ML19346A033
| ML19346A033 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/15/1981 |
| From: | Aamodt M AFFILIATION NOT ASSIGNED |
| To: | |
| References | |
| ISSUANCES-SP, NUDOCS 8106040405 | |
| Download: ML19346A033 (18) | |
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BEFORE THE ATOMIC SAFETY AND LICENSING ECARD In the Matter of 1
METROPOLITAN EDISON COMPANY 4
Docket No. 50-289 SP (Three Mile Island Nuclear h
Station, Unit No. 1)
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INTERVENOR AAMODT'S FINDINGS OF FACT CCNCLUSIONS OF LAW ON MANAGEMENT IssvEs
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THIS DOCUMEffT CONTAINS
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?93 QUAUTY PAGES
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8106040 YOS-
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Lu line Findin es 1.
Requirements for Iligibility to Si f:r URC Exacinaticn Crder I e.i E, CLI 9
8 a.
Audit of 1MI svents Ko. 1 - 15 pp. 1,2
- b..
Audit Operatbr Accelerateds: raining No. 16 - 22 pp. 2,3
/(
c.
Certification of Competency No. 23 -25
- p. 3 2.
URC licensing Examination -
a.
Validity No. 26 - 36 pp.4 t.
Coaching No. 37 - 40
- p. 5
~.
- i. ann 4ng
- .o. 27 - 5,y pp. 3,e a
r s
]3 4.
Z:ergen cies No. 55 - 60 pp. 6,7 a.
Simulator Training No. 61 - 72 pp. 7,8 E.
Attitude No. 73 pp. E,9 7.
Kanagement of Training No. 78 - E95 pp. 10, 11
([
5.
Fanage=ent of :-lant No. 91 - 97 pp. 11, 12 a.
Shift Rotation Uc. 95 - 100
- p. 22 9.
Operator Acchlerated : raining Irograc No. 101 - 109 pp. 12, 13 Conclusions of law
- p. 14 1
I
r
]
1.
In order to implement Commission Ofder Item I E of August 9, 1979, sp&cial eligibility requirements for Reactor
- Operators (RosJ and Senior Reactor Operators (SR0s) to sit for a Nuclear Regulatory Commission (NRC) examination were set.
Staff Ex.
1, a,t Cl-16.
2.
The eligibility requirements were to participate in a retraining program (Operator Accelerated Retraining Program OARP), and to pass a written and oral audit.
One part of the audit would be a special test on the TM1-2 accident which required a passing grade of 90%.
Id.
3.
The eligibility requirements were_ stated plainly:
" operators who complete the OARP and audit will be eligible to sit for examination."
Id.
4.
The eligibility requirements we t understood by the Licensee.
L,1c. Ex.
1, at 6-11; Lic. Ex. 27, at 141.
5.
The operators were to be' oertified to Be competent by the highest level of management at TMI, the Vice-President, Mr. Henry D.
Hukill.
Lic. Ex. 27, at 163; Tr. 12177-8 (Long).
6.
NRC indicated their intention to enforce the requirements for eligibility.
Tr. 12824 (Boger).
The Operating Licensing Branch testified to the stringency with which the standards would be applied. Id.; Tr. 12833-4; 12805'(Boger).
7.
Licensee personnel sat for NRC licensing examinations the third week of April, 1981.
Tr. 20585-6 (Newton).
8.
NRC testified that the operators were not required to pass the special test on the TMI-2 accident.
Tr. 20688-9 (Crocker).
NRC indicated that no audits or certifications of competency were required.
Tr. 20706 (Crocker); 20697 (Swanson).
9.
NRC denied that they had changed their eligibility re-quirements for the operators to sit for licensing examinations.
T7 10596 (Swanson).
_ - ~..__; ;;; __:. t;mi::si ::.t : : :. 3 10.
NRC stated _tbatstbe; language -iniOEich :the requirements Oere stated was ambiguous.
Tf. 20596 (Swanson).
The ambiguitv
- was that if the requirements were met, the operators were eligible to sit for the examination, but if the requirements were not m e t,,
it did not mean they could not take the examina-tion.
Tr..20597-8 (Swanson); 20695 (Crocker) 11.
The Board did not find the wording of the requirement 9
2 ambiguous.
Tr. 20598 (Smith).
13.
Subsequently, NRC made clearly conflicting statements regarding requirements that would_be'enfurced prior to licensing.
NRC indicated that the licensing examination would adequately test for, TMI-2 events and would not.
Tr. 20696, 20705 (Crocker); Tr. 20752 (Swanson).
14.
NRC stated they would require operators to pass a special: test on TMI-2 events before licenses are issued.
Tr. 20691, 20704 (Crocker); 20697 (Swanson).
They indicated that the test eculd be given by the licensee, and subsequently indicated that auditing by h " c'on t rac t or would be required.
Tr. 20572 (Crocker); Tr. 20752 (Swanson).
- 15. NRC stated they will not require further special training and testing on TMI-2 events for TMI operators.
Tr. 20691-2 (Crocker).
The Board finds that the Iicensee is not in compliance with Commission Order Item 1 E.
Certification of competence on TMI-2 events must be made by an auditor contractor within the view of the hearing.
16.
The licensee engaged two ccntractors to audit their candidates for' licensing.
Lic. Ex. 27, at 66; Tr. 2060 (Newton).
PQS, Inc. audited candidates who had completed 4
an intensive retraining program (OARP).
Lic. Ex. 27, at 66.
17.
The PQS audit reported failure of a number of previously licensed operators and trainees to pass the test (R0 or SRO) for which they had trained. Id. at 67; Lic. Ex. (ff.20755) at.l.
The tests were designed to mock NRC examinations and the passing standard was the same as the new NRC standards, i.
e.,
801 overall and not less than 70 in any category.
Id.
18.
PQS tested on TMI-2 events. Id.
Fifteen of the 28 operater failed at the required 90 level.
Id.
Three operators, one a previously licensed SRO, left the program.
Id.
19.
After a year of retraining, an audit of the candidates for licensing was made by Associated Technical Training (ATT).'
Tr. 2060
) Newton.
Four new candidates for licensing had joined the program.
Tr. 206(/ ) Newton.
Eighteen of the
3 29 candidates for licensing failed at the present NRC standards.
Tr. 1060 6 (Newton)
Of the 11 passing, 5 were SRO candidates and 6, RO.
Id.
20.
Audits _by contractors are predictive of the-outcome on NRC examinations..Tr. 2073
'(C r o ck e r ) ; Tr. 12725 (Kelly) 21.
Licensee did not use the audit to determine who was eligible to sit for the NRC examinations.
Tr. 20605 (Newton).
22.
The results of the.NRC examinations will not be known for months, probably August, 1981.
Tr. 20586 (Newton);-
Tr. 20754 (Swanson).
This is expected by NRC to be aftee the Board has made their decision Tr. 20708 (Swanson).
The Board finds ne reason to expect' that the operator candidates who' failed thu'ATT" audit will pass NRC licensing.
Further, these candidates were not eligible to sit for licensing under standards which implemented the Commission Order Item lE.
by the Vice-President of TMI
- 23. The certification /of the competency of the operators to sit for NRC licensing was to be based on the audits.
Long, et.
al.,
at 32.
24.
The operators who did not pass audits were to be retrained to match"the eligibility require =ents.
Id.;
Tr. 12167 (Long).
25.
NRC planned to check to look at the basis on which the Vice-President would make his cer tification.
Tr. 12066 (Haverkamp).
The basis for certification mentioned was results of audits. Id.
It was assumed that this certification would be made prior to administering the licensing examination.
Tr. 12066-7 (Haverkamp)
The Board finds that the certifications of competency by the, highest level of management D not beMbased on the audits.
The basis of certification needs to e s t ab li sh e d.
The Board finds that none of the eligibility requiremen.s implemented by NRC in response to Commission Order Item 1 E have been met.
~
k
4 26.
Bruce A.
Boger constructs NRC licensing examinations.
Tr. 12809 (Boger).
He has been employed in the Operator Licensing Branch of the Office of Nuclear Reactor Regulation for three years.
His~ degree is not in nuclear engineering.
Boger,-ff. 12770, Act.
27.
Mr. Boger had no formal training in test construction.
Tr. 12787-8 (Bo;er).
He had consulted no experts in test construction. Id.; Tr. 12850 (Boger).
He does not deteimine reliability or validity of tests he constructs.
Tr. 12854; 12797 (Boger).
28.
The NRC examination is an audit examination.
Tr. 12852 (Boger).
29.
Mr. Boger was in charge of the licensing examinations of the TMI-2 operators.
Boger, ff. 12770 at Act.
30.
The current NRC examinations are basically the same as those used prior to the TMI-2 accident.
Tr. 12810 (Boger).
31.
The major difference is in the category on heat transfer and fluid mechanics.
Tr. 12793 (Boger).
There are now five or six questions rather than one. Id.
There are no other additions.
Tr. 12790 (Boger).
32.
The section on heat transfer and fluid mechanics requires no higher mathematics than high school level.
Tr. 12790; 12792
~
(Boger).
33.
Training in mitigating core damage was not begun prior to the examinations.
Staff Ex. 13, at 12.
Nor was training in abnormal transients (Abnormal Transient Operating Guidelines).
Tr. 12875 (Boger).
34.
NRC has no test of the capability of candidates to handle
~
of an emergency in an emergency environment.
Tr. 12857
'p r o'b l em s (Boger).
NRC monitors annual drills in the control room, but does not : squire the full-blown communications of an emergency.
Tr. 12730=1 (Long).
35.
The NRC oral licensing exa=ination will not be conducted at a simulator.
Tr. 20755 (Crocker).
36.
The NRC examination is not a predictor of performance of operators'.
Tr. 12797 (Boger).
The Board finds the matter of operator competency cannot be left solely to be judged by the NRC licensing examination.
5 37.
Past NRC. examinations, including rteent ones, are-available to auditor contractors and others.
Questions used by licensee and auditors may be identical to those on the NRC~ examination.
Tr. 12738, 12703, 12733 (Kelly); 12848-9
- (Boger).
38.
Licensee used the second audit specifically to prepare' the' operators to take the NRC examination.
Tr. 20605 (New*.on).
The audit and licensing examinations were given within'a*few weeks.
Tr. 205 85 - 2 05 S'cINewt on).
39.
An inference of the Board may have been interpreted as requesting that the examinations be made easier.
Tr. 12062-3 (Smith).
40.
The operators were given an intensive two week reviev before taking the examinations.3 Tr. 205fY (Fewton).'
The Board finds the, amount of coaching i
an inadequate substitute for thorough learning.
41.
NRC admitted that if they had enforced the ell'gibility requirements to sit for licensing examination, the licensee would have been short of personnel.
Ir. 20692 (Crocker) 42.
NRC has been concerned for some time that. licensee has sufficient candidates for licensing-to provide for attrition and overtime restrictions.
S fo [f,Ex. /3, a t 2$ & ET.
Licensee then had an additional four candidates.
43.
NRC found the present number of candidates will probably not be sufficient to mann a six-shift rotation.
Lic. Ex. 13,
.at $ & St.
45.
NRC found that one SRO per shift would be sufficient.
ffc/[,Ex. 14, at 22 & 23.
44.
The sixth week was to be a training week, f o'r requalifi-cation.
Lic. Ex.
1, atd -/.2, 46.
NRC found that the plant would be operated more safely with two SR0s per shift.
Tr. 20745 (Crocker).
47.
One.SRO, as the Shift Supervisor, was to move around the' plant to ~ assure the overall safety.
Tr. 20757 (C r ocke r).'
The other SRO, as Shift Foreman, was to supervise the control room. Hukill, et. ah, at 18.
.:,m
6 48.
'w' i t h sne SRO, the Shift Supervisor would be assuming-the' duties of the Shift Foreman.
Tr. 20757 ( C r o c k e r ) '.
He would be tied to the control roo=, or the control room would be without a supervisor.
Id.
49.
One of the lessons learned froc TMI was that there shoule be two SR0s'on each shift. Tr. 20758 (Crocker).
50.
The bacRshift places an additional burden on the Shift Supervisor in that' he is the senior person at the plant.
Tr. 12663 (Allenspach).
51.
The Board is concerned that the findings in the emergenc:
area of the hearing have bs&n premised on requirement of two SROs on each shift.
Tr. 20763 (Little).
52.
NRC found the proposed change to one SRO per shift unresolved.
Tr. 20764 (Swanson).
53.
NRC h'ad argued before the C6mmission that in the area of management,' technical staff, technical qualifications and training, the more stringent requirements imposed on Near Operating Licensees /kN Oka)be imposed on Iicensee.
Term Tr. 20747-5 (Crocker).
NTOLs are required to have two SRos on each shift.
Staff Ex.14, at 22.& 23 54.
Shift Supervisor is direct &d noP to:becosa totally in-volved in any singl& operation In' times o'ftuhergency, when multiple operations are required in the control room. Boger, The Board finds that the management, operators and their training, which are unique to TMI, as well as the emergency plans unique to TMI, require that there be two SR0s on each shift.
The Board further finds that the licensee has not presented any training plans for a five shift rotation.
Licensee has had two years to provide for adequate manning and~ training.
55.
During an emergency, there are requirements to communics with off-site officials who cannot be helpful in solving the additional communicat. ion requirements emergency.
There are within the control room, to other placer in the plant and possibly to off-site authorities who can aid in the c r i s,i s.
Lic. Ex. 30.
56.
Licensee's experts hcd not determined how the capabilities of the op er a t or s are effected by the burdens of communication.
Tr. 12521 (Christensen); 12549 (Gardner);
23722 (Kelly) 57.
The communications requirements were not simulated during training'at t h e B &*a' simulator.
Tr. 12730 (Long).
58.
Training in making decisions in unonticipated situations (Decision Analysis) did nor, included the communications requirements of an emergency.
Tr. 12542 (Kelly); 12 5 2 6 '( Ch r i s t 59.
Licensee's expert and management were not confident that the week of training in Decision Analysis given to
-Shift Supervisors and other management - was sufficient.
Tr. 12169 (Long);.12549, 12552-(Gardner).
60.
Stress in emergencies can significantly alter judgemental-processes.
Lic. Ex. 27, at 112.
A stage can be reached by
. an y - p er s o'n ' wh e r e they are not able to function at all.
Tr.125 (Gardner).
The Board finds that training has not provided for capabilities needed in-the control room in emergencies.
61.
The Licensee uses the B&W simulator in Lynchburg, Virgini for training. Lic. Ex. 27, at 104.
62.
The B&W simulator is much smaller and more limited in scope than the TMI-1 control room.
Tr. 12250 (Ross).
63.
Since the TMI-2 accident, TMI-1 crews have received two hours of training at the si=ulator in TMI-2 events.
Eong, et.
al.
ar 29-30.
They also received an additional-sixteen hours of which 50-75% was training on the TMI-2 accident.
Tr. 12579 (Ross).
64.
Two weeks of simulator training per year is the minimum recommendation.
Tr. 12504, 12468 (Christensen).'
Some experts recommend six weeks.
Tr. 12508 (Christensen).
SUREG 0660 is proposing 160-200 hours.
Lic. Ex. 27, at 110.
65.
Licensee's annual requalification training is a we'ek at the simulator site, with 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> t r a in in g on the simu-lator.
Tr. 12156-7, 12263 (Long).
The effectiveness of these 2.0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> is reduced by the time that is needed to adapt to the differences from the TMI-1 control room.
Some. operators took as much as a day to a day and a half I
to adjust.
Lic. Ex. 27, at 109.
m S
4
. 66.
Each' crew was-run through ton' scenarios in a week's time.
Lic. Ex. 27, at 105.
This is a very small~saeple of the possible scenarios that can happen.
Tr. 12274 (Koss) 67.
Licensee's experts.strongly recommended the acquistion of a replica simulator of the TMI-l control room.
Lic. Ex.
27, at 144 68.
The experts ~ also recommended that an employee or two be specifically trained to coordinate the simulator program.
Lic. Ex. 27, at 98.
The B & k' simulator program has.been severely critized by ~ recognized. authorities. Id. at 107-8.
69.
Licensee 7does not have a simulator coordinator. Id.
at 110.
70.
Licensee does not propose to have a replica simulator until 1985.
Tr. 12145 (Long) 71.
T r a,in in g on a replica simulator is good preparation for emergencies.
Tr. 12565 (Gardner) 72.
The mock of the control room is a completely inadequate training devise.
Lic. Ex. 27, at 98.
The Board finds that the simulation training program is highly deficient.
Assurance of adequate re'sponse of operators.can only be throu'gh training and testing on a replica simulator.
73.
The extent to which training on a non-replica invalidates the training was vividly illustrated by the 4
ineffectiveness of an engineer and superintendent of Unit 1 who attributed that ineffectiveness to lack of familiarity with Unit 2 control room.
Tr. 13121 (Aamodt).
74.
Licensee personnel flagrantly misuse the paging syste=
between the control roo= and the plant.
Tr. 10269 (Sknico).
This behavior is clearly deviant from that in other industrial situations.
Tr. 10269 (Little).
A personal sense of responsibility is needed by control room oersonnel.
Tr. 10270 (Sheridan).
75.
One place where responsibility of operators can and should be developed is in training at the simulator.
Lic. Ex. 27, at 112.
The real world consequences of errors 1
7, 9
should be vigorously called to the attention of the training ~ crews.
Id.
Licensee does not do that.
Tr.
12635-6 (Long).
76.
Licensee assumes knowledge of accident
- 3. o t e n t i a l by operations, personnel.
Tr. 12310, 12326-7 (Long).
A c c i d'en t potential is not included in general employee training. Id.
77.
The Board was interested in the atti.tude of the Chemistry Department in handling samples. Tr. 12302 (Little)
The Director of Training and Education was not aware if a conservative approach used in biological laboratories was required.
Tr. 12302-3 (Long).
The Board finds that the licensee has not seriously considered the evidences of serious lack of responsibility of management and personnel to each other and to the public..
78.
The Department of Training and Education for GPU Nuclear is not represented on the organization chart.
Arnold, at Att.
The Director of Training and Education is Dr. Robert L.
Long.
Long., et.
al.,
at 6.
79.
Dr. Long is to provide policy guidance to the TMI training department.
Id.
80.
Although management should keep abreast of control Ex.,7 2
at 90, Dr. Long had not room design changes, Lic.
read the extensive review of the design'of the TMI-l control room.
Tr. 12304-5 (Long).
81.
Experts recommended that the TMI instructors
- tee hing skills be improved.
Lic. Ex. 27, at 146.
A single ween
~
~ annually of instruction was begun by Dr. Long and considered an adequate response.
Long, at 54 82.
Dr. Long's. background has'been essentially academic Long., et. al.
atJI,7,9 He denied thoroughness in training as a policy required in training nuclear power plant personnel.
Tr. 12327 (Long).
This wts evident in his response to correcting abuse of the paging system, Tr. /kJD ?
(L o n g-), to his irck of knowledge of procedures in the Chem'istry Dept., Tr. 12302-3 (long), and to his assumptions,
- Comparc Tr.10.%9-7dSbet ders b w
m
10 rel-ative to the perceptions of operations personnel.
Tr. 12310, 12326-7 (Long).
p.
at TMI 86.
The Manager of Training / Dr. Ronald A.
- Knief, has the ass 1gnment of* improving the course content and the faculty, and providing.a technical resource.
Long, et.
al.,
at 15.
85.
Dr. Knief stated that increasing. proficiency in ethematics was not necessary, Tr. 12196-7.
He was enfamiliar with safety procedures in the Chemistry, Department.
Tr. 12300 He did not consider the academic qualifications of the instructors important.
Tr.12188.
He made unclear distinctions between training and e d u c a t'i o n, although his goal was to distinguish between
~
them. Tr. 12186-7, 12190-1, All (Kneif).
86.
Dr. Knief professed that he had limited formal training in teaching principles.
Tr. 12182 (Kneif).
83.
Against the recommendation of the experts who reviewed the training program, Dr. Long is not planning to raise the educational levsl through a change in hiring practices.
Lic. Ex. 27,at 143; Tr. 12294 (Long).
84.
Mr. Samuel L.
Newton has been S pervisor of Operator Training at TMI for one year.
He has no other experience
'in commercial nuclear power generation.
His degree is
~
~
~
in nuclear engineering.
He does not have a RO or SRO not license.
His nuclear experience is limited to the Navy 1
nuclear program.
He is trained as a manager.
Long, et.
a at 17.
85.
Mr. Newton reco= mends operators competency to the Vice-President of TMI.
Tr. 12234-5 (Newton).
He supervis nine instructors, develops course material and coordinates t r a'i n in g. Long, et.
al.,
at 17-18.
j 4
86.
Mr. Newton attributed the failures of the operators W
11 to pass the audit on TMI-2 events to be the fault of the-training department.
Tr. 20639 (Newton).
87.
The form of a chaft prepared by Mri Newton raises.
Anderstandable serious doubts aoout his ability to deh'eloe/5ourse material.
T.
20601 (Newton).
Lic. Ex.ff.' 20577 at 1.
The chart was amended by eight footnotes and required a number.of annotations to be clear.
Tr. 20591-2, 20599-600, 20608 (Newten).
88.
The nine instructors at TMI are high-school graduates, some of whom have SRO or RO licenses.
Tr. 12176 (Long).
There are nine additional teaching positions o, pen, Staff Ex.
1, at C6-8, however it is difficult to find appropriate people whc will come to the plant site to t e a c h,.. T r. 12223 (Knitf).
89.
Accreditation principles assign major importance to the quality of the faculty.
Lic. Ex. 27, at 154.
90.
The training organization, except for the instructors have been in their present positions one year or less.
The 3oard flnds the Training Departmen lacks resourcas to communicate with operators they are training.
Structar is not a substitute for adequate and appr opria t e training, dedication to thoroughness, e
91.
Mr.-Henry D. Hukill and Mr. Ronald J.
Toole, the Vice-President and Mu ager of TM!, respectively, have been at TMI less than a year.
Neither's degree is in nuclear engineering.
Neither has an operator's license for TMI-1.
Hukill, et.
al.,
at 4-10.
92.
The Supervisor of Operations, Michael J.
- Ross, held his prssent job at the time of the TMI-2 accident.
al at 11-12.
Mukillaulil:l consuats witn Mr. Ross concerning the competent Mr.
of operators to be licensed.
Tr. 12345 (Newton).
94.
The Supervisor of Operaticos and the Operations /Engir Nuclear failed the special test on TMI-2 events.
The lat:
individual failed cue-retest. 2,t E'. M #C 7SS 8/-
i l
95.
Plant managers are presently not trained in managemer-b I
~
I
~
,4 technicues.
Tr. 12661 (Allens:ach )
96..
"perat.rs are not paid cc perable
.c the air craft industry. Sr.10375 (Sheridan) 97.
Licensee's exper s, in assessine the ; AE2, caution that frequent change in shift leads :: dissatisfaction, poor cotivation and poor perf:r=ance.
Lic.
- x. 27 at 148.
Licencee plans to re: ate _ the assign =ent of each shif t on d M#
a weekly basis. Idf 98.
Weekly rotation of assign =ent with six crews (1.
e.,
3 daytimes, one evening, one ni ht ), the crews w:uld te E
in volved'in a chanEe of shift for 5CH of their working weeks.
With four or five crews, shift change would be experienced from 6C to 75h of their w:rking weeks.
99.
fhe record indicates the. amount'.cf change is-about ence in six weeks, and doesn't count a change from day to evening shift.
Tr. 12245 (Ross).
100.
Licensee's expert suggested that shift rotation, and particularly to the backshift, should be examined.
Tr. 12450 (Christensen).
101.
ihe Operator Accelerated Training :-rcGra: was begun to prepare the licensed operators (24) and trainees (4) f r NRC licensing Examinations.
Lic. Ex. 2.7,at 1.
Candidates who took training in TM1-2 events, satisfactorily 00 plete the training progra: and pass the_ audit exats would be eligible to sit for NRC licensing examinations.
Id. at 141.
102.
Of the 26 candidates,15 failed the audit on IMI-2 events.
Zight failed the written RG or SES examina:3cn. Six failed or marginally passed the cral exa=ination, f
Lic. Ex.
ff. 20577, at 1.
f 9 2, O
103.
The conclusions of he reyort state tha: the iA??
provided the operating staff with "c:=prehensive knowledge of thecry, principles of operation, kinetics, ther=odynacies and heat' transfer.."
Lic. Ix. 27 at 141.
~he therrodyna:ics course was a hi6h school level course.
Tr. 12587 (long).
104 an accreditation model for engineering schcols was used :: evaluate the progra=.
Lic. Ex. 27 at 1, 150-3.
Accreditation check lists for engineering schools appear at 154 and 155, lic. Ex. 27.
The review cocci::ee. concluded that there were no accreditation criteria to follow.
Tr.12589 (long).
105 The 'com:ittee found that the instrue:crs were. lacking
~
in teaching abil1+y.
lic.~Ix.-27,iat 146.
They found the audio-visual aids inadequate.
I d. 2 6'.
.The. facilities were
" woefully" inadequate (cold, dirty ). Id. ' Twenty percent of the courses,where the instructors were evaluated as t
.. deque:p.in their. presentation, were repeated.
Tr. 12605 ina
)
(Eelly).
106.
A :ost inexact method was used to rate instructors:
evaluation by a co-lhstructor...Lic,. Ex. 27 at 60 The.
ratings were quantified to two decimal points.
Id.
107.
Courses or. which peekly qhi: secre's averaged le'ss than 70% were also repeated.
Id. a: 61.
108.
There was no correlation between the ratings and the scores en the tests.
Aamodt, Attach. 2.
Licensee explained 1
that ratings have little validity.
Ir.1322C-1 (Long).
109.
Several trainees pasaec all tests while previously licensed operators failed one or more parts.
Lic. Ex. ff.
-20577, at 1.
14 The 3 card finds that the OAR 3 was n::
designed :: successfulle i=rir the knowledge intended. Con'clusi:nt::: thd contfary are unsupper ec.
Conclusions cf Idw in accordance with Com:ission Orders CLE - ?c - 5, CII - 8C - 5, and CII 3, and based on the evidence of the reccrd of this proceeding end the f:regoing findings Of fae: related :: =anage=ent ccapetence, the 3 card concludes:
1.
The licensee accelerated and recualification training the training of all of prograts have failed to augment l
spera: ors and Senior Operators assigned to the contro room.
2.
The licensee has not conducted a 100 percent examination of all operators in the area of nctural circula-ivn and small break less of cociant accidents incluf.ng revised procedures and the ~IC-2 accident.
3 The licensee has not trovided for sufficient numbers of capable Operators and Senier 5perators to provide for manning, overtime restrictions.and attrition.
4 The licensee do es not have.the management or, technical ~res5uici3'::5'ofirsti the_p1,dht shfi1Pj"~~
5.
The licensee should not be allowed to restar; the plant.
Re5pectfully submitted.
~
g i.ari r e F.. Aa=cd V
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AAh 5/23/81 Cer ficate of 5erti _ce I hereby certify that a true and correc c:py cf Intervener Aamod: Findings ef Fact and Cerclusiens of lal was served in person to the parties on the attached Service list.
Those parties marked
- were served in person on Fay 22,1981.
Those parties tarked with an + were contacted api agreement =ade for service in person en or before F.ay 25, 1981.
All other parties were served by deposis in the U. S. kail, first class, postage prepaid on Fay 23,1981.
E-e<.<.u-L I
d ti The present document served replaces :ne entitled Intervener Aacodt Proec sed Findines of Fe.c and Conclusions of law served in error en parties marked +.
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