ML19253D035

Forwards AD Hotham Re Training & Performance of Plant Workers.Ltr Outlines Ideas & Suggestions for Training Nuclear Plant Workers.Requests Comment

ML19253D035
Person / Time
Site:	Crane
Issue date:	10/05/1979
From:	Byron B HOUSE OF REP.
To:	Kammerer C NRC OFFICE OF CONGRESSIONAL AFFAIRS (OCA)
Shared Package
ML19253D027	List: ML19253D026 ML19253D032 ML19253D035
References
NUDOCS 7912120535
Download: ML19253D035 (7)

Text

s c sta tei errect s, DEVEALYD.DYRCN Fe ' r t pics f.t ea C s T h CT. *

• A

• vJ h3 10 C.C-aceeStarrT

'Ei.t(2-46;2 w e r

• 62-es Crricer att Lea u

• .e M c. t t C r r.c r D qtt :.4 Q

g, a,,,ow q s

(6 W. A.t rTs.4 ST ot tr

t. O I:51721 J)ount of 3&tpresentatibts

' *[' '['['

,_m,,

W ut Le t V.LLact Gnt[N AR v tO SER VICES Ell 35Ijt!1Bt011, D.C.

20M0 0:. n7.s i si IP.!T A wLA* i P.S AN D F A CIL:T'ES LaVALE M'Lt* A h v CC VPENE ATICN October 5, 19 79 re. rc n75 u,,.c n As: sT.,Teo,c DC 1) 749-0300 A ND C a.T IC AL M AT L R sALS ELt F.* ? DJetG SELECT CO'/ Y IMEC ON AGING 14;5 L'et af f Ro*D (302) 448-53t6 H LL 5;NG A'*:: CC%$.vtR INTERESTS Mr. Carlton Kammerer Director, Office of Congressional Affairs

.:uclear Regulatory Commission 1717 H S t.

N.U.

.:ashington, D.C.

20505

Dear Mr. KarrJnerer:

Enclosed please find a letter I recently received from a constituent, Ms. Andrea D.

Hotham, who has professional background in the field of training nuclear pcwer plant workers.

She believes that in the study of the Three Mile Island experience insufficient attention has been given to matters that relate to the training and performance of the plant workers.

Her letter outlines some of her ideas and suggestions on this subject.

I would greatly appreciate it if you could review her ideas and give consideration to her suggestions.

Any comments you might have on this matter would also be appreciated.

With bes t regards,

Sincerely, everl B.

'ron BB3:ds 1540 317 m m20575

s ES 5[?.z Andrea D.

Hotham E,, 3: 15 e483 aooster ccurt Laurel, Maryland 20810 L : '/ -..

(301) 776-7050 fi,a;4 August 31, 1979 The Honorable Beverly Byron g ooD D

kd House of Representatives o

1216 Longworth Building y--

i Washington, D.

C.

20515 oo o

" ear Ms. Byron:

I have been watching with much interest as the Nuclear Regulatory Commission, nuclear industry and private citizens respond to the incident at Three Mile Island nuclear power plant.

I do not have sufficient background to speak to the issues of plant design, emergency planning or economic

. repercussions.

I do, however, have extensive background in training, and my growing concern that a crucial part of training is being overlooked during this recovery and reconstruction period compels me to write to you.

A brief summary of my background may help to clarify the view-points I am about to express.

I have worked for three major reactor vendors in their training programs and am currently employed by a major vendor of nuclear power plant simulators.

I hold a Senior Reactor Operator's license on Commonwealth Edison's Dresden Units 2 and 3.

Prior to my involvement in the nuclear industry, I graduated from Northwestern University with a degree in English and communications and a minor in

, education.

I hold teaching credentials from the states of Illinois and Minnesota.

I wish to empnasize that this letter expresses my concerns as a private citizen and is not in-tended to reflect directly upon any specific company or government agency with which I have been associated.

My concern is chiefly this:

while our industry, the NRC, and concerned individuals everywhere are making tremendous efforts to insure that an incident of similar or greater magnitude than Three Mile Island never occurs again, the fundamental role of the human element is being largely cverlooked.

I am

-roat deal of time, effort and ~cncy is being 1-that

=

g 7,

7y

..w g _

f. gig ig m

the solution to the problem.

My uncasiness is caused by what I see as a trend towards scapegoats and paper tigers; specifi-

_11;, t >. c c: of sirc_latcrs as s31 ation #rcr all training nd the establis; ment of 'ormidatie gcVernnent

' -ficiencies, 4

7.lations that may oe. c.a d e q u a t e, anneccssary, or ;nenforce-2.

I '

ntcnc

• c ici:.ct f " C '" t.;e V - l 3 Lr lZe:fulneEs t.

r1 -c in ir

inC, nor frCm i 20 g DVel. - _f.t's role in

~t:

~ict cf m tal '

_'Ca to l'

,l' c.

+

1540 318

ma o

D D

,t f

Face Two

~

U

'cs. Beverly Syron

,oo oj

, e[

August 31, 1979 the improvement of the industry is that our training, our licensing, our safe and efficient operations are only as good as the people involved.

I have no doubt that our technology, current and developing, is more than adequate to insure the viability of the nuclear industry.

Our primary thrust at this point must be the human element:

individual qualification, motivation, and industry-wide commitment to training.

y comments are focused on three interrelated aspects of training:

training programs, instructor qualification, and testing procedures.

The great majority of our training pro-grams are patterned, in terms of both duration and course material, for individuals with a background 'n the nuclear

'hvy.

I have no intention of discussing tP relative merits of the ':avy program.

It is conmon knowled _ that the source and experience level of commercial nuclear plant personnel is changing.

As fewer and fewer " nukes" are available for rapid transition to commerical operators, the emphasis in our training programs must shift.

We are no longer talking about mere skill-oriented approaches--we must now enter the realm of adult education.

I believe my perception in this area to be sharper than most, primarily because I have experienced first-hand the transition from tyro to licensed operator through industry training.

Only when we begin to treat operator training as real educa-tion will our programs improve to produce excellent, not merely adequate, operators.

The initial step is standardized and validated selection cri-teria.

Since so many utilities feel the teeth of powerful unions, the validation process is vital.

Several utilities have fought the selection criteria battle, and have had moderate success.

I feel it is time for the utilities to cooperate in a joint effort to establish and validate such criteria, sharing the burdens and benefits while creating for themselves the best possible means of selecting personnel to meet their needs.

Once the candidates are chosen, the establishment of a quality training program is the next milestone.

The overwhelming liability in this area is the reluctance of many to adapt to the c h a r.g i.. g s i t u a t i c r and different type of operator candidate.

The ajority of trainers are experienced, ex-military

ctcrr,

- :., can m]3tg to the

,-m

,c-

,,r-

~

~: ;

.a._

does not depend on how. cell he masters the concepts and skills invcived with rcactor operations.

Few can relate to the fact

..t ma:,

.a.

car'.:lates cacnot d i s t i c.g u i s h ".eed to mew" ce :o

.cw" infer nion, F.d_ crseg antly miss some

~_ - "-

_t-1t n c r:al whi' e

• reri.~,.g a lot of trivia.

1540 319

Page. Three.

9 9 <Y6 s

O hahh[j\\jd

'Ms.

Eeverly Eyron g,

August 31, 1979 It is the human experience, especially apparent in structured education, that tasks are learned more readily and rapidly, understood more thoroughly and retained longer when specified in the form of learning objectives.

Witness the difference "Be able to draw X, between " Learn how a reactor works" versus Y, 2 systems; list actuating setpoints; discuss interrelaticnships in terms of controlling neutron flux."

There is no place for confusion in education, particularly when the results can have such far-reaching economic and safety implications.

I feel it is imperative for the industry to develop realistic, standard learning objectives.

I suggest a cormittee be formed, ccmprised of educators, government represe:,t ati ns, ar.d know-laigeable, experienced personnel from utilities, vendors and ccnsultants.

This ccasittee would be chattered to f:rmulate, by rcactor type and plant design, very specific objectives for operator candidates to achieve and maintain through requalifi-cation.

These standards could then be applied to all operator training programs throughout the country, while plant-specific items could be addee to the utilities' internal training pro-the students The opinions and experience of the operators, grams.

instructors leed to be taken into account--decisions have and the been made for too long solely by the managers and chiefs who

~

directly involved in the situation on a daily basis.

are not this could be a difficult and time-consuming task.

I realize I do not recommend it lightly.

In our present situation, most utilities and vendors are in a defensive posture.

They state (or imply) that the student should "know everything."

They to the NRC examiners the unpleasant and untenable leave position of judging this " complete" knowledge and blessing the candidate.

There is no accountability.

No one will stand up and say "This is what our operators must know."

Consequently, the students are caught in a quagmire of data, expected to and assimilate countless pieces of information, deter-

. collectrelative importance of all pointsSand recall any or all mine on demand.

The task is incomprehensible.

As we continue to this and that, we turn out operators who know a little about increase.the ranks of operators whose in-depth understanding of important points may be insufficient to prevent or control a future TMI.

Scmeone must take on the responsibility.

I would like to see

.: 4ndust1 establish and utilize such standards across the 2

ard.

In our current state, ncwever, utilities and vendors e

,-e

=c4t=nt to change or prcgress without e :.:p re s s

a:

.ncs.

If this :='not be 1

._ndied, our only alternative is i_ o h::i e... a N.;.C

>st.ahl.sh c..d enforce such standards.

It is hoped that the S?C would

. =1; ^Cicit d<=tiiled inputs from utilities, cendors and

.itants.

= ' ' '

'L'.7't ee c:

q

;C cets

- _ n ",o 1 3 C 1'C -

.c 21.

Ts.

_ :t

-p

.c

. x.

1540 320

~

. Pace *Four

~

D I *. s. Eeverly Eyron I'O O g F

~

bW n

A;cust 31, 1979 UU l Sul i

a SRC testing program.

The NRC must establish a standard exam bank, not of complete tests but of individual questions.

Each question must have a written key clearly defining those coints to be covered for full credit.

Point value should be

'ssigned for partial credit.

If a student consistently furnishes a

more correct information than the answer key requires, he may ce given extra credit or a corr.endation to his company identify-ing superior performance on his licensing exam.

There must be consistency between what is taught and that is considered testable.

Specific objectives will outline to the instructor what he must teach, will clarify for the opera-tor candidate what.;e must learn and will guile the examiner M thcce subject arcas valid for questionir" Students will no 1cnger " learn the test", concentrating cr probable NRC questions experienced in former tests.

Ouc tions will be validated, poorly-worded or improper ones eliminated.

Examina-tion grades will beccme meaningful, being based on the same precise criteria each time.

Precise record keeping of all examination results, from in-house or vendor training through NRC licensing, will produce clear benefits:

weak areas will be identified for further training, operators reviewing their tests with answer r.eys will be able to correct their mis-conceptions, and the problem of an operator challenging an exam failure will be eliminated. If this extensive process of documentation, validation and feedback seems extravagant or unnecessary, consider the tremendous amount of time and effort the candidate has put into fulfilling his end of the contract.

It is only fair that he receive this consideration in an area that so directly affects his livelihood and career.

Another important milestone is quality control regarding the competence of instructor ; and NRC examiners.

Three Mile Island has taught us that knowledge'of basic informa-tion is not sufficient in itself.

Operator candidates must be able to apply that knowledge, to understand it thoroughly in order to think through solutions to problems.

Currently, our training and testing programs contain a plethora of facts to be memorized--there is not enough emphasis on in-depth understanding or thought process.

This is where we see most clearly the abundance of informed

.r t: :ctional ri sf f who cannot or do not tcach.

Not all 1st:acters med to be licensed--that depends on, chat

1

_'t is

- - : r c ;. t t; r,-

m

_m.

v.___.

_,2m cn of irformation, but a CCFDrChensive Lrocram of facts and

, plication, a r. i x cctween technical newledge and c~r. uni-

. C C u J '. g O d -- - C O ^ ',. 0 0 n

._. '; _ :.1 1 1.'.

." _ _ d._ a _ z 5t

_ t:

.ct01

d ~i

'Ont, r-m 3 ( ~. r.- n t ind utilities, t

cc, c u g ',. {,;. d ?' l C' ' cbCuld be

,r--

- ;g - /

n-

.enefits

~

1540 321

0 0 0 R)

.Fage.F.ive n

Ms. Beverly Byron

,UU

[] D ha a

iugust 31, 1979 U

It follows that it is incumbent upon the NRC examiners to have sufficient in-depth knowledge to appropriately evaluate, from oral and written basis, the operator candidate's thought process as well as factual recall or manipulative skills.

The examiners' knowledge level and conduct during the test should be irreproachable.

Emphacis must be placed on under-standing, involving more than cursory questicning.

Documen-tation of oral e>.am responses is important so consistency can be maintained from one individual test to the next.

It is obvious that quality training requires total support "y *he c o = -r : nt and inducu,- - = m;

's

. t.

e date, see ". ave

'r

.ct

..__.c: red that 1crel o f cc.= _. ent indus-j - t. : de.

iMI

?:.

>~

-t r:, :r

.:- _ a - : f c-ty

., _.. _ _ :, fcolproof plant design or advanced

.nulation.

We also co:2centrate on the peopic--meeting their train-

2:

ing needs so they can meet the highest standards of perfor-mance.

The establishment of a committee and standard objec-tives may be time-consuming, difficult and costly--it is also vital.

Short-term economic considerations cannot be foremost in our minds.

I have enclos~ed a synopsis of points for your convenience.

I hope that my thoughts have been of some interest or benefit--please contact me if you desire clarification or further details on anything I have mentioned.

If a committee of interested and informed persons is established, I would be honored to serve its purpose in any way possible.

I thank you for your patience in reading this lengthy letter.

I write it out of deep commitment to excellence in training and real concern for our nation's energy future, but perhaps my strongest motivation is insurance of public safety.

Our responsibilities are too awesome to allow room for any complacency.

Respectfully submitted, i~

.!/fi- /!

f),,u Andrea D.

Hotham

~ c':~:s 1540 322

Dn r

U D

go 9

S I?;DUSTRY AND GOVER:::'.ENT ACTIVITY FOLLO'.;I::G ' :'I

? ssible panaceas or public reassurance without sufficient substantive effects.

Potential disregard for <ey issue of human centribution to quality of training, testing, operations.

Lac:, of coordination, cooperation, standardizaticn.

SI:'ULATION AND GOVEF'; MENT REGULATIO::

Effective tools only if utilized to full potential.

Foalistic approach required--prec'eding on " wishful thinking" is counterproductive.

OPE; ATOR 'f RAJ';ING 2d ? election criteria, validated and utilized.

';eed detailed standard objectives.

':eed input from those with firsthand experience in training /

operations areas.

eed increased instructor / examiner qualification--including familiarity with education process.

I;eed to establish emphasis on assimilation and application of in f o rm a t ion, not memorization of facts.

TESTING PROCEDURES Strict documentation for validation purposes.

Specific standard answer keys to valid exam bank questions.

Thorough examination of operator's thought process and in-depth understanding as well as factual recall and manipulative skills.

ORGANIZATION Standard objectives committee comprised of educators, govern-ment representatives, and knowledgeable, experienced personnel from utilities, vendors and training' consultants.

Cormittee subdivided into groups by reactor type--individual system assignment by expertise.

Permanent committee comprised of one representative from each original work group--responsible for final consensus.

Decisions to be documented and expeditiously adopted by all training programs--NRC testing based on training standards.

A_CCOU:: TAB ILI TY

=

-5 J-

,.3,.

-d

, ;st. ~1_. J. t 50901aLions a '. 5 f ( C C ~30 n d a t i C T. S.

int effort to produce standards that are t.'. _ve r s a lly a cceptable.

~

e

~;;cipe 70,*yre Of at j } i t j ;g

,3 m,g g;gjting 3

s z

'c rs u

'2C dt ! CL 25.

1540.523

.