A reprint from the 4th Quarter, 2001, NEAL Report

FENOC System for 10 CFR 50.59 Topic of an ANS Paper

    A paper on the creative combination of an electronic performance support system (EPSS)and computer-based training (CBT) presented at the American Nuclear Society Winter Meeting featured the FENOC system. "FENOC's CBT and Performance Support System Used for 10 CFR 50.59." is the paper title. Its authors are Ted Hilston of First Energy Nuclear Operating Company and Larry Grime and Fred Plata of L. A. Grime and Associates, Inc. AcroServices.
    FENOC is one of many AcroServices clients using the AcroHelp EPSS to support their 10 CFR 50.59 program. FENOC's system is particularly outstanding because it includes extensive company and site specific content. Examples include comprehensive checklists for regulatory applicability determination issues such as security, quality assurance and fire protection. Lists of fission product barrier parameters to consider for each unit assures 10 CFR 50.59 evaluation preparers have this important information when addressing 10 CFR 50.59 (c)(2) criteria . For the Davis-Besse site there are several lists based on the UFSAR. Ted Hilston summarized the success of the system: "I received a lot of calls during the early implementation of our new program. I used the AcroHelp system to show the individuals where they could find the answer to their questions. I found that our guidance contained the answers. After a few weeks like that, I now get very few questions."
    The following is from a news release issued November 14, 2001, at the ANS meeting that summarizes the presentation.

    Summary: It's a big win-win situation when your training program doubles as your performance support system. Yet that's what FirstEnergy Nuclear Operating Company (FENOC) accomplished with their transition to meet the requirements of a revised Nuclear Regulatory Commission regulation. The challenge facing FENOC was to re-qualify hundreds of personnel at each of their three Midwestern nuclear power plant sites. FENOC successfully used computer-based training (CBT) and an electronic performance support system (EPSS) from AcroServices.
Since qualification to perform a regulated process was involved, the CBT includes a challenging examination. Such a CBT program is a new experience for many learners. The training delivery is to the learner's workstation; exams are taken on-line at a proctored location.
Ted Hilston, FENOC's lead on the project, said, "Our goals were to provide first class training for the 'must know' information needed to perform the process and to have a state-of-the-art web-based support system." FENOC chose AcroServices to provide the training, programming and subject matter expert input to the project. A task force with representatives from the three FENOC sites met with AcroServices personnel throughout the project to define needs and refine the materials drafted by AcroServices.

    Supporting information: AcroTrain™ software and support services from L. A. Grime and Associates, Inc. AcroServices™ permitted FENOC to efficiently implement the revised regulation 10 CFR 50.59 at their three nuclear plant sites in Ohio and Pennsylvania. This regulation controls changes made at nuclear power plants to determine if the Nuclear Regulatory Commission needs to review and approve the change before it's implemented. Nuclear plant licensees verify that a proposed change is safe and meets regulatory requirements prior to implementation. However, there may be a significant change that fully satisfies the regulations but requires NRC review and approval. Hence, regulation 10 CFR 50.59.
    The licensees must perform a written 10 CFR 50.59 evaluation against eight specific criteria to determine if they require advance NRC review and approval. Licensees review thousands of proposed activities each year that vary from a simple change in the location of an electrical outlet to major system changes. These proposed activity reviews must determine if regulation 10 CFR 50.59 applies. Procedures establish the site-specific requirements for the 10 CFR 50.59 process. Forms with numerous questions must be answered to evaluate proposed activities. Engineers perform the necessary technical analysis to support the determinations. Plant licensees are motivated to avoid unnecessary requests for the NRC to review activities since the reviews can cost $100,000 or more and usually take six months or longer to complete. However, failing to request an NRC review when needed puts the licensee at risk of large civil penalties and perhaps even loosing the license to operate the plant.
    FENOC wanted AcroServices to provide the first drafts of procedures and forms for the new process, a state-of-the-art computer-based system to re-qualify personnel and a system to support individuals when they perform the process.
    "Since we were accountable for the entire system, AcroServices was able to delivery much more than just training or just performance support, but the entire system: define the process and requirements, re-qualify individuals and establish a highly effective support system," per Larry Grime, AcroServices' president and 10 CFR 50.59 subject matter expert. Larry Grime is well known for his expertise with regulation 10 CFR 50.59. He has taught thousands of nuclear industry personnel how to perform the process and consulted to most of the nuclear plants through the United States on this topic. He was able to provide the pros and cons of various options for the new process at FENOC. They had to consolidate their three separate programs into one program for use at all three sites. AcroServices had industry generic CBT and the AcroHelp EPSS. They refined these for FENOC and added the procedures, forms and a custom web site to complete the FENOC 10 CFR 50.59 program.

AcroTrain CBT System Provides Needed Flexibility

    The CBT used the AcroTrain system to present content using PowerPoint® presentations for 54 topics identified through analysis of the tasks that individuals would need to be able to perform to implement the new process. Nuclear industry standards require testing as a part of the qualification process. This particular topic includes several highly technical and legal terms that must be properly applied to change situations. Engineers must function more like lawyers at times when applying the 10 CFR 50.59 process. The presentations covered each point, formative exercises gave learners practice applying the concepts and the AcroHelp system provided more in-depth information for learners who needed it. Learners were also encouraged to raise questions and make comments while completing the CBT.
    Each FENOC site would need to re-qualify approximately 200 individuals. They considered using instructor-led training but based on the success of CBT at the Davis-Besse site and the desire to avoid the high cost of instructor-led training, FENOC decided to use CBT at all three sites. For two of the three sites, this program would be the first highly technical CBT experience. Some individuals had considerable difficulty. Others were very appreciative of the convenience and in depth coverage of the topic. The audience came to the course with diverse backgrounds. Some had advanced engineering degrees and more than 20 years of industry experience. Others were in administrative roles and had a minimum of engineering and nuclear industry experience.
    The AcroTrain CBT authoring and delivery system met the FENOC needs by providing flexibility for the learners and in-depth supporting information. For each topic, the learners had a brief PowerPoint presentation, one or more exercises, and access to the AcroHelp™ performance support system. For this program AcroHelp contains more than 600 pages of guidance, AcroServices proprietary logic diagrams and topic discussions, and provisions for additional site-specific guidance. Thousands of links programmed by AcroServices allow users of AcroHelp to access the specific information for the topic under consideration. Fred Plata, AcroServices' training director stated, "We expect learners to become familiar with the wealth of 10 CFR 50.59 guidance available with AcroHelp while taking the CBT. Later, when they have to apply the process, they will then know exactly how to find the information to answer their questions."
    AcroTrain allows learners to learn by exploring. Learners may proceed directly to the exercises, then review the related presentation only if needed to successfully complete the exercise. Restrictions on the sequence that learners use to complete topics are only limited to those topics having a necessary prerequisite topic.
    When early failure rates exceeded 20%, the questions and responses were reviewed and program changes implemented. Comments collected from the CBT were also reviewed. This led to question refinements to assure all learners properly understand the question. The most significant changes were to add a 'points to remember' feature to the presentation. These points summarize each topic. They concisely present the desired 'mastery' information for each topic. For those individuals needing more extensive material review, or that were uncomfortable with the computer format, the program content was printed out at one site and made available. The AcroTrain system supports such printouts of the presentation and exercises.
    AcroServices designed forms for the FENOC program. They designed dialog boxes to capture the evaluation topic, preparer and title. From the form, users are able to access the AcroHelp performance support system. The information is available on a context sensitive basis. When users complete the form and have the necessary approvals, they electronically submit the completed evaluation. At this time, the electronic copy is a 'for information only' copy. A printed copy with original signatures is the record copy. The submit process includes checks to verify the form is complete. With the paper only system these forms replace, the original copy of the evaluation would be filed only with the activity change package. For screenings, and applicability determinations, thousands of these will be performed each year. In the past, if the NRC or others wishes to review the documents, it was very time consuming to locate the copies. With the electronic copies, site personnel can easily identify the completed forms.
    To complete the 10 CFR 50.59 system, FENOC also desired a web site. From the web site users can obtain the forms needed to complete the 50.59 process. They also can access the data in the AcroHelp performance support system.
FENOC runs the system on their network at each of the sites. Plans are to move the program to a single network server after they complete network modifications at the Beaver Valley site. Although they were not able to access the FENOC network, Ted Hilston was able to qualify consultants in Atlanta via a load of the program on a laptop computer. The consultants were pleased with the program. One commented, "It answered questions I've had on the process for years."