ML20039E965

Motion That Hearing Be Reopened to Receive & Examine Responses of Licensing Candidates to HPI Questions on NRC Oct 1981 Exams.Knowledge Essential to Plant Operation. Certificate of Svc Encl

ML20039E965
Person / Time
Site:	Three Mile Island
Issue date:	12/21/1981
From:	Aamodt M AAMODTS
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8201110668
Download: ML20039E965 (5)

Text

(.

/d 4i 5, s'. -

. .D . A .f f ,e -: i f A

.m E:.n p . .m ; . . :.y . : : r.- n.x -

l stroaE THE AlcMjC fArtTy ; :D tiCtss1xG hor.aD y,gE4E.C AND Tat snein y_; STER .

4

- . _ _ . _ . _ g .: ' ':

'df JM -6 PS:05

) 'M S -

b-In the Matter of '_ S. .

'. *, CFF.J.

E ::7 SECCEi.? :

Dar, i::13 & EE,w:.

,)'

ETROPOLITAN EDISON COMPANT y) g pock.et. 50 - 289 Re.s.t ar t "

(Three Mile Island '*uclear

('i 2ny' ,,

g

• \f'!l( * [

gL dIlli %cM gf- Y;h L

Station, Unit 1) {

[ _ _

I

- h. .1

\ N 94 .x y' M Mon +g g h ;uq, AAMODT NOTION THATiTHE HEARING BE REOPENED TO RECEIVE AND EXAMINE THE' RESPONSES OF LICENSING CAN TO THE HPI QUESTION The Aarodts notion that the hearing be reopened to receive and examine the respe1ses of the licensing candidates to a question on the October,1981 NBC liccasing examination concerning the operators' actions prior to terminating Since this knowledge on the the High Pr essure Inject ion system at TMI-Unit 1.

part of the operators is essential to safe operation of the plant, the failure of eleven of the thirty-one candidat es to make a correct response is significant.

The evidence of the incorrect responses was not supplied in time for the Special Master to examine any of the candidates in the reopened hearing on cheating. Since training and the content of the NRC examination were not issues in that proceeding, the examination of the candidates' responses may not have been appropriate. However, the issues raised by the incorrect responses This new -

are those that were to have been considered in the main hearing..

evidence is clearly relevant to that proceeding and of suf ficient weight for the hearing to be reopened.

Statistical analysir of the candidates' responses to' the HP[ question has suggested that there is evidence relevant to the reopened hearing on cheating failed as well.

Of the seventeen candidates who took the A examination, eight d.

whereas only three of the sixteen candidates who took the B examination faile 8201110668 811221 L -

~~

PDR ADOCK 05000289PDR j

0

3 ,

Thi s 9 .wt d' . r; ei.ce in ; er for.:..r.ce t r.uld 1 : at t rilut ed - t o one of two enuses: Either the two gt oups const itut e two univarses, or a form of cheating occurred. Since it is rore reasoi.able to a sure that the operators constitute a single' training universe, the logical explanation is that a form of cheating.

effected the October licensing examination. In light of the testinony on Doctmber 10 of Mr. U, where Mr. U stated under cath that he, the mothing of the

~

April IIcensing examination discussed his examination freely in the control room with individuals who were about to take the B examination, the rechanism for chaating is apparent. It should further be noted that Mr. U testified that this kind of dialogue was commonplace, and he did not consider it to be cheating.

One can reasonably assume that had the above-mentioned control room dialogue (or othar similar forms of information transferral) not occurred, lack of u derstanding of the llPI question would have been even more videspread.

Failure to have inparted necessary information concerning the liPI system to the candidates for licensing is attributable to the TMI Training Department.

l, Either the training program was inadequate, or the operators had attitudes

'which precluded Icarning. In either case, the Training Department should have The responsibility been aware that the candidates were not properly prepared.

of the Training Department in failing to properly prepare the candidates -

concerning the llPI question should be determined through a hearing.

The hearing should also define criteria that can adequately measure the .

proficiency of candidates for licensing. Of the eleven candidates vlio failed the llPI question, eight had received passing grades on. the licensing examination i

and vill be licensed by NRC. In areas of knowledge critical t[ihe safe -

\. operation of the plant, 100% proficiency is not unreasonably stringent, particularly for senior reactor operators. (A single SRO may be present an'd in charge of the plant.) The refinement of criteria was the thrust of l

I Aamodt Contention 2, and the Board's conclusion (PID 264 ) that the contention

v N .

- r  ! if..d :s cl ar Jy c- s' t d *- y : ?.e . : 't ac e of the ep;r.it c>rs' t i'I-

• f

. c. .< . r ning t i.e EPI syst em.

The new evidence also brings into question the Enard's conclusions concerning training in general. (PID, August 27, 1981). In the course of the restart hearing, it was statistically der.onstrated that the training program was inadequate. Af ter an int ensive training pr5 gram (OARP), one-fourth of the operatc.rs f ailed scme part of the final exasination (Kelly) and one-half failed the Category T (TMI-2 events); after a year of requalification training.

s

~~ sixteen of 27 operators failed a dock of the NRC examination (ATIS). The SRC Staf f and Board response was to closc-off litigation in this area, asserting that adequacy of. the training program would be determined by the results cbrained on the NRC licensing examination. In view of the high failure rate c>n the October licensing examination, a conclusion of inadequate training by thd TMI Training Department must result. A hearing to determine the cause of the inadequacy appears appropriate and necessary if the present Licensee is allowed to continue to operate the TMI-1 plant and train operators.

The Licensee has placed on the record of the reopened hearing a new version of their training program. This material was not subjected to cross-examination as training was not an issue of the reopened hearing. This material may very well be used by parties to the proceeding to address the adequacy of training-through Icgal argument. Use of such unsupported documents could Icad to a gross distortion in findings of fact and conclusions of law.

~

For all of the above reasons, the reccrd of the hearing on the restart of TMI-1 should be opened to enter and examine the responses of the candidates Niv for licensing to the questions on the October licensing examination, including and specifically ciamining the responses to the HPI question. The relevance .

to the data / Eo b0cN[ Ink $ EhaSEing, attitude and management should be consideredc In order not to segment the Board's consideration of these important issues, the record of the hearing on cheating and the main hearing should be censidered I

t . :..; T e res ..:d. ,

T.e s r.c .- t f ul ly s ubi t t ed ,

'r

.......>o

_s

• - [/ -

. :. . ../,e_

.. c..._ <

Parjorie M. A7r.odt This is to certify that the above docuhent, AAMODT MOTION THAT THE HEARING

~

bE REOPENED TO RECEIVE AND EXAMINE ,THE RESPONSES OF LICENSING CANDIDATES TO -THE in HPI QUESTION, has been served on the anclesed service list by deposit  ;

U. S. Mail, first class, this 21st day of December,1981.

A /

~

/ // - .

l !!- 's.)"(./) b1 A.%.M L_,

j Marjor[id M. Aamodt e

e>

e

(

1

. e4 v.

l  ;<s-

\ .

l f '

l .

l

,.-..-....m- , , _,,

. ..s -

i' ,

• 1 M.: cit t 1. 5-0 ,. OXKETC UstlEC

~

Giorge F. Trchbridge, Esq. Mr. Jchn E. Minnich, Chairman Shaw, Pittman, Potts & Tros bridge Dauphin County Scard of Comissioners 1 1800 M Street, N. W. 82 Jm -6 P5:05 oauphin County Courthouse

., 'Jashington, D. C. 20030 gjp Front and Market Streets

,m y v Harrisburg, Pennsylvania 17101

~e Counsel for ::RC Staff 0Fiit t Office of Executive Legff Mgjg ragturn773'gggt Mr.. Farvin I. Lewis U. S. Nuclear Regulatory Comission 6504 Bradford Terrace Wishington, D. C. 20555 Philadelphia, Pennsylvania 19149 Mge P.eginald L. Gotchy

Jordan D. Cunninghn, Esq.

Atomic Safety and Licensing Appeal Board Fox, Farr & Cunningham U. S. Nuclear Regulatory Commission 2320 iorth Second Street Harrisburg, Pennsylvania 17110 Wa:hington, D. C., 20555 Ms. Gail B. Phelps NYPIRG William S. Jordan, III, Esq.

5 Seekman Street Harmon & Weiss New York, N. Y. 10038 1725 Eye Street, N. W., Suite 506 Washington, D. C. 20006 Mr. Robert Q. Pollard John A. Levin, Esq.

609 Montpelier Street Assistant Counsel Baltinore, Maryland 21218 Pennsylvania Public Utility Cornission P. O. Box 3265 Robart W. Adler, Esq. Harrisburg, Pennsylvania 17120 Assist ant Attorney General 505 Executive House Ms. Louise Bradford P. O. Box 2357 TMI Alert, Inc.

Harrisburg, Pennsylvania 17120 315 Peffer Street Harrisburg, Pennsylvania 17102 Walter W. Cohen, Esq.

Consumer Advocate Thomas J. Germine, Esq.

Departh.ent of Justice Deputy Attorney General 1425 Strawberry Square Division of Law - Room 316 Harrisburg, Pennsylvania 17127 1100 Raymond Boulevard Newark, New Jersey 07102 Ellyn R. Weiss, Esq.

Harmon & Weiss Judge Gary J. Edles, Chairman 1725 Eye Street, N. W., Suite 506 Atomic Safety and Licensing Appeal Boar Washington, D. C. 20006 U. S. Nuclear Regulatory Commission Washington, D. C. 20055 Mr. Steven C. Sholly '

i Union of Concerned Scientists Judge John H. Buck 17P5 Eye Street, H. W., Suite 601 Atomic Safety and Licensing Appeal Boar Washington, D. C. 20006 U. S. Nuclear Regulatory Conmission Washington, D. C. 20555 Dr. Judit! 41. Johnsrud y,g ,

Dr. Chauncey Kepford Judge Christine N. Kohl

% Environmental Coalition on Nuclear Power Atomic Safety and Licensing Appeal Boar s

433 Orlando Avenue .

U. S. Nuclear Regulatory Comr.ission State College, Pennsylvania 16801 Washington, D. C. 20555