to the February 2021 event and continues to challenge the operations department going forward.
2 [Refer to the NCNR ROE Report Root Cause Investigation of February 2021 Fuel Failure (Revision 2, 9/13/2021) for further details on staffing].
Independent Nuclear Safety Consultant Task 04: Training Independent Assessment Report Page 8 of 37 Figure 2 shows a similar decline in the average experience of the SROs and qualified Reactor Supervisors for the past 12 years. The January 4, 2021, point shows the experience of the crew performing latch checks after the January 4, 2021, refueling.
Figure 2. Average Experience of SROs and Reactor Supervisors In the past, operator experience was heavily relied upon to perform many tasks at the facility, including refueling. Because of the loss of experience, NCNR-ROE started a transition from a knowledge-based performance to a greater reliance on written procedures (rule-based performance).
The Team The team was comprised of four independent training consultants with commercial nuclear industry experience and backgrounds in senior management as well as backgrounds in operations and operations training. This experience includes the implementation of multiple equipment operator, licensed reactor operator, and licensed senior reactor operator training programs in the commercial nuclear industry. These programs were developed and implemented in accordance with standards set forth by the Nuclear Regulatory Commission (NRC) as well as the Institute of Nuclear Power Operations (INPO). Refer to Attachment 3 for a description of the individual team members background and experience.
Objective The purpose of this task is to provide an independent and comprehensive assessment of the Training (all presently in-place training programs) at the NCNR-ROE. The assessment will be performed in accordance with the requirements of the August 1, 2022, Confirmatory Order Modifying License No. TR-5. The assessment will be used to identify areas for improvement, corrective actions, and other improvement opportunities. The assessment also will be used to
Independent Nuclear Safety Consultant Task 04: Training Independent Assessment Report Page 9 of 37 gauge the rigor, importance, and overall quality of NCNR-ROEs internal self-assessment activities in this performance area.
Methodology In accordance with INPO ACAD 02-004 (Guidelines for the Conduct of Training and Qualification Activities), this assessment includes a review of training materials and the facilities; observations of training activities; interviews with operators, supervisors, and training instructors; and a review of training program records. In accordance with DOE Guide 414.1-1c (Management and Independent Assessments Guide), this assessment was both Compliance-Based and Performance-Based. To maximize the effectiveness of the assessment, the team utilized a combination of assessment techniques including interviews, document reviews and observations.
Performance-Based Assessment (Attachment 1):
The assessment Monitored/Observed the following:
Classroom training (Initial operator training)
Control Room activities SRO/RO/Equipment Operator interviews Training Program Manager interview OPS Manager interview Compliance-Based Assessment (Attachment 2)
Training Assessment Task #4 SOW, the assessment accomplished the following:
Performed a completely tailored comprehensive assessment of the training program and provide recommendations on actions to address any weaknesses and opportunities for improvement identified.
Performed an audit of NBSR training program documentation and implementation.
Compare application of training program to ANSI/ANS-15.4-2007.
Conducted an analysis of training program efficacy to include metrics such as NRC license application and exam success, internal requalification success, timely maintenance of required proficiency trainings, and robust engagement of continuous learning.
Performed an independent audit of on-the-job training conducted from crew to crew to ensure that consistency and quality are maintained in accordance with training program documentation.
Performed independent audit of training provided by training program staff to ensure that consistency and quality are maintained in accordance with training program documentation.
Performed independent audit of supervisory and leadership training. Ensured that supervisors are meeting requirements as required by facility policy.
Acknowledgements The team received excellent support from NCNR-ROE staff. NCNR-ROE staff questioning and openness to understand the team perspective is a strength.
Independent Nuclear Safety Consultant Task 04: Training Independent Assessment Report Page 10 of 37 The Assessment Results Current training program(s) lack structure, consistency and rigor to ensure adequate knowledge is obtained and retained.
Current staffing does not support the ability for license path individuals to devote time solely to their qualifications.
The NCNR-ROE Team has a picture of what the program should look like.
Implementation of present thoughts, processes and plans require immediate resources to accomplish in the near term (1 year), or an integrated long-term plan will need to be developed for the present resources to accomplish the improvement plan over time (3-5 years).
Succession planning and the Training Pipeline analysis should be considered in the program development.
Performance-Based and Compliance-Based Assessments The following summarizes the team conclusions by objective. The Assessment Report uses the following definitions to classify the observations of each of the categories:
Area of Strength - This term is used to characterize demonstrated performance in a program or process element within an area being assessed that is exceptionally effective in achieving its desired results. An Area of Strength is a program, process, or activity of such a high quality that it could serve as an example for other similar elements.
Positive Observation (PO) - This term refers to a noteworthy observation that does not rise to the level where it would be considered as a strength.
Area in Need of Attention (ANAs) - This term is used to identify a performance, program, or process element that is sufficient to meet its basic intent; however, management attention is required to achieve full effectiveness and consistency. ANAs are not normally identified or addressed in action plans submitted to the NRC but are brought to management attention for consideration and possible entry into the NCNR-ROE Corrective Action Program or alternative tracking process.
Area For Improvement (AFIs) - This term is used to characterize an identified performance, program, or process element that requires significant improvement to obtain the desired results in a consistent and effective manner. AFIs identified in the Assessment Report will be addressed by the Action Plan Submitted to the NRC.
Performance-Based Assessment The assessment team observed one operations Initial classroom training session as well as one RX startup and shutdown in preparation for the upcoming NRC exam (License candidate practice for upcoming NRC exam). Both observations received a Positive grading result. Refer to Attachment 1 for further details.
Independent Nuclear Safety Consultant Task 04: Training Independent Assessment Report Page 11 of 37 Compliance-Based Assessment Objective 1 Performed a completely tailored comprehensive assessment of the training program and provide recommendations on actions to address any weaknesses and opportunities for improvement identified.
Results The factors identified below lead to the following Area for Improvement(s) (AFI):
AFI # 1: Failure to adapt a structured and rigorous training program has resulted in inadequate employee knowledge, skills, and abilities for performance of duties.
AFI # 2: Failure to implement the standards established by ANSI/ANS 15.4-2007 has resulted in a training program which is knowledge based as opposed to performance based.
Current Status While effort is being made and changes have been incorporated into the operations training program, the training program does not align with industry standards.
Currently NCNR-ROE Operations does not employ a structured and rigorous training program.
A structured and rigorous training program uses a concept of Analysis, Design, Development, Implementation and Evaluation, when developing approved training material for their programs.
A structured and rigorous training program relies on identified tasks and objectives ensuring the developed training material is systematically evaluated and revised to improve the required knowledge and skills of individuals. There have been changes incorporated in the current Operations training program and once all needed actions have been completed the program could be used as a template for other NCNR-ROE training programs.
The other NCNR-ROE training programs (Health Physics, Engineering, Leadership) all lack structure, minimum standards, lesson plans etc. like the Operations Training program. The Safety training program is administered by NIST.
The Gap Refer to Attachment 2 for the GAPS and Recommendations associated with Objective 1.
Vulnerability Standards, Consistency, Rigor, and Sustainability - Failure to implement a training program based on a structured and rigorous training approach. has resulted in inadequacies in Operator proficiencies, knowledge, and skill. As experienced operators continue to retire, the lack of a structured program is not sustainable in ensuring the knowledge of long-time incumbents is retained for future operations personnel.
Independent Nuclear Safety Consultant Task 04: Training Independent Assessment Report Page 12 of 37 Objective 2 Perform an audit of NCNR-ROE training program documentation and implementation. Compare application of training program to ANSI/ANS-15.4-2007 and similar facilities.
Results The factors identified Below lead to the following Area for Improvement (AFI):
AFI # 3: Failure to provide guidance on how to fully implement training programs has resulted in inconsistencies in implementing initial license classes (from class to class) as well as implementing 24-month requal cycles.
ANA # 1: Failure to implement an electronic storage system for completed documentation relating to completed training and evaluations places NCNR-ROE at risk of not being able to provide required documentation to auditors and regulators in a complete and timely manner.
Current Status Procedure guidance on how to fully implement a training program (i.e.: initial operator training, requal training, engineering training etc.) is not available. Note: some training program requirements are identified in the Conduct of OPS - Training Procedures, however, it does not describe how to fully implement an operations initial or requal program from start to finish. This does not align with industry standards.
Documentation exists for completed training for initial training and requalification. All documentation is in paper form and stored in file cabinets. This could be problematic for retention and retrieval. This puts NCNR-ROE at some risk for audits if the material cannot be located.
The Gap Refer to Attachment 2 for the GAPS and Recommendations associated with Objective 2.
Vulnerability Program Implementation: Currently the transfer of knowledge on how to implement the entire operations training programs (Equipment operator, Reactor Operator, Senior Reactor Operator initial and requal) resides with the Training Program Manager. This information would be very difficult to duplicate if that person were to leave the position. In addition, other departments are left of their own accord to determine how to qualify a new person for the their position, such as Health Physics.
Documentation/Record Retention: The use of hard copy (paper based) documents storage can be problematic for retention and retrieval (records are not kept in a fireproof cabinet or area).
This also places NCNR-ROE at risk of being unable to provide the documentation to auditors and regulators in a compete and timely manner.
Independent Nuclear Safety Consultant Task 04: Training Independent Assessment Report Page 13 of 37 Objective 3 Conduct analysis of training program efficacy to include metrics such as NRC license application and exam success, internal requalification success, timely maintenance or required proficiency trainings, and robust engagement of continuous learning.
Results The factors identified below lead to the following Area for Improvement (AFI):
AFI # 4: Failure to implement the requalification program as intended has resulted in a loss of Operator proficiency due to a lack of a structured program and lack of minimum knowledge criteria.
Current Status There are no metrics which track either throughput or pass rate.
The NRC initial exam rate has been successful over the years. There has only been one failure in recent history.
Until the last requal biennial written exam, exams had been successful over the years. Past practices in the implementation of the exam resulted in high pass rates, however, the last completed written exam was implemented differently. The test writer and the material presenter worked independently which resulted in a 50% failure rate. NCNR-ROE identified this as an indicator of knowledge proficiency amongst the incumbent members. There are no specific metrics tracking this, however individual weaknesses were identified and remediated.
In addition, the annual operating exam process is not robust. The process as it exists relies on the Crew Chief having a discussion with the incumbent regarding a particular evolution, there are no prescribed pass/fail criteria, and the grading relies on the Crew Chiefs judgement and is subjective in nature.
The current requalification process is inadequate to ensure the Operators maintain proficiency.
The Gap Refer to Attachment 2 for the GAPS and Recommendations associated with Objective 3.
Vulnerability Standards, Consistency, and Rigor-The requalification program lacks structure and prescribed pass/fail criteria for the operating exam. Additionally, the lack of recurring requalification training has resulted in a loss of Operator proficiency.
Independent Nuclear Safety Consultant Task 04: Training Independent Assessment Report Page 14 of 37 Objective 4 Perform an independent audit of on-the-job training conducted from crew to crew to ensure that consistency and quality are maintained in accordance with training program documentation.
Results The factors identified below lead to the following Area for Improvement (AFI):
AFI # 5: Failure to implement the On-the-Job-Training established in ANSI/ANS 15.4-2007 has resulted in inconsistencies in knowledge requirements expected for licensed candidates and a loss of knowledge proficiency of licensed Operators.
Current Status On-the-job training at NCNR-ROE does not meet the intent of a structured and rigorous training approach. There are no defined tasks or objectives from which a comprehensive OJT program could be built. OJT currently consists of qualification oral checkouts at the system level.
Some guidance on how to conduct OJT/TPE is located in the Conduct of OPS Training Procedure AR 2.0; however, while interviewees were able to describe the OJT process to a point, they were NOT able to describe the TPE requirements. Due to a lack of implementing a Systematic Approach to Training the use of the On-the-Job Training (OJT), Task Performance Evaluation (TPE) and Job Performance Measures (JPM) implementation is basically non-existent.
The Gap Refer to Attachment 2 for the GAPS and Recommendations associated with Objective 4.
Vulnerability Standards, Consistency, and Rigor-The lack of a structured On-the Job-Training/Task Performance Evaluation has led to inconsistency in knowledge requirements for initial license candidates when pursuing qualification signatures and a loss of proficiency of licensed individuals.
Objective 5 Perform an independent audit of training provided by training program staff to ensure that consistency and quality are maintained in accordance with training program documentation.
Results The factors identified below lead to the following Area for Improvement (AFI) and Area Needing Attention (ANA):
Independent Nuclear Safety Consultant Task 04: Training Independent Assessment Report Page 15 of 37 AFI # 6: Lack of Operations training personnel has contributed to a loss of proficiency of licensed and initial licensed personnel due to the lack of a structured rigorous and sustainable program.
ANA # 2: Based on employee feedback, corrective action (CAP) and Human Performance Tools (HPES) training given to NCNR-ROE personnel is ineffective. Although this observation was limited in scope (training) it raises the question of the overall effectiveness of the Corrective Action Program. NCNR-ROE management should perform an independent review of the effectiveness of the actions taken to date for the Corrective Action Program.
Current Status Currently there is only one individual assigned to training and this person also fills the role of the Training Program Manager (TPM). The TPM was observed conducting preparatory training of individuals preparing to take the upcoming NRC exam. The training was done well and the TPM encouraged participation by the individuals and asked probing questions to ensure comprehension of the material.
The TPM Is very well respected; however, he is fulfilling all of the duties and responsibilities associated with Operations initial and requal training. A lack of resources dedicated to training has impacted the ability to establish and maintain a solid training program for Operations. With only one person assigned to training, the ability to make changes to the program quickly rises above the level of effort.
In addition to operations training, the assessment team also received critical feedback on the Corrective Action Program (CAP) training as well as the Human Performance Tools (HPES) training. Interviewees struggled with aspects of both of these programs.
The Gap Refer to Attachment 2 for the GAPS and Recommendations associated with Objective 5.
Vulnerability Program Staffing: Having one person assigned to training is a single point vulnerability issue if he were to leave. A lack of resources dedicated to training has impacted the ability to establish and maintain a solid training program for Operations. Reduced training resources will continue to impact the organizations ability to achieve the goals of a comprehensive training program for both initial license and licensed individuals.
CAP Training: The effective implementation of a Corrective Action Program to ensure that significant issues are properly evaluated, and effective corrective actions are identified and implemented to either prevent or minimize the probability of recurrence is significantly diminished.
HPES Training: The effective implementation of Human Performance Tools to reduce/prevent errors are significantly diminished.
Independent Nuclear Safety Consultant Task 04: Training Independent Assessment Report Page 16 of 37 Objective 6 Perform independent audit of supervisory and leadership training. Ensured that supervisors are meeting requirements as required by facility policy.
Results The factors identified below lead to the following Area for Improvement (AFI).
Area For Improvement (AFI) #7 Lack of a structured leadership training program for NCNR-ROE personnel has led to inconsistencies in application of training of supervisory personnel and is ineffective as a corrective action.
Current Status Supervisory training as it currently exists is a program run by NIST. The NIST New Leader Program has the supervisor attend a couple of weeks training away from the NIST facility and then a mentor (existing supervisor) is assigned to the individual for the next year. Monthly meetings occur between the mentor and the supervisor.
The program is not a structured program and does not have procedural guidance. A review of the lesson plans found them to be lacking in structure and content and did not meet the standards of a structured and rigorous program. Lesson plans were one-page documents.
Previously personnel promoted to a supervisory position were not given any preparatory training prior to being promoted, they were simply put in the position often without any turnover from the previous supervisor. There now is a series of mandatory training that is offered by Human Resources that must be completed within a certain timeframe of being placed into a supervisory position.
As a corrective action to the February 3, 2021, event, the Chief of Reactor Operations performed training of 8 leadership courses.
The Gap Refer to Attachment 2 for the GAPS and Recommendations associated with Objective 6.
Vulnerability Standards, Consistency, and Rigor-A lack of structured leadership training for NCNR-ROE supervisors puts NCNR-ROE at risk for non-compliance with the NRC Confirmatory Order.
Independent Nuclear Safety Consultant Task 04: Training Independent Assessment Report Page 17 of 37 Attachments : Performance-Based Assessment : Compliance-Based Assessment : Assessment Team : Contacts and Interviews : Reference Documents
Independent Nuclear Safety Consultant Task 04: Training Independent Assessment Report Page 18 of 37 & 2: Performance-Based & Compliance-Based Assessment The Assessment Report uses the following definitions to classify the observations of each of the categories:
Area of Strength - This term is used to characterize demonstrated performance in a program or process element within an area being assessed that is exceptionally effective in achieving its desired results. An Area of Strength is a program, process, or activity of such a high quality that it could serve as an example for other similar elements.
Positive Observation (PO) - This term refers to a noteworthy observation that does not rise to the level where it would be considered as a strength.
Area in Need of Attention (ANAs) - This term is used to identify a performance, program, or process element that is sufficient to meet its basic intent; however, management attention is required to achieve full effectiveness and consistency. ANAs are not normally identified or addressed in action plans submitted to the NRC but are brought to management attention for consideration and possible entry into the NCNR-ROE Corrective Action Program or alternative tracking process.
Area For Improvement (AFIs) - This term is used to characterize an identified performance, program, or process element that requires significant improvement to obtain the desired results in a consistent and effective manner. AFIs identified in the Assessment Report will be addressed by the Action Plan Submitted to the NRC.
Independent Nuclear Safety Consultant Task 04: Training Independent Assessment Report Page 19 of 37 : Performance-Based Assessment (performed at the site)
Monitor/observe: Classroom training:
Area of Strength Positive Observation (PO)
Area in Need of Attention (ANAs)
Area For Improvement (AFIs)
X Results: Positive Current Status: The Assessment Team observed one classroom training session (license class review of regulatory requirements in preparation for upcoming NRC exam). The training was done well and the TPM encouraged participation by the individuals and asked probing questions to ensure comprehension of the material. Instructor and trainee engagement was positive.
Independent Nuclear Safety Consultant Task 04: Training Independent Assessment Report Page 20 of 37 : Performance-Based Assessment (performed at the site)
Monitor/observe: Control Room activities:
Area of Strength Positive Observation (PO)
Area in Need of Attention (ANAs)
Area For Improvement (AFIs)
X Results: Positive Current Status: The Assessment Team observed one RX startup and shutdown (License candidate practice for upcoming NRC exam). Licensed SRO and License candidate engagement was positive. (Note: two NRC inspectors watched previous RX startup and shutdown activities with other license class candidates that day. No negative comments noted).
Independent Nuclear Safety Consultant Task 04: Training Independent Assessment Report Page 21 of 37 : Compliance-Based Assessment Objective 1 Assessment of the training program:
Perform a completely tailored comprehensive assessment of the training program and provide recommendations on actions to address any weaknesses and opportunities for improvement identified.
Area of Strength Positive Observation (PO)
Area in Need of Attention (ANAs)
Area For Improvement (AFIs)
X GAP: A structured and rigorous training program process is not used to develop and implement the initial and requal training programs GAP: No Task-to-Training Matrix exists for any of the programs.
GAP: Skill of the Craft Tasks are not identified. The lack of a catalog of approved tasks, also includes the lack of definition and listing of Skill of the Craft tasks.
GAP: The following issues were noted with Qualification Cards for Equipment Operator, Senior Reactor and Reactor Operator, and Supervisor positions:
No defined standard exists for selected tasks. There is a lack of detail and structure as to what is required to be known and what is nice to know in order to complete the task successfully and obtain a signature.
Task signoffs are more of a Knowledge-Based (quiz question) checkout than a Performance-Based demonstration for proficiency, as defined in ANSI/ANS 15.4-2007.
Checkouts are not consistent from one shift to the next in regard to what level of knowledge is required in order to obtain the signature.
Independent Nuclear Safety Consultant Task 04: Training Independent Assessment Report Page 22 of 37 : Compliance-Based Assessment Objective 1 Assessment of the training program (continued):
Perform a completely tailored comprehensive assessment of the training program and provide recommendations on actions to address any weaknesses and opportunities for improvement identified.
GAP: The following issues were identified with Classroom Training Material:
There are a limited number of classroom lesson plans available for an instructor to use. (A noted exception is material for Reactor Theory and material for the SAR portion of the initial license class).
The lesson plans which do exist lack the appropriate structure that would comply with a structured and rigorous training approach. (lack tasks, comprehensive objectives, established minimum knowledge requirements and references. Some progress is being made updating lesson plans and linking to associated support information).
Current objectives are not standardized and do not contain rigor (i.e., a Condition, Action and Standard)
There is very limited if any student material available. No Student Handouts / Training Guides / Fact Sheets are available for students to study from and have available for classroom lectures.
Students are left to obtain facility information from SharePoint. Multiple interviewees stated SharePoint is difficult to navigate.
(The Training Program Manager has noted qualification cards being revised will include links to the appropriate reference(s) for studying material).
GAP: Training is NOT being used to address identified knowledge and skill weaknesses in order to improve individual and station performance. Crews are addressing knowledge and skill weaknesses within their own crew. The ROE Chief recently mandated a requirement for operations crew members to dedicate 20% of their time to self-study.
GAP: Training is not proactively being used to improve plant performance. Not all operators feel they have the input to change training. (Note: Training feedback forms are available). One exception, an issue with the Tritium monitor became a CAP item and was incorporated into the OPS training program.
GAP: Very few mockups are available to practice tasks. Refueling test stand is one exception but has limitations as to how realistic it is. Operators have to rely on the availability of the actual control room to perform tasks.
GAP: The use of Industry and NIST Operating Experience (OE) is not fully ingrained in the day-to-day culture at the facility.
Independent Nuclear Safety Consultant Task 04: Training Independent Assessment Report Page 23 of 37
- Compliance-Based Assessment Objective 1 Assessment of the training program (continued):
Perform a completely tailored comprehensive assessment of the training program and provide recommendations on actions to address any weaknesses and opportunities for improvement identified.
Recommendations:
Perform a Task Analysis (based on the updated/revised operation procedures) and determine which tasks should be selected for classroom training, selected for initial training, selected for requal training, and selected for OJT/TPE. Also determine the frequency of the task training and incorporate it into the requal program. A graded approach could be used for this Task-to Training Matrix development, refer to DOE document DOE-HDBK-1078-94 section 2.4 for further guidance.
When the Task Analysis has been completed:
o incorporate tasks that are performance based.
o If a selected task is knowledge based, identify the required standard (minimum required knowledge) for that signature.
o Determine and identify which tasks are Perform / Simulate / Discuss.
o Incorporate a signature block for OJT / TPE signatures (for each task).
Develop classroom lesson plans for the instructor to use. These lesson plans should be developed based on a standard lesson plan format agreed upon by the NCNR-ROE training staff. Refer to DOE document DOE-HDBK-1078-94 section 4.3 for further guidance.
Develop training material that corresponds with each classroom lesson plan and can be utilized by the student (i.e.: Student Handouts / Training Guides / Fact Sheets. This material should contain the following information: system descriptions, type of pumps, power supplies, interlocks, setpoints, Tech Spec, immediate operator actions etc.). NCNR-ROE training staff to determine which format to use.
Change the requirement for 20% self-study to having a rotating crew member provide a training subject to the crew on a weekly basis. This training could be in the form of a lecture, task proficiency demonstration, etc.
NCNR-ROE to review and determine if additional mockups or some type of simulator (panel simulator, glass top, mockup etc.)
could be made available for use by license class members.
Independent Nuclear Safety Consultant Task 04: Training Independent Assessment Report Page 24 of 37
- Compliance-Based Assessment Objective 2 Audit of NBSR training program documentation and implementation:
Perform an audit of NBSR training program documentation and implementation.
Compare application of training program to ANSI/ANS-15.4-2007 and similar facilities.
Area of Strength Positive Observation (PO)
Area in Need of Attention (ANAs)
Area For Improvement (AFIs)
X X
GAP: Admin Rule series 2 procedures for Conduct of Operations - Training lack guidance on how to fully implement the Initial and Requal training programs at NCNR-ROE.
GAP: There is a lack of a singular established training program for which all NCNR-ROE departments adhere to in order to establish consistency, rigor and sustainability of training at the NCNR-ROE campus. The other department training programs (Health Physics, Engineering, Leadership) all lack structure, minimum standards, lesson plans etc. like the Operations Training program. (Note: The Safety training program is administered by NIST).
GAP: Training implementation lacks structure Schedules for EO, ILO and Requal need to be developed to capture each programs requirements A to Z.
Selecting classroom topics for requal.
Selecting Objectives ILO Training is not always attended if the individual is OnShift.
GAP: Operations training and knowledge is not shared throughout the NCNR-ROE organization. Going forward, hope to offer plant Cert training for non-OPS personnel (engineering, HP, etc.). Plant Certification Program to include theory review, plant systems, integrated plant operations, and in-plant and control room observations.
GAP: Documentation exists for completed training of initial training and requalification training; however, all documentation is in paper form and stored in file cabinets. No tracking database (TMX, Blackboard, etc.) exists to determine who is currently qualified in which positions (qualifications are manually tracked).
Independent Nuclear Safety Consultant Task 04: Training Independent Assessment Report Page 25 of 37
- Compliance-Based Assessment Objective 2 Audit of NBSR training program documentation and implementation (continued):
Perform an audit of NBSR training program documentation and implementation. Compare application of training program to ANSI/ANS-15.4-2007 and similar facilities.
Recommendation: develop a Training Program Implementation Procedure similar to the Training Program Description (TPD) at Palo Verde.
TPDs identify the technical training requirements for Equipment Operators, Reactor Operators (ROs) and Senior Reactor Operators (SROs) to successfully participate in initial qualification training (Equipment Operators) and the initial Licensed Operator Training as well as Continuing Operator Training programs.
TPDs also establish program administration requirements and establish the methods and responsibilities for the development and administration of examinations.
Develop this procedure(s) incorporating the requirements of ANSI 15.4 2007, the current AR 2.0 procedure series, and the Requalification Program for the NBSR 2009. Refer to DOE document DOE-HDBK-1078-94 section 1.4 for further guidance.
Recommendation: develop a Training Program Implementation procedure for all NCNR-ROE departments to adhere to in order to establish consistency, rigor and sustainability of training at the NCNR-ROE campus. Other department training programs include Health Physics, Engineering, Leadership etc. could follow the template established by operations. Ensure any training material required to be developed by this procedure contains structure, minimum standards, lesson plans etc. like the Operations Training program.
Recommendation:
Develop generic implementation schedule for Equipment Operator Training Develop generic implementation schedule for initial License Training Develop generic 24-month implementation schedule for Requal Training with required topics to be completed in year 1 and in year 2. Incorporate crew input for additional items that should be added to the requal schedule (note: these items can be modified/deleted from year to year based on crew input).
Recommendation: NCNR-ROE to evaluate and implement a tracking database for personnel qualification and records. This would make information more easily retrievable and more importantly protected against loss.
Independent Nuclear Safety Consultant Task 04: Training Independent Assessment Report Page 26 of 37 : Compliance-Based Assessment Objective 3 Analysis of training program efficacy:
Conduct analysis of training program efficacy to include metrics such as NRC license application and exam success, internal requalification success, timely maintenance of required proficiency trainings, and robust engagement of continuous learning.
Area of Strength Positive Observation (PO)
Area in Need of Attention (ANAs)
Area For Improvement (AFIs)
X GAP: while the initial NRC exam pass rate has been successful, multiple individuals interviewed noted a lack of program structure made it difficult to know what to study when preparing for examination GAP: The last 24-month written Requal exam had an approximately 50% failure rate. For this requal exam the test writer and the material presenter worked independently. In the past, exams tended to focus on a more targeted amount of information discussed for that 24-month cycle. NCNR-ROE has identified this 50% failure rate as an indicator of knowledge proficiency amongst the incumbent members. There are no metrics tracking this however individual weaknesses were identified and remediated.
GAP: The annual operating Requal exam is subjective in nature. There are no established pass/fail criteria. The process as it exists relies on the Crew Chief having a discussion with the incumbent regarding a particular evolution [as defined by the Requalification Program document (NRC controlled document which has its basis defined in ANSI/ANS 15.4-2007 Section 6)].
GAP: Currently there is no established requalification training occurring on a regular basis to ensure operator proficiency. (Note:
NCNR-ROE has committed to a 5th crew to establish recurring training however, it is currently resource limited for both operators and training personnel).
GAP: Current staffing does not support the ability for license path and requalification individuals to devote sufficient time for studies and support work needs of day-to-day operations.
GAP: There is a lack of the use metrics for initial and requalification exam success rate to gauge program health.
Independent Nuclear Safety Consultant Task 04: Training Independent Assessment Report Page 27 of 37 : Compliance-Based Assessment Objective 3 Analysis of training program efficacy (continued):
Conduct analysis of training program efficacy to include metrics such as NRC license application and exam success, internal requalification success, timely maintenance of required proficiency trainings, and robust engagement of continuous learning.
Recommendation:
Develop an initial license class schedule that can be utilized to implement the program from start to finish.
Develop a 24-month requal training schedule with required topics to be completed in year 1 and in year 2. Incorporate crew input for additional items that can be added to each requal cycle. (Note: NCNR-ROE has committed to adopting a 5th crew position, as resources allow which will allow the establishment of requalification training on a recurring basis. This should allow continuous learning to occur when the program and training is established).
Develop and standardize pass/fail criteria for the requal operating exam.
Independent Nuclear Safety Consultant Task 04: Training Independent Assessment Report Page 28 of 37 : Compliance-Based Assessment Objective 4 Audit of On-the-Job Training:
Perform an independent audit of on-the-job training conducted from crew to crew to ensure that consistency and quality are maintained in accordance with training program documentation.
Area of Strength Positive Observation (PO)
Area in Need of Attention (ANAs)
Area For Improvement (AFIs)
X Comments: No OJT/TPE training occurred during the assessment period, however, the following GAPs were noted.
GAP: Several issues were found that adversely impact the implementation and performance of on-the-job training. These include:
Lack of approved tasks from which the OJT program can be built. This would allow the creation of Job Performance Measures which would be used for the performance of OJT and TPE.
Qualification cards require revision to include minimum knowledge standards and separate sign offs for performance of OJT and TPE.
GAP: No formal training currently exists to become an OJT/TPE evaluator. (There is no training available to ensure individuals have a full knowledge and understanding of the OJT/TPE process and a proficiency for conducting and implementing OJT/TPE).
Recommendation: Develop OJT/TPE training in accordance with industry standards, refer to DOE document DOE-HDBK-1078-94 and INPO NISP-TR-02 OJT/TPE Process - Vendor Originated Procedure for further guidance. Provide this training to the operation department; include both classroom training and a demonstration and/or practical exercise while delivering the training.
Independent Nuclear Safety Consultant Task 04: Training Independent Assessment Report Page 29 of 37 : Compliance-Based Assessment Objective 5 Audit of training provided by training program staff:
Perform independent audit of training provided by training program staff to ensure that consistency and quality are maintained in accordance with training program documentation.
Area of Strength Positive Observation (PO)
Area in Need of Attention (ANAs)
Area For Improvement (AFIs)
X X
GAP: Only one person is assigned to operations training and that person is the Training Program Manager.
GAP: No formal training currently exists to train and qualify an instructor (i.e.: there is no course such as Train the Trainer).
GAP: Several issues were found that adversely impact the training provided to the Operations staff and to some extent the NCNR-ROE staff. These include:
Lack of resources is impacting the ability to establish a structured, comprehensive, and sustainable training program to ensure the needs of the Operations staff are satisfied.
Lack of a structured initial and requalification license operator training has contributed to a loss of proficiency for some individuals.
GAP: Individuals interviewed feel the Corrective Action Program (CAP) training is ineffective for now. The CAP training was conducted as the program was being developed and individuals who received the training feel ill equipped to implement the process as intended. One individual commented that they had to go back and refer to emails describing the process and even then, it wasnt correct in its direction.
GAP: Individuals interviewed feel the Human Performance Tools (HPES) training is ineffective for now. Individuals interviewed struggle with aspects of HPES training and there has been no follow up from training or management to check and adjust on implementation.
Independent Nuclear Safety Consultant Task 04: Training Independent Assessment Report Page 30 of 37
- Compliance-Based Assessment Objective 5 Audit of training provided by training program staff:
Perform independent audit of training provided by training program staff to ensure that consistency and quality are maintained in accordance with training program documentation.
Recommendations - Program Staffing:
Add two additional training personnel to the OPS staff (one would be the lead for Initial Training and one the lead for Requal Training).
o These individuals should complete a Train the Trainer type course to be instructor qualified.
o Create a formal tracking process for this qualification.
Develop a Training Program Implementation Procedure for Instructor Training and Qualification to identify requirements for instructor qualifications. (This could also be added to a section of the Implementation Procedure recommended in the Assessment of the Training Program). Refer to DOE document DOE-HDBK-1078-94 section 1.4 for further guidance.
Develop a formal training process to become a qualified OJT Training and TPE evaluator.
o Create a formal tracking process for the OJT/TPE qualification (i.e.: who is currently qualified to provide a signature and who is not).
Independent Nuclear Safety Consultant Task 04: Training Independent Assessment Report Page 31 of 37
- Compliance-Based Assessment Objective 6 Audit of supervisory and leadership training:
Perform independent audit of supervisory and leadership training.
Ensure that supervisors are meeting requirements as required by facility policy.
Area of Strength Positive Observation (PO)
Area in Need of Attention (ANAs)
Area For Improvement (AFIs)
X GAP: Personnel promoted to a supervisory position are not given any preparatory training prior to being promoted. They are simply put in the position often without any turnover from the previous supervisor.
GAP: Review of the lesson plans for this training found them to be lacking in structure and content and did not meet the standards of the SAT process. Lesson plans were one-page documents.
Note: As a corrective action to the February 3, 2021, event, the Chief of Reactor Operations performed training of 8 leadership courses. Interviewees were split about the effectiveness of the training. Most individuals found it helpful, but some individuals found little or no value in the training.
Independent Nuclear Safety Consultant Task 04 - Training Independent Assessment Report Page 32 of 37
- Assessment Team Michael T. Coyle, RADM, USN (Ret)
Rear Admiral Coyle has over 58 years of experience in the maintenance and operation of Naval and commercial nuclear power, including significant positions of leadership. After completing the Navy Nuclear Propulsion and Submarine training programs he served in nuclear submarines before transitioning to the Navys Engineering Duty Officer program where his duties included extensive experience in naval shipyards that specialized in nuclear submarine and surface ship maintenance and repair. He eventually commanded the Pearl Harbor, Hawaii and Mare Island, California Naval Shipyards. After selection for Rear Admiral his Flag Officer assignments were Deputy Commander for Submarines at the Naval Sea Systems Command, Maintenance Officer for the Pacific Fleet, and Deputy Commander for Engineering at the Naval Sea Systems Command.
Following retirement from the Navy in 1998 he was the Site Vice President at the Clinton, Illinois Nuclear Power Station and later, the Site Vice President at the Cooper Nuclear Plant in Brownville, Nebraska. From 2004 to 2006 he was on loan to the Nuclear Energy Institute (NEI) in Washington, DC.
From 2006 to 2009 he was Vice President, Special Projects for Exelon, the largest operator of commercial nuclear plants in the United States. From 2009 he has been an employee and consultant to several contractors performing work for the Department of Energy. RADM Coyle received a Bachelors degree from the U.S. Naval Academy where he graduated with distinction in 1965, and a Master of Science degree in Mechanical Engineering from the U.S. Naval Postgraduate School in Monterey, California where he received the Naval Sea Systems Command award for Naval Engineering.
Team Leader Clifford N.
Croasmun Senior Reactor Operator Certification (BWR), NRC Licensed Reactor Operator (BWR 5), Task Qualified Auxiliary Equipment Operator (BWR 5), Senior Simulator Floor Instructor (BWR), Training Instructor Qualified, Root Cause Evaluation Qualified, M.A.R.C. Labor Relations Qualified, Dale Carnegie Course. Niagara Mohawk Initial License Training Program, Niagara Mohawk Requal Training Program, Niagara Mohawk SRO Certification Course. WD Associates, Inc. Manager - Training & Development for WD Associates Inc., SRO Certified Instructor, Susquehanna Power Station (BWR), Responsibilities:
- Develop Simulator Scenario Guides for CPE evaluations
- Develop Simulator Scenario Guides for Requal Annual Exam
- Develop Initial License Training Scenario Guides
- Perform Classroom and Simulator training duties to Initial License Classes o Classroom training included plant systems, admin, off-normal procedures, and Emergency Operating Procedures.
Analyst
Independent Nuclear Safety Consultant Task 04 - Training Independent Assessment Report Page 33 of 37 Classroom presentations presented using multiple media methods including PowerPoint, videos, and the internet.
o Simulator training included startup/shutdown, off-normal, and Emergency Operating Procedure training.
Station Recovery Team Member for an NRC 95001 and 95002 inspection, Wolf Creek Nuclear Operating Company:
Responsibilities:
- Developed written Closure Packages to address Substantive Cross Cutting Issues (addressed in NRC Inspection Manual chapter 0310). Closure Packages to be presented to the Nuclear Regulatory Commission as part of the inspection process. (Extensive use of Word required).
- Developed a Common Cause Condition Report for cross cutting issue H.2.c Documentation.
- Coached/Mentored station personnel on the inspection process and actions to be taken.
- Coached/Mentored station personnel on corrective action product quality.
- License Operator Requal Training
- Assisting in the development of an NRC Initial Licensed Operator Exam Steven Wackenstedt Initial Test Program Test Engineer, Voglte 3&4 Construction;
- Test Engineer for startup/construction activities associated with system startup testing and acceptance testing and turnover to client: Provide input and feedback to the organization to drive completion of project milestones beyond assigned duties to include: Barriers to completion of work and possible solutions to issues encountered to complete work and meet milestones; Oversight and control of the Initial Testing Program clearance and tagging program in a supervisory position albeit being a contractor; Provide support of Main Control Room activities, equipment and system manipulations, to ensure testing and operational activities are completed in a timely and safe manner. Initial Operations License Mentor and Instructor, Palo Verde Nuclear Generating Station: Mentor/instructor for the 2016, 2018, 2019 & 2021 Initial Licensed Operator Training classes. Class had a 100 percent pass rate; Responsible for ensuring the highest standards for Operator performance were upheld by license candidates and training staff; Responsible for consistent application of conservative decision making and questioning attitude human performance tools used while operating the reactor and plant:
Regulatory Recovery Consultant, Arkansas Nuclear One Station: Developed and provided targeted training regarding vendor oversight and the responsibilities of vendor personnel in compliance with the stations standards and expectations; The training involved dynamic learning activities for all vendor Analyst
Independent Nuclear Safety Consultant Task 04 - Training Independent Assessment Report Page 34 of 37 personnel and assessments of vendor supervision and leadership. The training resulted in no significant human performance events by vendor personnel during the Unit 2 Shutdown Cooling Heat Exchanger outage conducted during the spring of 2017: Regulatory Recovery Consultant, Pilgrim Nuclear Station: Conducted Safety Culture interviews with the members of the stations identified Safety Culture Priority groups. Analyzed and summarized the data obtained from the interviews to provide station management with insights to the Priority Groups Safety Culture underlying issues:
Provided support for review of stations compliance in the areas of Equipment Reliability and the implementation of the Maintenance Rule. Regulatory Recovery Consultant, Arkansas Nuclear One Station: Conducted Safety Culture interviews with the members of the stations identified Safety Culture Priority groups. Analyzed and summarized the data obtained from the interviews to provide station management with insights to the Priority Groups Safety Culture underlying issues. Provided support to the Operations Department.
Performed targeted observations of Operations personnel during refueling outage with a focus on department standards and expectations. Provided mentoring and training of Operations Senior Reactor Operators and the implementation of the stations Operability Determination/Functional Assessment improvement process. Participated in the NRC 95003 readiness assessment/review in the inspection area of Identification, Assessment, and Correction of Performance Deficiencies (IACPD). Focus of assessment was Allocation of Resources and the impact on the station Operations Department in the areas of Control Room alarms, burdens and discrepancies, long standing tagging issues, procedure use and adherence. Participated in readiness assessment for NRC Problem Identification and Resolution (PI&R) inspection in the areas of Corrective Action Process and Operations with a focus on effective corrective actions, operability determinations, control room burdens and operator work around(s). Provided station support for NRC Inspection Procedures 95001/95002 readiness preparations.
Assisted station management in successful completion of 95001 Inspection for a NRC White Finding by performing readiness assessment of White Finding Root Cause Evaluation. Performed readiness assessment of Yellow Finding Root Cause Evaluation in preparation of 95002 Inspection. Operations Mentor, Wolf Creek Nuclear Station.
Performance Improvement Consultant, Browns Ferry Nuclear Station. Operations Shift Manager, Palo Verde Nuclear Generating Station.
John Ettien Mr. Ettien brings more than 43 years of experience in program/project/facility management, procedure development and implementation, training and qualification, conduct of operations (CONOPS), and regulatory compliance to include Oversight
Independent Nuclear Safety Consultant Task 04 - Training Independent Assessment Report Page 35 of 37 over 21 years of experience directly supporting the U.S.
Department of Energy (DOE) and its prime contractors. His relevant experience includes: Waste Disposition Operations Manager; Oak Ridge Reservation Landfill (ORRLF)
Operations Manager; Operations Manager for the K-25 Decontamination and Decommissioning (D&D) Project; and Deputy Project Manager (DPM) for the Molten Salt Reactor Experiment (MSRE) chemical defueling project. When Mr.
Ettien was the ORRLF Manager and the Waste Disposition Operations Manager, he maintained all of the roads necessary for operation of the facilities. He was also required to ensure all maintenance was performed to U.S. Department of Transportation (USDOT) standards for a large variety of equipment (e.g., bulldozers, pan scrapers, dump trucks, backhoes, straight-frame trucks, mobile cranes, forklifts, tractor trailers, etc.) Mr. Ettien never missed an annual inspection for the equipment for which he was responsible.
He served as the Surveillance and Maintenance (S&M)
Project Manager for all Bechtel Jacobs Company LLC (BJC)-
managed at the Y-12 National Security Complex (Y-12) and the Oak Ridge National Laboratory (ORNL) that involved the reduction of S&M requirements and field activities, exceeding
$100M. He managed the document revisions necessary (e.g., Documented Safety Analysis [DSA], Technical Safety Requirements [TSR], etc.) to reflect the reduced level of S&M activities. He was the Project Manager for various DOE projects, including the development of the Standards/Requirements Identification Documents (S/RIDS) at the Savannah River Site (SRS) for both the Site and Defense Waste Processing Facilities. He served as the Program Manager for URS l CH2M Oak Ridge LLC (UCOR)
Facility Management, training all UCOR Facility Managers (FMs) and implementing CONOPS organization wide for UCOR. Mr. Ettien also served as the Lockout/Tagout Subject Matter Expert (SME) and the Hazardous Energy Program Manager for UCOR. On the Tower Shield Reactor Project, Mr. Ettien ensured the development, review, and approval of all defueling procedures, developed the working schedule, and interfaced with the various organizations responsible for the oversight of this project. He provided oversight to the BJC and subcontractors CONOPS programs, mentoring and qualifying facility managers, interfacing with training organizations to identify training requirements, and reviewing training courses for implementation of applicable standards.
He was also the DPM for the U.S. Spent Fuel Team in the DPRK and mentor to the Operations Managers at the Comanche Peak, Point Beach, and Sizewell B Nuclear Plants. Mr. Ettien is trained in Tap Root Cause Analysis and has participated in performing Root Cause Analysis utilizing other methodologies. Mr. Ettien has an active DOE "Q" clearance.
Independent Nuclear Safety Consultant Task 04 - Training Independent Assessment Report Page 36 of 37 : Contacts and Interviews Tom Newton, Deputy Director Don Pierce, SEC Chair Randy Strader, Chief of Reactor Operations Andrew Gahan, Chief of Aging Reactor Management Paul Brand, Chief of Reactor Engineering Jacob Seiter, Training Program Manager Daniel Mattes, Mechanical Engineer, Reactor Engineering In addition, onsite interviews were conducted with 30 individuals from Operations, Engineering, Security, HP, Safety and Aging Reactor Management.
Independent Nuclear Safety Consultant Task 04 - Training Independent Assessment Report Page 37 of 37 : Reference Documents NIST/NCNR Documents
- 1. Administrative Rule (AR) Series 1 and 2 Procedures
- 2. Administrative Rule (AR) 4.0, Fuel Manipulation Proficiency Requirements
- 3. Requalification Program for the NBSR (License TR-5 March 2009)
NRC Documents
- 1. NRC Confirmatory Order
- 2. NRC Technical Evaluation Report (Docket No. 50-184 March 9, 2023)
Industry Documents
- 1. ANSI-15.4-2007, Selection and Training of Personnel for Research Reactors
- 2. DOE G 414.1-1C, Management and Independent Assessments Guide
- 3. IP 69001, NRC Inspection Manual for Class II Research and Test Reactors
- 4. DOE-HDBK-1078-94, Training Program Handbook: A Systematic Approach to Training
- 5. INPO ACAD 02-004, Guidelines for the Conduct of Training and Qualification Activities
- 6. INPO NISP-TR-01, Systematic Approach to Training Process - Vendor Originated Procedure
- 7. INPO NISP-TR-02, On-the-Job Training & Task Performance Evaluation Process - Vendor Originated Procedure