Peter S. Winokur, Chainnan

Jessie H. Roberson, Vice Chainnan

John E. Mansfield

Joseph F. Bader

DEFENSE NUCLEAR FACILITIES

SAFETY BOARD

Washington, DC 20004-2901

June 5, 2012

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Mr. Daniel K. Hoag

Acting Manager, Y-12 Site Office

U.S. Department ofEnergy

P.O. Box 2050, Mail Stop 8009

Oak Ridge, Tennessee 37831

Dear Mr. Hoag:

The Defense Nuclear Facilities Safety Board (Board) considers training to be a crucial

element in preparing operators to safely conduct nuclear operations at defense nuclear facilities.

The Board is encouraged that Babcock & Wilcox Technical Services Y-12, LLC (B&W) and the

Y-12 Site Office have recently made improvements in the areas ofprocedural compliance,

conduct of operations, and activity-level work planning. Many ofthese improvements depend

on training to emphasize management~sexpectations for safe operations, making a highly

effective and properly implemented training and qualification program even more important.

Consequently, the Board's staffreviewed the B&W training and qualification program at the

Y-12 National Security Complex. The staff's review concluded that the training and

qualification program utilizes a systematic approach to training consistent with Department of

Energy requirements, but also revealed several opportunities for improvement in its

implementation and effectiveness. These include (1) evaluating and enhancing the content of

certain training activities, (2) more effectively utilizing continuing training to improve operator

expertise, and (3) improving the implementation ofthe process used to identify training

requirements. The enclosed report provides specific details for your consideration. The Board

looks forward to hearing about any planned improvements to the training and qualification

program during our next scheduled visit to Y-12.

Sincerely,

~~tSA Peter S. Winokur, Ph.D.

Chairman

Enclosure

c: Mr. Glenn S. Podonsky

Mr. Steven C. Erhart

Mrs. Mari-Jo Campagnone
DEFENSE NUCLEAR FACILITIES SAFETY BOARD

StaffIssue Report

April 30, 2012

MEMORANDUM FOR:

COPIES:

FROM:

SUBJECT:

T. J. Dwyer, Technical Director

Board Members

D. Campbell

Training and Qualification Program, Y-12 National Security

Complex

This report documents a review by the staff of the Defense Nuclear Facilities Safety

Board (Board) of the training and qualification program of Babcock & Wilcox Technical

Services Y-12, LLC (B&W) at the Y-12 National Security Complex (Y-12). The review was

conducted March 12-15, 2012. Staff members J. Anderson, D. Campbell, D. Kupferer, J. Pasko,

and C. Roscetti assessed B&W's program against the requirements ofthe Department of Energy

(DOE) Order 426.2, Personnel Selection, Training, Qualification, and Certification

Requirementsfor DOE Nuclear Facilities, and B&W's implementing procedure Y90-027,

Conduct ofTraining Manual (Training Manual). The staff held discussions with personnel from

B&W and the Y-12 Site Office and observed several training activities, including on-the-job

training and classroom sessions. The staff reviewed the execution of training at the (1) site level

(related primarily to access control), (2) Production organization level, and (3) Facilities,

Infrastructure and Services organization level for nuclear workers, shift supervisors, and

journeyman craft personnel.

The staff found that the Y-12 training and qualification program aligns with the

requirements of DOE Order 426.2. The B&W Training Manual specifies a methodology for a

systematic approach to training that generally reflects the guidance in DOE Handbook 1078,

Training Program Handbook: A Systematic Approach to Training. However, the staff identified

several gaps in the implementation of the program, including inconsistencies in the systematic

approach to training that may limit the program's effectiveness. Addressing these gaps would

help ensure that operators are effectively trained to perform work safely. Operational safety at

Y-12 would also benefit if B&W formalized a rigorous continuing training program that is

responsive to emerging needs.

Systematic Approach to Training. DOE Order 426.2 requires that DOE contractors

utilize a systematic approach to training. Key elements of this process include a systematic

analysis of the jobs to be performed and the derivation of learning objectives from this analysis.

Accordingly, B&W's Training Manual outlines five phases in the implementation of a

systematic approach to training. The staff identified deficiencies related to B&W's analysis and

implementation phases.
Analysis Phase-The analysis phase of the systematic approach to training, per DOE

Handbook 1078, is used to identify performance-based training requirements, typically through

the completion of a job task analysis. DOE Handbook 1078 and the B&W Training Manual

require that essential documentation of the job task analysis process (e.g., action steps, logs,

meeting notes, decisions made) be retained to provide a rationale to support subsequent training

policy decisions. B&W personnel could not produce this documentation for any job reviewed by

the staff during this review. The staff also noted one case-involving the core qualification

profile for an operator position in Building 9204-2£ (the Quality Evaluation Assemblyperson)-

in which B&W failed to perform a task analysis. As a result of the incomplete task analysis,

B&W cannot demonstrate that the training objectives for the Quality Evaluation Assemblyperson

address all required tasks.

Task statements listed on B&W's job task analyses exhibit varying levels of detail. For

many certified positions, the task statements are specific (e.g., "place Oxide Dissolver in warm

stand-by~~). For other positions, such as qualified shift managers, task statements are vague (e.g.,

"provide oversight for operations"). Due to the lack of detail in these instances, B&W personnel

could not clearly show how they derived performance standards, skills, knowledge, and abilities

as required by DOE Order 426.2 and the B&W Training Manual. As a result, some positions

with identical task statements have a different set of training courses. B&W personnel could not

demonstrate, in these cases, which sets of training courses are appropriate or whether they

identified a complete set of training objectives tailored to reinforce the principles and learning

objectives uniquely applicable to each worker. In the case of the lockout/tagout refresher

training course, discussed below, the lack of specificity resulted in several learning objectives

being omitted from the course.

B&W completes a task-to-training matrix (TIM) containing the results of the job task

analysis process. The B&W Training Manual identifies the TTM as "one document that can be

used to guide maintenance of a training program," and states that "the TIM serves as a

configuration management document for the development and implementation of the training

program." The TIMs reviewed by the staff did not fulfill these functions. None reflected the

format suggested by the B&W Training Manual, and some required content was absent (e.g.,

learning objectives, training selection category, training setting, and training sequence). The

staff noted cases in which a specific task was absent from the task analysis but present in the

TIM. The staff also noted cases in which a specific course was not included on the TIM but

was identified as a training requirement by the electronic tracking system.

Implementation Phase-DOE Order 426.2 requires and the B&W Training Manual notes

that a training program must consist of a combination of classroom training and on-the-jobtraining (OJT). B&W's program incorporates a variety of training delivery mechanisms. For the

most specific job tasks of certified operators, however, a large fraction of operator training

consists of OJT activities. Most classroom training addresses objectives related to general access

or programmatic requirements. Operators would benefit from a better mix of classroom training

to augment the OJT they receive for their job-specific tasks. For example, seminars on advanced

system characteristics, tabletop walkthroughs of advanced accident scenarios, and classroom

instruction covering one-line diagrams in support of system walk-downs for new trainees would

be beneficial.

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OJT activities are conducted according to a performance documentation checklist. Each

checklist lists several related procedures and includes a single performance objective (i.e.,

"Given the OJT Standards, the employee will be able to demonstrate the necessary skills and

knowledge, as applicable to the position"). The lack ofspecificity in the performance objectives

and in the definitions of required skills and knowledge causes OJT to be largely expert-based.

As a result, specific learning objectives are detennined by the individual trainer on a case-bycase basis, and may not be consistent or complete. More detailed objectives for OJT would

ensure trainees receive a consistent level of knowledge during the qualification and certification

process.

Continuing Training. DOE Order 426.2 states, "Continuing training programs must be

established to maintain and enhance the knowledge and skills of operators." The Order specifies

some high level training topics, and asserts that contractor management may re-qualify personnel

once they have completed the continuing training program, including requisite examinations, but

does not provide particularly robust detail for what constitutes an effective continuing training

program. DOE Handbook 1118, Guide to Good Practicesfor Continuing Training, provides

some additional details on expectations for both fixed and flexible continuing training.

B&W personnel execute a number of activities that may be considered "continuing

training." These include fixed courses specified as part ofthe recertification or requalification

profile for certified and qualified positions (administered primarily on a 2-year cycle). Flexible

elements include Y-12 Site-Level Flexible Continuing Training (focused on sitewide issues but

not issues related to specific divisions or groups of operators), training on procedures and safety

basis changes, distribution of lessons learned, seminars in criticality safety, discussions during

pre-job briefings, and seminars conducted by the Operational Performance Improvement group.

Each of these elements is a necessary part of continuing training and helps ensure responsiveness

to new information.

Very few, if any, of the continuing training elements cited above are formalized in a

program and coordinated across or within organizations to assess and improve operator

expertise. The lack of coordinated program-level goals or assessments outside of the

recertification/requalification cycle inhibits the effectiveness of B&W's continuing training.

While B&W meets the requirement to conduct "continuing training," and high level topics are

appropriately covered, a formal program has not been established to be responsive to operator

needs or to look forward to future operational challenges. The methods suggested in DOE

Handbook 1118 for assessing personnel strengths and weaknesses and tailoring continuing

training accordingly would help ensure that the B&W training program meets the intent of the

DOE Order 426.2 requirement for continuing training.

Specific Course Content. The staff observed a number of training activities. Severalfor example, the Applied Engineering Fundamentals classroom training course-were well

executed. For others, however, the staff noted problems associated with both scope and content.

Annual Refresher Training in Lockout/Tagout-The training session observed by the

staff did not cover all documented objectives. Specifically, instruction on procedural

requirements related to caution tagging was lacking. Additionally, the course provided only

cursory information on the control of hazardous energy sources, methods for isolation of

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hazardous energy, positive protection, and the use of diagrams. For the TTMs that required

training on Lockout!fagout, there were no corresponding hazardous energy control or positive

protection courses listed for the Lockoutrragout task statement. The lack of training on these

topics in the annual Lockoutffagout refresher course and the lack of additional training courses

listed on the TIM under the Lockout/Tagout task statement create a gap in training on the

Lockoutrragout process. The lack of detail in the task statement for lockout/tagout likely

contributes to this gap. Finally, there was no written examination.

Training in Conduct ofOperations-This training, developed as part of a sitewide

Conduct of Operations Improvement Plan, is a considerable upgrade relative to previous webbased training. The course includes hands-on simulator training and discussion of relevant

lessons learned. Throughout the course, however, the staff observed that the training was

confined primarily to the implementation of placekeeping (the primary course objective). While

required placekeeping is a new policy at Y-12, and the training stressed rigorous procedural

compliance, the training's overall value was compromised when certain concepts were

determined to be out of scope. On the simulator, for example, calibration stickers were not

applied to gages, expected readings/conditions were not discussed, unverified operator aides

were used, and appropriate personal protective equipment was not required. Valves included in

the valve lineup were all normally open valves. This is not representative of the types of valves

encountered in an operating facility, which could include locked, throttled, or normally shut

valves, so that the training's practical value was limited. Poorly defined expectations for worker

communication during the completion of continuous-use procedures resulted in ineffective

performance of the simulated task. Finally, there was no written examination.

Feedback and Improvement. B&W often uses training to implement corrective actions

in response to operational events. In many instances, this training is conducted during pre-job or

shift briefings. B&W was unable to show how the effectiveness of this training is assessed, as

specified in the evaluation phase per DOE Handbook 1078. Training personnel stated that the

enhanced floor surveillance and senior supervisory watch programs may follow up on known

issues; it would be beneficial, however, if these programs were required by management to

explicitly determine whether the training has been effective. A formalized continuing training

program, as discussed above, would also help management improve the feedback loop, thereby

making the training program more responsive and effective in limiting the recurrence of

operational events.

B&W uses examinations to assess the effectiveness of training for some courses.

Operational evaluations (i.e., graded walkthroughs) and oral exams also are part of the

recertification/requalification cycle. Currently, these examinations result only in a pass/fail

determination. In order to more thoroughly assess the effectiveness of training, B&W would

benefit from analyzing examination results to identify specific areas of operator need. Currently,

an operator could fail on all questions related to a particular learning objective but pass the exam

overall. In such instances, additional focus on this particular learning objective during the

training sequence may be warranted.

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