ML20032C232
| ML20032C232 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 11/03/1981 |
| From: | Brown N, Long R, Newton S METROPOLITAN EDISON CO. |
| To: | |
| Shared Package | |
| ML20032C214 | List: |
| References | |
| ISSUANCES-SP, NUDOCS 8111090529 | |
| Download: ML20032C232 (31) | |
Text
,
o LIC 11-03-81 4
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Mattet of
)
)
METROPOLITAN EDISON COMPANY
)
Docket No. 50-289 SP
)
(Restart)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
LICENSEE'S TESTIMONY OF ROBERT L.
LONG, SAMUEL L. NEWTON, AND NELSON D.
BROWN 8111090529 811102 PDR ADOCK 0500028
l TABLE OF CONTENTS I.
Nature of Testimony..............................
1 II.
Training & Education Department Orientation Prior to July,1981 2
III.
Operator Training Administration Since the TMI-2 Accident...............................
4 A.
Instructions to Examinees 8
B.
Proctoring 9
C.
Grading 9
D.
Safeguarding the Integrity of Exam Materials........................... 11 IV.
The Re-Examination Process....................... 11 V.
Coaching......................................... 14 VI.
Une of Independent Examiners..................... 16 VII.
RWP Training..................................... 19 VIII.
New Procedures & Policies Related to Exam Administration and Cheating...................... 24 A.
Administration of Examination Proced ure................................... 25 B.
GPU Nuclear Policy Regarding Cheating, Fraud and Misconduct.............. 27 C.
Standards of Conduct........................ 28 D.
Adherence to Policies and Procedures........ 28 IX.
Conclusions...................................... 28 :
TMI-l Replacement Operator Training Program Description :
TMI-l Senior Reactor Operator Replacement Training Program Description :
Licensed Operator Requalification Training Program Description :
Radiation Protection Examination Answer Sheet of Harry E. Williams, Jr.,
April 28, 1981 :
Radiation Protection Examination Answer Sheets of Other Individuals Tested on April 28, 1981 :
Administrat' ion of Examinations, Procedure No. 6200-ADM 2600.1 l :
Qualifications of Nelson D.
Brown l
-i-
/
BY MR. NEWTON I.
Nature of Testimony My name is Samuel L. Newton, and I am the Operator Traini 3 Manager at TMI.
While this represents a change in title since my earlier appearance before the Licensing Board in this proceeding, my responsibilities remain unchanged, and are described in detail in 1 174 of the August 27, 1981 Partial Initial Decision (PID).
My qualifications also were the subject of previous testimony, and are described -in the ?ID at 1 175.
My testi. mony is directed at Licensee's admini.strative practices for licensed operator exams since 'the TMI-2 accident. t s
I will address the practices of the TMI Training Department
\\
prior to the recent discovery of cheating by two operators on-the NRC examinations as well as the other training admin'istra-
~
tive issues.
With me is Nelson D.
Brown, who is the Supervisor -
of Licensed Operator Training.
Mr. Brown's statement.of qualifications is provided (Attachment 7).
While I am familia'r with training practices since the TMI-2 accident, 1 did not arrive at TMI until April of 1980, and thus cannot directly address administrative practices during 1979 and early 1980.
Mr. Brown, however, has been in the TMI Training Department since 1975, and thus can answer questions on qualifying exams during the period prior to 1980.
Also testifying on the subject of training administrative practices is Dr. Robert L.
Long, the Director of GPU Nuclear's Training & Education,
q i1
~
4
, e q
Department. i Dr. Long's qualifications also have been previously submitted and discussed in this proceeding.
See PID 4
,~
1 171.,.'
BY ' DR. - LONG 7
II.
Trair.ing & Education Lapartment Orientation Prior to July, 1981 Before discussing the operator examination procedures s
previously utilized by the TMI Training Department, I would Llike to focus briefly on' the ' orientation which the Training &
1 Education Department has given its instructors since the TMI-2 acc1 dent'.
In summarizing this program, I hope to clarify the addinistrative issues with which na have been concerned in the
~
past year and. a half.'
s The Training & Education Department deliberately considered the elements needed to provide our instructors an orientation towards four philosophy of training and education.
An Instructor Development Program was then established last l
year at TMI.
During this five day program, emphasis was placed upon (19. principles of good instruction, e.g.
effective speaking, planning and conducting a training program, selecting media and materials, and preparation and use of lesson plans; (2) instructor performance, emphasized through " mock" performances analyzed by staff and participants for their effectiveness in meeting their stated objectives, presentation techniques, and use of visual aides; and (3) principles of testing and evaluation, through analysis of techniques for
determining effectiveness of instruction.
Our principal goals in conducting this program were to provide a practical means of training instructors to become learning-and learner-oriented; to improve the quality of training by directing our instructors towards measurable, realistic training goals and clearly defined learning objectives; and to expand our instructors' understanding of training design, presentation and evaluation.
In the past, the focus of the Department has not been on methods for ensuring the security of our exam process through such means as instructing operators not to cheat on exams and 100 percent proctoring of examinations.
In hindsight, this omission in instruction was clearly a mistake; however, I am reluctant to be too self-critical on this subject because the implicit understanding which I believe every member of our teaching staf f has and had in the past is that cheating is totally unacceptable behavior and not only is not condoned, but is essentially incomprehensible in the context of training in preparation for seeking an NRC license to operate a nuclear power plant.
I cannot overemphasize my certainty that the unspoken proposition that one was to do one's own work (unless an assignnent was intended by its nature to involve working through problems with others) was not articulated because it was a second nature proposition, just as one probably does not s
tell factory workers not to steal parts from the assembly line.
Today, with more " lessons learned" on this subject, and in order to safeguard the integrity of the teaching programs which _ _ - - _ _ _ _ -
we have carefully and thoughtfully developed for our operators, emphasis will be placed on the integrity of exam administra-tion.
We understand that this is necessary in order for the NPC, the public and us to have confidence in the capability and integrity of our operators, to assure that the operator trair.ing program is a sound measure of individuals' readiness to serve as licensed operators, and for the benefit of operators who do not engage in misconduct.
BY MESSRS. NEWTON AND BROWN III.
Operator Training Administration Since the TMI-2 Accident As discussed in Licensee's previous testimony on Training and reflected in the PID at 11 163-207, licensed operator training at TMI has undergone major revisions since the TMI-2 accident, with major organizational and staffing changes instituted within the TMI Training Department, as well as complete revisions made to the structure and content of the operator training programs.
Essentially, operator training consists of " replacement" training, termed " Category IV" training because of its labor union classification, which is the program designed to train individuals who have not previously served as control room operators at TMI, and
- requalification" training, which is the cyclic program that all licensed TMI operators must take each year in order to maintain their licenses.
In addition, separate qualification and requalification requirements exist for new and requalifying senior reactor operators.
_4_
Since the-accident, most of the changes which have taken place in the operator trai;41r 9 program reflect substentive changes in naterials Laught, and the complete restructuring of the programs themselves, e.g.,
with the emphasis on classroom instruction, rather than self-study work in the RO and SRO replacement training programs.
Less attention has been paid to training riogram exam administrative procedures.
Nevertheless, the new operator training programs do include considerable administrative requirements applicable to each specific program.
The TMI-l Replacement Operator Training Program Description (Attachment 1) and the TMI-l Senior Reactor Operator Replacement Training Program Description ( Attach-ment 2), approved in January and May of 1981, respectively, provide for record retention of training documents, including lesson plans, student handouts, completed OJT task sheets, oral exam summary sheets, exam keys, and' completed exams and quizzes (written and oral), as well as other pertinent qualification records.
Candidate progress reports are to be maintained and updated regularly during the course of the replacement and requalification programs.
Moreover, these programs specifi-cally require the Supervisor of Licensed Operator Training and the course instructors to evaluate the programs annually for,
among other thing s, the adequacy of records, and to report their findings to the Manager of Training and the Manager of Operations at TMI-1. -
The Licensed Operator Requalification. Training Program Description (Attachment 3), was approved in July of 1981, and will be implemented when annual requalification training resumes.
It includes similar provisions to those described above as well as other important administrative procedures.
For example, training attendance requirements are very specifically delineated; closed-book written quizzes are required af ter each week of lectures; quiz administration and grading is specifically described; annually-required plant drill scenarios are required to be planaed and approved by the Manager of Operations; and OJT requirerients are specified in great detail.
Of particular importance is the specification of written comprehensive exam administrative procedures, including maintenance of an exam question-and-answer file or " pool" from wnich exams are prepared.
Emphasis is also placed on establishing a structure which will enable " consistency of questioning" while " minimizing possible compromico of examinations prior to administration." Attachment 3, at pp. 39.0-43.0.
It is the intention of the Training Department t
to revise the RO and SRO replacement programs described above to ensure inclusion of similar administrative requirements, as
[
applicable.
l l
In evaluating Licensee's exam administrative practices since March of 1979, it is important to recognize that operator training programs and personnel have been continuously chang ing, resulting in the programs described above, and the current Training & Education Department.
During this period of l
1 I
time, Licensee has conoucted at TMI the Operator Accelerated Retraining Program (OARP), which culminated in the " Kelly" comprehensive examinations in April of 1980, administered by Mr. Frank Kelly of PQS Corporation, a portion of which constituted the initial Category T exam, covering TMI-2 accident material.
Following the OARP, requalification and initial qualification or replacement training has been ongoing,
with the administration of the ATTS "moex" exams and the NRC 's exams in April of 1981.
Numerous makeup training sessions and tests have also been administered fo r individuals whose oral or written exam results were initially unsetisfactory, e.g.,
Category T makeup exams.
Formal procedures for exam and quiz administration during these programs did not exist.
We have attempted to descrit ? below, to the best of our ability, the manner in which exams and quizzes given during these various training programs were administered.
Finally, in responce to the issue raised concerning the reluctance of one of the training instructors to answer questions concerning rumors and the use of crib sheets and unauthorized materials, as this individual explained in a subsequent NRC interview, his reluctance to answer the questions posed to him by the NRC interviewer was based on the rambling and, essentially, compound nature of the investigator 's questions.
When subsequently asked specific questions by NRC, the instructor had no difficulty stating his absolute lack of any previous knowledge of cheating or misconduct on the NRC or Company-administered examinations.
The instructor did overhear the phrase, " passing papers" in a discussion between two people he walked by in the Training offices several. weeks after the NRC exams.
However, not until
.the cheating incident was uncovered in July, and NEC's investigative reports issued, did the instructor consider that the phrase he had overheard was a possible reference to cheating.
A.
Instructions to Examinees i
The written and oral instructions given to operator examinees during. annual requalification and qualification exams i
and weekly quizzes have varied, both according to the nature of the exam being given, and the instructor giving the exam.
Mr. Kelly, of PQS, describes in his testimony his administra-tion of the mock exams given at the end of the OARP in April of 1980.
The ATTS or " mock" exam given in April of 1981 was not accompanied by written instructions.
Oral instructions were given, although not on the subject of cheating.
i Generally, annual requalification exams at TMI included written instructions; however, these instructions did not include the directive not to cheat.
Directions included such matters as answering questions on separate paper, how an i
examinee could determine which questions only needed to be answered by senior reactor operators, and the minimum passing grade.
Oral instructions varied according to the instructor, with respect to both requalification exams and weekly quizzes given during the course of the training program.
Several instructors recall that they specifically directed students to do their own work on annual requalification exams. -
B.
Proctoring Written examinations and quizzes given in the classroom at TMI were generally proctored.
(Closed book quizzes were also given on take home assignments, which were not proctored.)
However, because the emphasis of proctoring was on the availability of an instructor to answer questions, as needed, and not on the need to monitor the classroom for miseenduct, proctors did leave the classroom for periods of time.
In retrospect, in order to ensure proper conduct, to protect individuals who successfully pass exams, to avoid the possibility of compromising the exam process, and to remove any temptation to cheat which the absence of a proctor might create, all closed book exams and quizzes should have been, and l
from now on will be, fully proctored, as discussed by Dr. Long later in this testimony.
C.
Grading Generally, quizzes given to operators during the i
qualification and requalification programs were graded by the l
l instructor teaching that section of the program.
In some instances, quizzes were reviewed to determine areas of l
weakness, but were not numerically graded.
Comprehensive exams, such as the operator qualification (Category IV) exams, sometimes were graded by an assigned individual who made up the exam based on a pool of questions provided by each instructor teaching portions of the program.
In other ins tances,
comprehensive exams were made up and graded by a number of ind ivid uals. !
The ATTS or " mock" exam was graded by nine individuals, including members of the Operator Training Department (Messrs.
Brown, Boltz and Husted) and contractors from ATTS.
The exams were taken in two "se ts"; that is, the 36 RO exams given consisted of 20 " set A" exams and 16 " set B" exams.
Similarly, the 20 SRO exams administered consisted of 8 " set A" exams and 12 " set B" exams.
Thus, the exam was given in two intervals, with different exams given each interval.
All 56 examinations were graded over one weekend.
The exams were divided topically, so that one grader looked at every answer to a particular question; however, that individual did not necessarily look at only questions contained on one set of the exams.
Nor did he look at the answers in a particular order, i.e., he may have graded Operator A's answers after looking at-other exams in connection with the first question on one topic.
He may then have graded the next question on the same topic beginning with Operator A's answer.
The ATTS exam graders did not suspect cheating on the exams they administered.
They did not know or hear rumors that cheating had occurred on this exam prior to August.
We attribute their nondiscovery of cheating to the short amount of time in which the various exams were graded in a rather rote fashion with the use of an answer key, the absence of a consistent order in which the exams were graded, and the general similarity of correct answers to a particular question.
This exam was proctored; however, a proctor was not always in the room.
j l
D.
Safeguarding the Integrity of Exam Materials Licensee had no written procedure to safeguard operator exam materials; howaver, instructors do have locked file drawers to facilitate exam security.
Moreover, we have no reason to believe that the integrity of operator exam materials was ever compromised, or that instructors did not take care to ensure that operator exam materials could not be obtained prior to taking an exam.
Mr. Kelly addresses in his testimony the administration of the mock comprehensive exams following the OARP.
With respect to the ATTS exam given in April of 1981, different exams were given on different days.
Moreover, examination questions were handed in at the end of the examination.
Prior to the exam, ATTS kept possession and maintained security of the exams.
In general, with the creation in 1980 of a separate Administrative Support section of the TMI Training Department, administrative work generally has been allocated to that organization in an effort to reduce administrative demands on instructors.
- Thus, historical records have been maintained by Administrative Support; however, training instructors are still responsible for the integrity of an exam prior to its use.
BY DR. LONG IV.
The Re-Examination Process The Training & Education Department within GPU Nuclear Corporation, which has been organized in its current structure
since early 1980, intends to continue the policy of allowing individuals who fail examinations, or who fail to achieve a high level of proficiency on a subject area or areas, to re-take the " examination.
I can say without equivocat' ion that this process is not intended to ensure that individuals who lack the requisite knowledge somehow muddle through the training program, and then perhaps muddle through the NRC exam and-become licensed operators.
In my view--and I believe that this is a fundamental j
principle of education--focusing upon a particular subject area streng thens an - individual's understanding of that material.
Moreover, the re-examination process does not simply consist of f
taking an exam or quiz, failing it, and them immediately re-taking the exam.
Rather, we believe that if an individual appears to lack a thorough knowledge of materials -- a fact which may be apparent from a quiz on the subject, from his performance in OJT, or from an oral or written comprehensive exam -- it is the responsibility of the instructor to identify that weakness, and to provide to an individual additional instruction, reading materials, exercises, or whatever training tools are appropriate to assist that individual in gaining the requisite undersranding.
Thus, a major purpose served by both quizzes and j
examinations in our licensed operator training programs is to
{
focus operator instructors on areas which were not understood by a particular individual or, perhaps, were not taught sufficiently well.
Our procedures provide for discdssions
between the Operator Training Manager and TMI-1 Manager of Operations in the event an individual repeatedly fails examinations to determine whether the individual lacks the ability or motivation necessary for the job, whether additional training is appropriate, or whether there is a personal, attitude or other problem which is resulting in deficient exam performance.
However, we do not believe failing an exam, which generally means failing to achieve at least 80% on specific subject areas, necessarily indicates that an individual should be automatically disqualified.
In summary, our training programs are written to ensure that deficiencies in operator performances on exams are monitored, remedied through additional training, and re-evalua ted through re-examination in the area (s) of deficiency.
This method of instruction is carried out in specific instances for individuals, as well as generally, in our formulation of lecture topics for the annual requalifica-tion ;nogram.
One of the factors which the licensed operator instructors censider in determining the focus of their lectures is the degree to which the material is understood in depth by the operators, as reflected in their previous comprehensive annual examinations.
During the requalification program lectures, emphasis is placed on the materials on which the 1
l operators achieved the lowest grades in the previous requalifi-cation or teplacement training program.
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f i
BY DR. LONG, MR. NEWTON AND MR. BROWN V.
Coaching
" Coaching," which we understand to be teaching an examination, rather than teaching the complete subject area, in our opinion is not the teaching method employed at TMI.
- Nor, on the other hand, can we say that this phenomenon is avoided entirely.
The Training & Education Department is committed to the well established educational method of criterion-referenced instruction.
This approach relies on developing behavioral learning objectives which serve to focus both student and instructor attention on the performances sought as a result of the instruction.
This has the distinct advantage of avoiding the " hide and seek" game which we believe frequently exists between a teacher and students for determining what subject matter will be on an exam and, generally, what information the teacher really wants the students to understand.
Sometimes, the learning objectives call for memorization, e.g., stating NRC's radiation exposure limits or numerical values for plant reactivity coefficients.
In other cases, the - obj ective requires explanation of a concept, e.g., defining what a reactivity coefficient is and describing how it is used and why it changes with various plant conditions.
We do not believe that this teaching philosophy and method results in students ignoring other materials taught; rather, it forces teachers to organize their lectures and materials around basic concepts and necessary information, and allows students to more easily determine the significance of the information communicated to them. l
The development and use of behavioral learning objectives is an important part of the TMI Instructor Development Program (described in Section II-of this testimony) which has been completed by all licensed-operator instructors.
The upcoming Advanced Instructor Development Program -is being designed to provide substantial additional emphasis on criterion-referenced instruction.
As training programs and lesson plans are developed, updated, or otherwise revised, increasingly better behavioral learning objectives are incorporated through the joint efforts of the instructors and their supervisor / manager.
Finally, we believe that it is important to recognize that operator training, like any other educational process, does involve a significant amount of memorization, as well as conceptual understanding of materials.
In order for an individ ual to succeed on a comprehensive exam, such as our annual requalification exams or the NRC license examinations, a great deal of time must be spent by that individual memorizing formulas, important terminology, procedures, etc.
This process is no different from the process which we understand lawyers, doctors and engineers engage in when they are licensed.
In order to determine whether an individual has " learned",
i.e.,
memorized, this material, test questions frequently will be
- rote, e.g.,
ask the student to write a particular formula.
In our view, this does not constitute " coaching."
On the other hand, we do not believe that concepts can be memorized; nor do we believe our quizzes and exams permit short-circuiting the lear. ring process by complete memorization of materials.
For -
example, we alter the nature of conceptual questions suffi-ciently to assure that an individual really does understand the principle and has not just memorized a definition.
While we may very well tell our students tha t they will be tested on a particular concept because of its importance, by changing the nature of the question slightly when we test students on this conceptual material, we can fairly easily determine whether the subject matter is genuinely understood.
In addition, of course, through the required oral examination process which in our annual exams may vary from four to six hours, we can rather easily determine an individual's depth of understanding.
t BY DR. LONG AND MR. NEWTON VI.
Use of Independent Examiners one of the issues in this proceeding is the adequacy of Licensee's plans for improving the administration of future Company qualification examinations for licensed operators and candidates for operator licenses, including the need for independent administration and grading of such examinations.
Section VIII of this testimony, by Dr. Long, discusses our new procedure for exam administration, as well as several other pertinent policies.
With respect to the use of independent examiners, we do not believe that this is responsive to the issue of cheating, nor do we see it as a necessary or even a desirable step to take.
The fact that cheating took place on an NRC-administered examination, and on exams written by ATTS and administered and graded by ATTS and members of the TMI operator training staff,,
indicates that cheating can occur on any exam, regardless of who writes, administers or grades it.
What we as educators and examiners must do is preserve the integrity of our training program and examination pro ~ cess.
We do not believe that the answer lies in delegating this responsibility elsewhere, e.g.,
by using outside contractors to administer exams.
Rather, we must improve our own administrative processes to protect against abuses such as copying exam answers.
In our view, there are a number of things that GPU Nuclear can, and hopefully has, done to prevent cheating.
Management must make clear to its employees that cheating is totally unacceptable.
The importance of the operator examination process in determining the qualifications of operators must be clearly articulated.
In addition, the consequences of cheating must be clearly understood.
Mr. Bukill in his testimony addresses the Company's efforts in these areas.
From our perspective as members of the Training & Education Department, we must assure ourselves that we have done everything possible to avoid compromising the extensive process which we have so carefully developed to train operators.
To this end, we must establish and follow procedures on exam administration, document control,~ record retention, and other safeguarding principles.
One of the major reasons we do not support the use of independent examiners on a regular basis at TMI is not only that we do not think it is particularly responsive to the cheating issue, but also because we believe that an instructor -
who has worked with' students over an extended ~ period of time, who has developed the teaching materials, who knows the facility and its procedures very well, and who understands first-hand the potential weaknesses of his students, is in by far the best position to write and grade an exam.
We are confident in our teachers and training managers, and our experience tells us that they write exams which focus on the material which, in our view, is most impo r tant.
In our efforts to improve the exam administration process we do not want to reduce the substantive value of the teaching program, of which quizzes and exams are an integral part.
We believe that this is the risk that one takes by substituting outside contractors for regular training staff when it comes to writing and administering exams.
Now that we have increased our training staff so that we Jo not have to rely on outside contractors, it would be a disservice to our program to opt for that route because of our past administrative shortcomings.
Finally, the "outside consultant" verification of the
- qualifications of our operators, as well as the adequacy of our operator training program, is the NRC operator license examina tions.
Of course, this exam process can be abused, too, as we now well know.
And we anticipate that like us, the NRC staff will strive to better protect itself from such abuses.
Here, again, we do not believe it is a matter of who adminis-ters the exams, but how well exams are administered.
BY DR. LONG VII. RWP Training While I cannot directly address the specific allegations of cheating which I understand have been raisci concerning one exam in April, 1979, by a Mr. Harry E. Williams, Jr., a former contractor employee at Three Mile Island, I will attempt to describe the context of the program to which his allegations relate, and the information I have been able to gleen from past Training records and from present and former Training personnel.
Every individual who works at Three Mile Island, including Licensee employees and contractor personnel, must take General Employee Training (GET) on an annual basis.
(For very'short visits, waivers with escort are permitted.)
Personnel who do not work in so-called radiation areas of the plant (where there is a reasonable potential for radiation exposure above a specified level) need only take the basic health physics course given by the Training Department.
This course covers pertinent emergency plan information, basic elements of health physics, security, safety, NRC and site regulations.
Individuals who t
(
l need a radiation work permit (RWP) in order to do their jobs because of the areas of the site in which they work must take a more extensive, intermediate health physics class, frequently l
called RWP training.
While the health physics courses available for various personnel working at TMI have changed over the past several years, both before and after the accident the basic distinction between individuals who were required to l l I
have an RWP (and take RWP training ), and those who were not, has remained the same.
GET Training, both basic and intermediate, was (and still is) required to be retaken by all employees on an annual basis.
Thus, many of the individuals taking the exams had been trained cnd tested on the material on a number of previous occasions.
In order to pass the intermediate or RWP course, an individua'l was required to attend the training session and successfully take the te s t.
Once an individual met these criteria, he received from the Security Department an "RWP" indication on his or her regular identification badge.
In order to go into a radiation area, however, at least in the time-frame of the spring and summer af ter the TMI-2 accident, it was also necessary to get checked through one of the designated health physics control points into the plant.
Thus, obtaining an RWP sticker on your badge did not entitle you to enter RWP areas of the facility.
To pass through a control point, it was required tha t there be on file a record of tne person's respirator fit, which verified tha t the individual had participated in a procedure to ensure that the respirator issued as standard equipment fit properly.
- Also, each individual had to have a thermoluminescent dosimeter (TLD) issued to him, a current whole body count on record and a current physical on record.
By the fall of 1979, this system was fully computerized.
Prior to the TMI-2 accident, each year approximately 1,500 to 2,000 individuals took GET (both basic and intermedia te _
courses, and including individuals who were requalifying).
With the tremendous influx of individuals onto the Island af ter the accident, the number of people taking GET rose to very roughly 1,500 to 2,000 individuals each month, at least for the first three to four months af ter the accident.
Subsequently, the numbers went down to approximately 500 each month--still significantly higher than the pre-accident figure.
Processing 1,500 to 2,000 miscellaneous individ uals, from experienced, degreed nuclear engineers to construction laborers, through classes ranging in size from approximately 5 to 50, required an enormous effort peripheral to the major focus of Licensee and others af ter the accident.
In order to accomplish this task, the Training Department, with the assistance of the Health Physics Department, employed a number of outside contractors, in addition to Training personnel, to conduct the GET programs.
The contractors' suitability for this job was verified by individuals in the Health Physics Department.
The Training Department, responsible for the administration of the GET programs, provided to the instructors (including consultants) the package of materials which were required to be ta ught, including audio-visual tape s, lesson plans, and testing materials.
Basic and intermediate health physics courses were taught around the clock in three sessions for ' a number of months af ter the TMI-2 accident, at which time they were taught twice each day, in order to cover day-time and night-time shif ts.
A number of different exams (from two to four versions) existed O \\
for the RWP course in the months following the accident.
The instructor / examiner generally utilized two tests, an A and a B test, in each classroom, with tests alternating from person to p'e r so n.
Thus, if I were taking test A, the individuals sitting on both my lef t and right sides would have been taking test B.
After the approximately seven to eight hour course, the test was administered.
Multiple choice questions were used, and there were generally 45 to 50 questions.
Effort was made to fully proctot the tests, although the instructor / examiners may have left the room for a period of minutes to resolve administrative matters, go to the bathroom, etc.
On a few occasions, an instructor / examiner may have been running two classes at a time, with the basic course consisting solely of audiovisual instruction tapes.
Nevertheless, to change tapes, answer questions, and administer the basic health physics test, the RWP instructor might have been absent from the RWP classroom for longer periods of time.
However, because of the shorter basic course, any such absence would not have occurred during the administration of the RWP test.
One of the individuals who taught RWP shortly after Mr.
Williams took the course recalls that he suspected a last may have been missing.
Another RWP instructor / examiner recollects that the answer key may have been seen.
As a result of these suspicions, the tests were changed, at least by rearranging the I
order of the questions.
The recollection of one of these former RWP training instructors is that he closely proctored
'the te st, and only he and the instructors he worked with knew._ _
where the tests and the answer keys were kept--which was at two different locations.
However, this individual is not sure whether this procedure for securing the exam materials occurred prior to or af ter he became suspicious of cheating on the RWP exams.
He does recall that in about the fall of 1979, exams and keys were locked up.
i I
From Training records, it is clear that Mr. Williams, who was employed by Licensee's security contractor at TMI from early 1979 through May of that year, took basic health physics on January 22, 1979, and then took the intermediate course on 4
April 28, 1979.
The allegations Mr. Williams has raised relate to the April RWP test he took, which was administered by Mr. Steven F. Lavie, a contractor employed by NUS Corporation.
The test Mr. Williams took contained. 50 multiple choice questions.
In order to pass, a grade of 35 or better was required.
Mr. Williams passed, with 44 out of 50 correct answers.
See Attachment 4.
Thirty-six other individuals took the RWP training course and test on April 28.
One person failed the test.
The highest grade on the test was 48 out of 50, which one person reccived.
The rest of the grades ranged in the high 30 's and low-to-mid 40's.
See Attachment 5.
i Today, both basic and intermediate (RWP) health physics are taught at TMI under the auspices of the TMI Training Department.
Exams are regularly rewritten, at least every six months by requirement, and several versions of the exam are administered to each class of RNP students.
Every individual
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l who is currently " badged" for unescorted access into the plant, j
which means tha t the person has taken the basic or intermediate
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health physics course and passed the tes t, has taken (or retaken) the test in the past year.
The administrative procedures which I describe in Section VIII of this testimony apply to RWP and all other exams administered by the TMI Training Department (as well as any tests administered by contractors who may be employed by Licensee).
VIII.
New Procedures & Policies Related to Exam Administration and Cheating As a result of the discovery of cheating on the NRC operator examinations, a new procedure has been written on the Administration of Examinations, Procedure No. 6200-ADM 2600.1 (Attachment 6).
This procedure is applicable to Training &
Education Department personnel, as well as Training & Education Department contractors and monitors.
Other corporate policies, which formalize policies originally implemented by executive memoranda, are in the final review and approval process.
Examples of these are:
(a) GPU Nuclear Policy Regarding Cheating, Fraud and Misconduct, Procedure No. 1000-POL-2604.1, applicable to all GPU Nuclear personnel; (b) Standards of Cond uct, Procedure No. 1000-POL-2000.1, applicable to all corporate activities; and ( c) Adherence to 7,Iicies and l
l Procedures, Procedure No. 1000-POL-1218.3, applicable to all corporate activities.
While the procedure for exam administra-l tion is self-explanatory, it may be helpful to briefly
[
l summarize its important principles.
I have also summarized the i
corporate policies listed above.
A.
Administration of Examinations Procedure In order to ensure that all exams administered by the Training & Education Department test the ability of the individual and prevent conduct which would defeat this purpose, I have instituted, effective October 20, 1981, the following rules applicable to all exams administered by the Training &
Education Department:
(1) specific methods are provided for ensuring that exams are secured, e.g.,
typists must return all draft exam sheets to the individual requesting the typing; (2) all exams are accompanied by a " Written Examination Certification Cover Sheet" which, among other tning s,
specifies whether the exam is open or closed book, specifies rules of conduct, identifies authorized reference materials, and provides a space for students to sign a statement that their work is their own; (3) instructor / examiner procedures are specified for ensuring that the physical environment in which the exams are taken does not compromise the exam process, e.g., no unauthorized materials are present, students are not sitting close together, seating char ts are made for " major" exams, such as the requalification exams; (4) 100% proctoring is maintained; (5) rules on students leaving the exam room during the examination are provided; and (6) misconduct is required to be immediately reported to Training supervisory personnel orally and in writing; the written report is given to the Manager of Training who reports it in writing to the Human
~
Resources Department (GPU Nucl ear 's personnel department), and notifies an individual in the student's supervisory chain, as well as the Director of Training & Education.
I have discussed this new procedure with the. Training Department at TMI in a meeting which I convened for the training manager, supervisors, instructors and administrative personnel the week of October 19, 1981.
In this meeting, I emphasized tha t it is incumbent upon us as teachers to ensure the integrity of our examination process.
While we are not the disciplinary function in the organization, it is clearly our responsibility to approach examinations with the appropriate attitude, and to take measures to protect the efficacy of the exams we administer.
In addition to my emphasis on the responsibility of our instructors to preserve the integrity of the programs they teach, Mr. Herbein, the Vice President of Nuclear Assurance, has voiced his opinion on this subj ect through individual letters sent to and meetings held with all licensed training personnel in GPU Nuclear.
In addition to specifically asking each individual to endorse the Company's position with regard to the importance of the NRC examinations and other regulatory requirements, Mr. Herbein has discussed the reliance management.
has placed and will continue to place on the instructors' relaying information they know about misconduct such as cheating.
~I understand Mr. Bukill has conducted essentially the same interview process with licensed members of his staff.
l B.
GPU Nuclear Policy Regarding Cheating, Fraud and Misconduct The Office of the President of GPU Nuclear has instituted a policy which clearly defines what constitutes cheating, fraud and misconduct, and states GPU Nuclear's policy regarding these activities.
The policy makes clear that no GPU Nuclear employee shall cheat, perpetrate a fraud, or falsify any company document, report, test or examination in the conduct and discharge of his assigned responsibilities without disciplinary action being taken by the company, in those instances where such becomes known to the Company.
The severity of such disciplinary action is dependent upon the facts of each case, and it is clearly stated that charges of known or suspected misconduct may warrant immediate suspension of the individual (s) involv ed, subj ect to further disciplinary action up to and including discharge.
The policy also makes clear that all personnel are responsible for reporting all perceived acts of cheating, fraud or misconduct.
It is the responsibility of the Director of Human Resources to investi-gate all such reports.
Ultimately, it is the responsibility of upper management, e.g., Mr. Hukill, with the counsel of Messrs.
Arnold and Clark with respect to TMI-1, to determine the appropriate disciplinary action for TMI personnel who are found to have violated this policy..
C.
Standards of Conduct This policy, -also. instituted by the Office of the President, is intended to clearly 1 state the Company's expectation that its employees behave.in a manner. consistent
.with our unique responsibility as members 'of the nuclear power industry to protect the public health and safety. l Prohibited activities, such as possession - or use ' of ' substances which alter-physical or' mental capacity, gambling, intentional dishonesty, and the public use of profane language are specified.
D.
Adherence to Policies and Procedures This statement, from the Office of the President, essentially states that strict compliance with policies and procedures issued by GPU Nuclear is required, and that GPU Nuclear will not condone any instance of willful disregard of 4
policies or procedures.
I IX.
Conclusions As a result of the cheating by two SRO license candidates on an NRC examination, we have critically examined our past i
. ractices.
While there was a mostly unspoken understanding p
i that cheating is totally unacceptable behavior, the lack of formal procedures and practices may have been a contributing i
factor to the misconduct of the two license candidates.
We now have implemented a procedure fo r " Administration of Examinations" to ensure that our examinations provide an objective and accurate measure of the specific knowledge and skills that individuals must have to properly perform their f
i l'
~
jobs.
We have clarified through formal policies and meetings with.oersonnel our total commitment to ensuring that all our activities are in compliance with corporate ~and regulatory requirements.
Finally, we remain committed to the delivery of increasingly high quality programs in the -wide range of subject creas required of a nuclear facility and to ensuring the integrity of the testing and evaluation of our trainees. -
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