ML20039D690
| ML20039D690 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 12/24/1981 |
| From: | Adler R PENNSYLVANIA, COMMONWEALTH OF |
| To: | |
| References | |
| NUDOCS 8201060007 | |
| Download: ML20039D690 (5) | |
Text
PA 12/24/81 UNITED STATES OF N ZRICA UN%
NUCIIAR REGULATORY OQ11LSSION BEFORE THE ATOMIC SAFETY AND LICENSIg BQ*@l All :26 In the Matter of
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.00t4DNEALTH OF PENNSYINANIA'S CGNENIS ON THE SIGNIFICANCE AND RELEVANCE
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y-N The Comotr.cealth stated its positions on the admissibility of the HPI question and answers during the Deccaber 10, 1981 evidentiary hem ing.
Tr. 26, 783-84. Although the~ additional documents agreed upon by the parties dtiring the December 14, 1981 conference call resolve same of the concerns stated by the Connonwealth, the concerns regarding the~ relevance and probativeness of the issue remain.
The Comonwealth, perceives only one way in thich the HPI documents migh* be construed as relevant to the issue of operator cheating. A comparison of the knowledge of an operator on the written versus oral portions of the exam might be relevant to the issue of operator cheating if, for exanple, an operator had the correct answer on the writt'en, but not the oral portion of an exam. However, such differences in knowledge could be explained by other factors, such as the precise manner in which the question is asked and the answer is received by the oral exanuner, or the skill of the examinee in taking written versus oral exams. The 3
960 Cocnonwealth does not believe,that admitting the documents alond tould I(
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i esolve these issues. Ibreover, if the purpose of the documen*.s is to cocpareithe knowledge of the operators on the written versus' the oral exam, there is no evidence that the sanple of one question, however inportant to the operation of the plant, is sufficiently probative to drew conc.iusions on the issue of operator cheating.
Therefore,' the Cocnonwealth muld object to the admission of the l
L HPI questions and answers in the reopened operator cheating hearing.
i II. Management Issues (Operator Training) l, The answers to the HPI question are clearly relevant to the issue of-operator _ training. The criteria for termination of HPI constitute an irportant aspect of operator knowledge in terms of the safe operation of the plant. However, the Connotwealth again muld caution against the use-1 of a single indicator to draw broad conclusions regarding~the adequacy of' operator training. The IRC exam is supposedly designed to tese the competence of reactor operators by asking a broad scope of questions over the course of a written and oral exam. Using. incorrect responses to a single exam question as an indicator of operator cocpetence, in effect, would raise the criteria f6r passing the IRC eum to 100 percent.
It may be aruged that a single question is so inportant in terms of an operator's ability to operate the plant safely, that the answers to that question override the results on the entire exam..This would consti'tute nore of an attack on the IRC exam process than on the competence of 'IMI-l operators. To satisfy this criterion, the IRC exa would have to include a series of "superquestions", for which perfect l
-or near-perfect responses are required in order for the examinee to
-receive a passing grade. The'Connonwealth would view this concept as t--.
$xcessivelyharshandunnecessarytothesafetyoftheplant.
It nust be understood that exam conditions are far different' fron operating conditions.
During an exam, the operator nust recite a large anount of information without the use of reference material.
It is unreasonable to expect perfect performance under such conditions. Under operating conditions, it is critical for the operators to understand that procedures -
must be followed precisely, and to kuw dich procedures to refer to under given circumstances.
It is not critical for the operators to merorize the procedures.
Finally, the Commmealth notes that the NRC's grading of the HPI question does not necessarily provide an accurate indicator of the operators' knaaledge of the key requirmunts for HPI tennination. For example, operators who indicated.that HPI tennination is necessary to prevent the pressurizer level from going off scale high wre marked correct; yet operators otio gave a nearly synonytrous response, that HPI termination is necessary to prevent the pressurizer from going solid, were marked incorrect.
For the reasons stated above, the Co:monmalth believes that reopening the record to receive the HPI question and answers alone m uld not i
necessarily provide an accurate indicator of operator competence. A proper review w uld require an investigation of the adequacy of the entire NRC examination process to measure operator competence.
'Ihe. Board rejected this approach in the operator cheating hearing, and the Conronwealth does not believe that sufficient justification has been dmonstrated here to wanant such an extrane result.
Respectfully submitted, CU
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ROBERT W. ADIER
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Assistant Coursel Cormorwalth of Pennsylvania
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UNITED STAIES OF MERICA
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,.t, IUCIEAR REGULATORY 00bMISSION -
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BEFORE THE ATOMIC S.U'E1Y N D LICEtSIl0 BOARD
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Lt.KralCATE OF SERVI
-I hereby certify that the foregoing "Commnuealth of Pennsylvania's Coctnents on the Significance and Relevance of the Answers to the HPI Question" was served on the parties on the attached service list this 24th day of Decenber,.1981, by deposit in the U.S. mail, first class
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ROBERT W..ADLER-Assistant Counsel Commnwealth of Pennsylvania g
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!GCLEAR REGUUU'1RY CO' MISSION BEFORE 'IEE AKMIC SAFETi NO LICENSING UOARD In the lhtter of
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FEIROPOLITAN EDISON CO: PAIN,
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Docket tb. 50-289
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SERVICE LIST Docketing and Service Section Mr. Steven C. Sholly Office of the Secretary Union of Concerned Scientists U.S. Ibclear Regulatory Conmission 1723 I Street, N.W., Suite 601 Washington, D.C.
20555 Washington, D.C.
20006 Ivan W. Smith, Esquire, Chairran Ms. Iouise Bradford Atomic Safety and Licensing Board Panel
'IMI Alert U.S. Ibclear Regulatory Conmission 315 Peffer Street Washington, D.C.
20555 Harrisburg, Pennsylvania 17102 Dr. Walter H. Jordan Ellyn R. Weiss Atomic Safety and Licensing Board Panel Sheldon, Harron, Roisman & Weiss 881 West Outer Drive 1725 I Street, N.W., Suite 306 Oak Ridge,'lecnessee 37830 Washington, D.C. 20006 Dr. Linda W. Little Karin P. Sheldon, Esquire (PANE)
Atomic Safety and Licensing Board Panel Sheldon, Harmon, Roisran & Weiss 5000 Hermitage Drive 1725 I Street, N.W., Suite 506 Raleigh, ! brth Carolina 27612 Washington, D.C.
20006
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George.F. Trowbridge, Esqaire James A. Tourtellotte, Esquire Shaw, Pittmm, Potts & Tro4 ridge Office of the Executive Ingal Director 1800 M. Street, N.W.
U.S. Nuclear Regulatory Conmission Washington, D.C. 20006, Washington, D.C.
20555 Ms. Marjorie M. Aamodt John A. lovin, Esquire R.D. #5 Assistant Counsel Coatesville, Pennsylvania 19320 Pennsylvania Public Utility Conmission P.O. Fox 3265 Ms. Gail Bradford Harrisburg, Pennsylvania 17120 Anti-Nuclear Group Representing York (AIGRY)
Robert L. Knupp, Esquiro 245 W. Philadelphia Street Assistant Solicitor. Countv of Dannhin u_
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