ML20080N228

Response to Commission 840120 Memo Listing Integrity Issues. Hartman Allegations & Leak Rate Falsifications Must Be Examined to Understand Functional Company Policy

ML20080N228
Person / Time
Site:	Three Mile Island
Issue date:	02/18/1984
From:	Aamodt M, Aamodt N AAMODTS
To:	NRC COMMISSION (OCM)
References
NUDOCS 8402220158
Download: ML20080N228 (42)

Text

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UNITED STATES OF AIERICA

. hUCLEAR REGULATORY C0'OfISSION -

000tETED BEFORE THE C01911SSIONERS: USHRC Nunzio Palladino, Chairman Victor Gilirsky Thomas Roberts 84 FEB 21 A10:41 James Asselstine Frederick Bernthal v c- -- .

In tle Matter of )

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METROPOLITAN EDISON COMPANY, ET AL. ) DOCKET 30-289

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(Three Mile Island Nuclear )

Generating Station, Unit 1) )'

AAMOUT RESPONSE TO COMMISSION MEMOPANDUM OF JANUARY 20, 1934, t

INTRODUCTION T'ce Commission provided a list of integrity issues. The parties have the opportunity to advise the Commission.by February 21, 1934 whether the list is complete and accurate and whether these issues (and any others) are resolved or unresolved. If any issues are considered unresolved, the

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parties were directed to explain, with specificity, why, the i=portance to the restart proceeding and recommerd action for resolution. Any reco amerdatiors for reopening the record should meet the Commission's tripartite test (timeliness, safety-related and significant).

ABSTRA CT This document will show that the Hartman matter (the falsification of leak rate reports at Unit 2 and operation in violation of technical specifications) is the most significant unresolved management integrity issite because it is the clearest example of the Licensee's fur.ctional alicy as it presently exists and is implemented.

Othere ur.:esolved management it tegrity issues which are significant and safety-related to the restart of Unit 1 and for which a reopening sho tid be provided are the ratter of misleading a-d withheld it. formation 8402220158 840218 PDR ADOCK 05000289 0 PDR g3

2-during crd cinca 'tha accidant; th2 falsificatiors cf icok rate raporto and operation of Unit 1 in violation of technical specifications; allegations of improper hiring practices; and procedural circumvertion in the Unit 2 cleanap and harrassment of the "whistleblowers".

Sone integrit aspects of Licensee's response to the training of. licensed operators were incl.:ded in our appeal of the Licersing Board's decision and argued on January 11, 1984 Depending on the Appeal Board's decision, this matter may require a reopening. We would await the Appeal Board's decision.

The management integrity aspects of the operators' cheating on tests at TFE-1 was considered in a hearing but remains unresolved. This was a subject of our appeal on January 11,19S4. We would await the Appeal Board's decision.

The other integrity issues listed by the Commission and which are under I

f i

OI investigation are clearly un$esolved. These include the changes in the

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Keaton Report of the sequence of events during the accident and issues which arose from review of the GPU v. B&W trial material. These =atters, for the most psrt, relate to other matters where reopening is clearly needed and could be examined in those hearing.

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- DISCUSSICN The Hartman Matter The most relevant and significant mansgement issue of the Restart Proceeding remains unresolved because of the actionc of the Licensee, the NRC Staff and the Commission. This issue is the verified matter of 1

! falsification of leak rate reports to NRC and operation of Unir 2 in violation of technical specifications which resulted in the accident on Parch 28, 1979. The Commission's recent decision (January 27, 1984) to separate restart of Unit 1 from this matter is a gross error, legally and substantively.

The Restart Proceeding was ordered to consider catters which were related to the THI-2 accident, to assess their icportance to and persistence i within the Unit 1 organization.,

The matter of falsification of leak rate rates and operation under clearly improper conditions blinded the operators to similar conditions e

during the escalation of the accident from an incident of a clogged demineralizer to a loss-of-coolant accident. The policy decisions which permitted the falsifications to be instituted and carried out at Unit 2 have not been examined. Assurances by the NRC Staff and the Licensee that the policies and individuals presently in place would not permit an identical or similar situation are hullow and self-serving.

The falsifications were not isolated incidents. They were a criminal company scheme which was carried out over the entire operating life of the Unit 2 plant. Licensee dared to operate a nuclear plant in disrepair at risk to public and worker health and safety and dared to trick the 1:RC inspectors by falsification of reports and dared to involve its entire i operations organization (at a minimus) in these criminal acts.

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l After tha ccc'idInt cccurred, tha company policy became en2 ef ccvarup.  !

1 The misinformation concerning the severity of the accident and the everchanging sequencing of the events of the accident (Keaton Report) were part of the attempt to coverup. The "new" managers (Hukill at the plant and Clark at the corporate level), with the organization since 1980, must be involved in the coverup. They have worked alongside those who have been involved in the falsifications and the coverup. The company, with the cooperation of the NRC, has worked to successfully prevent the public's hearing of the criminal behavior at Unit 2 This kind of effort could not have been carried out exclusively by the pre-accident organizatinn. This burden has sapped the energy of the company, so that a company with apparently abundant expertise has not been able to bring the Unit 1 operation above average marks by INPO.

The training program has been affected. The co=pany, beholden to

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operators and a training department which has taken the rap for an accident caused by management's criminal policies, has not been able to administer

. an adequate training program. The company tolerated cheating during company tests, did not help proctor the NRC exams, upheld the integrity of operators who cheated on tests and paid these operators a $1300 bonus prior to their testimony in the hearing on cheating.

As long as the leak rate falsification matter at Unit 2 is left unresolved, the management will remai1 impotent, and the plant will operate in chaos.

. For what other reason than blackmail would the company be willing to retain Husted in the training department and elevate another former TMI-2 operator, Fredericks, to the position of supervisor of licenscd operator trcining? How was Shif t Supervisor "0" (one af the extensive cheaters) able to quickly obtain employcent with a contractor used by Licensee and allowed back on the island? ' Jay were Floyd and Miller, obviously connected

with the falsifications as management of Unit 2, retained in the shadows of the company organization? Why were any of these employees retcined within the GPUN system in view of the policy, stated in 1931, which declared total intolerance of any form of cheating?

Further evidence of a company at the mercy of its peployees was the .

incredible behavior of the plant personnel during a visit of the. Licensing Boa rd. The loud speaker system, between the plant and the control room, vis essentially unavailable due to " mad homber" whistles. Dr. Little noted, during the hearing of engineers concerning control room design, that she had never before observed a comparable industrial problem' If Licensee had chosen to bare the Hartuan matter at the beginning of the Restart Proceeding, there could have been some hope of "decoupling" the matter from restart. However, the Licensee has been deceptive, concealing

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its criminal behavior, -denying it, attempting to assign b1' mea to B&W, the NRC and

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individuals within the company, ' and working to force the restart of Upit 1 prior te a full hearing of the matter.

If the Coumission had chosen to air the Hartman natter at the beginning of the hearing, the matter may have been excised. The NRC, however, denied its own investigators subpeonas, then hid the matter in the Department of Justice, tried to ignore the public nature of the Hartman allegations in the NRC review of the GPU v. B&W trial materials, stayed a hearing demanded by the intervenors and now attempts to decouple the matter from restart.

If the- Commission' continues to bs unwilling to face the facts of the Hartman cetter and the coverup, the Comtlision will conclude the extended TIE-2 accident investigation without confronting the essential cause of the accident. That would be an obstruction of justice.

The Commission must either mehe a pre-e=ptive decision to deny the Unit i license or wait to decide on restart until there has been a full

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' cnd ep;n rasciutien of th2 Hartman matter. Thsra is sufficient cvid2nca to deny the license in view of the Commission's nandate to protect public health and safety, but insufficient evidence to per=it restart, which would be simply and purely an accomodation to Licensee.

Misleadinn end Withheld Information Followine and Since the Accident This icsue needs to be ' restated and broadened to demonstrate the common company policy that continues in place fr,om before the accident until the present: coverup.

The issue is not "whether" Licensee withheld information during the accident (see Commission list at I.A.) and since the accident (I.E.1. ;

III.D.1.; III.E.1.,2). The investigations following the accident, including I&E's, were in agreement that misleading information was provided and information withheld. It is clearly evident since the accident that :

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l Licensee has withheld information, notably the Faegre & Benson report of the Hartman allegations.

The unresolved issue is "why" mis' leading information was provided and l important information withheld. This facet has been disputed (Stello,

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Udell, Gilinsky), but remains unresolved by the Licensing Board. See August 27, 1981 PID at para. 470-1, 493, 501.

After examining most of the investigations, the Licensing Board decided that further litigation prebably would not resolve this issue, so the Board

. did not attempt to do.so.

Our interest in this issue, during the hearing, was to have the opinions of the Udall committee (which differed from that of I&I) examined on the record of the hearing. We failed to accomplish this because we understood that II:IA would do that. For whatever reason, T:HA did rot, and the only record evidence is the benign and confusing explanation of I&I that excused Licensee

. and was not easily understood by the Board. (I&E considered L'icensee's

provision of misleading information ' knowing' but not ' willful' )

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Our interest in this issue heightened following the close of the Restart I record, more specifically after April 1983, after studying the Hartman 1

testimony in the rPU v. B&W transcript. We found that.the conditions. hidden by the falsification of leak rate reports, the leaking PORV and overflow into the sump, blinded the operators the morning of the accident to the conditions of the stuck-open PORV during HPI injection. Therefore, the operators could not be forthright concerning their oversight of parameters of locs-of-coolant, thus providing the motiva? on to shield the condition of the plant. (We cannot help but conjecture that D)eckamp's rush to Harrisburg, the day of the accident, was to control the informat ion given to the governor.)

In our October 27, 1983 filing (pages 11,12), we raised our perceived relationship between the Hari aan matter and the misleading information'.

I at is now clear that the Board's decision is flawed. The Board accepted I&E's view that the matter was o tvoid of criminality, and it was on this assumption that the Board did net pursue a determination of the individuals

• responsibility. See August 27, 1981 PID a t pa ra. 491, 493 The Licensing Board clearly admitted that if es -!.dence of a company schere had been suggested, the Board would have pursued the tatter.

The departure of most of the t 'imary players in the misleading information scenario -- Miller, Herbein, Die. s amp -- is uni portant. Any company scheme would have evolved from company policy. Written policies, provided in the hearing, which declare that all information will be provided to the Commonwealth and the public,. do not resolve the . matter; they are obviously self-serving.

Functional policies are the only relevant policies and should be considered i- the Re' start Proceeding. The functional policy of Licensee is still, evidently, coverup. To this day, Licensee has not provided all information concerning the

' Hartman mattsr or sctisf:ctcry cxplanaticas for the misleeding information provided during the accident. Nor has Licensee explained its ' loss' of in-plant and survey radiation records from the first day of the accident.

Licensee has not explained why the F&B study of the Hartman metter was withheld and why the BETA and RER audits were provided lata. Licensee e needs the opportunity of a hearing to demonstrate a change in policy concerning forthrightness. T he Commission needs to observe whether Licensee's functional policies have changed or remain the same as in 1979.

Procedural Circumvention in the Unit 2 Cleanup and Harrassment of the I "Vaistleblowers" This is a clearly relevant matter to the restart decision. It reveals the functional policy of GPUN. The allegations of the three engineers and the secretary (Kirg, Parks, Gischel, Wenger) are known or available to the

' It suffices to Commissioners and need not be restated here in detail.

stress the elemente, y

The three engineers believed that procedures important to safety were being circumvented in the cleanup at Unit 2. The engineers tried, by various ccans, to bring the cleanup aperation back into procedural compliance. Of particular concern was the improper refurbishment cf the polar crane. The engineers reached out (to NRC, for instance) for assistance to halt the procedural violations. Each of the individuals allegcd personal harrasment by co=pany management.

The NRC hss confirmed the engineers' allegations of procedural circu=vention. No report has yet been issued concerning the harrarsment allegations.

The 1.clicy under1/ i ng this retter is the critical issue. The functional company policy appears unchanged from that which percitted falsification of Icah rate reports and operation in vioistion of technical specifications of

+ both picnts prior to th2 sceidant. Th2 enly differenca appsars to bs that there were four "whistleblowers" who umy have prevented an accident instead one who was too late.

Licensee's investigation of the "whistleblowers" provides another look at present GPUN policy. The intent of Licensee's report was to coverup the matter. A law firm,which represents the Oyster Creek plant , was hired to investigate. The similarity of Licensee's approach to that employed in its investigation of cheating on tests is striking; a company lawyer, John Wilson, was presented as an independent lawyer to cover extensive a

cheating on company tests.

Allegations Concerninn Eirinn Practices on September 16, 1983, Licensee prov'ided a report (dated Sepce' m ber 2,1983)

l. of an investigation by Faegre & Benson of allegations concerning hiring practices.

F These allegations were first reported to the NRC by the alleger, Thomas Quinn, an engineer who sought employment at TMI in thy 1982 The allegations' were the subject of Board Notification 83-08, dated February 1,1983.

Quinn alleged that someone in the personnel department at GPU arranged a second psychological evaluation after Quinn had failed the first one and provided information to the employment agency which would help Quinn pass the second screening.

F&B made an extensive study of the Quinn silegations and concluded that Quinn uns truthful.

The NRC Staff has made its own investigation and provided the Commission with three reports dated February 25, 1933, February 28, 1933 cnd October 12, 1903 We have only been provided the first report, served on January 4,19S4.

The NRC's first report cencluded that Quinn's cliegations ucre untrue because the investigators could not find corroborative evidence. Houcver, the Steff's'scarch included interviews of only those principal characters dhose corroborative testimony vould have been contrcry to self-interest.

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- These interviews were of the examining psychologist, membars[cf the GPUN Personnel Office, the Start-Up and Test Group, and employment counselors for Ikin Line Personnel Service, Inc. The Staff accepted the denials, and at the same time, rejected the allegations although Quinn had much less self-ir.terest.

(The Staff's position was not unfamiliar: ^ollowing the cheating hearing, the Staff rejected the allegations of an informant, a chief engineer at anothe:

nuclear facility and formerly an STA at T!E, in favor of the denials of the accused and others with se'.f-interest.). The Staff's conclusion is of little worth.

According to F&B, the NRC Staff has conducted another investigation --

interview of 30-40 people placed he THI by Main Line. E&B expressed reservations about the credibility of the NRC investigation. In comparing data with the NRC investigators, F&3 found.that NRC had missed corroborative evidence in one of seven overlapping interviews. NRC was to have reinvestigated, however, we cannot assume that NRC's subsequent investigations are more credible than the first, nor do we understand why NRC would have iss,ued the first, which is obviously in error, according to F63.

On January 25, 1984, the Licensee provided another allegation concerning

. hiring practices. An employee of Licensee has alleged that a psychologist of applicants for ecployment who performed screeninns/and psychological evaluations of e=ployees lacked requisite academic and license qualifications. Licensee srates that it has begun an investigation.

Thi.e catter is timely, safety-related and significant, and warrants examination in the Restart Proceeding. The Licensing Board chose to pass over the matter of hiring practices, raised in our Contention 1, 0 houcver the conclusions of the F&B study challenge the Bosrd's decision.

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.The Falsification of Lenk Rate Reports at Unit 1 This issue was fully addressed in our motion of January 24, 1984 before the Appeal Board.

The Co= mission has admitted the relevance of this issue to the restart decision, however, the Commission would only await ," indications" from OI concerning its investigation. If OI gives the go ahead, and the Cammission allows the plant to restart, the NRC Staff would oppose any further investigation of the operators. This.would be an obstruction of justice.

Although URC rules of practice and procedure state that important safety-related issues cannot be resolved by the Staff, even after the closing of a record (NUREG - 0386,VI.13.1.) even if a hearing on TFE-1 leak rate falsification was provided after restart, for all intents and purposes, it would be fruitless if we were denied access to the operators, the first-hand source of information.

This issue is open, significant, safety-related and timely, and fy must be resolved. oneniv. orf or t o a rv d eei r i er to restert. _

The Integrity Aseects of Licensee's Inadecuate Co==itteent to the Training of Licensed O,erators The Commission is correct in identifying the integrity aspect of Licensee's inadequate address of the trainir.g of licensed operators.

However, contrary to the Commission's assertion, this aspect was raised.

For instance, in July 20, 1901 in replying to the Co=aonwealth-Licensee agreenent (at page 29a), we wrote:

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The menacement of TFH-1 has not kent their commitments on which the August 9 order was based relative to the training of licensed operaters and the manning of shif ts with licensed operators.

Training of operators and proper =anning of shif ts were two objective nessures by which the =anagement of T>E-1 can be evaluated. The Board, theref ore, cannot overlook the inadequate performcnce of management in these areas in the Board's assessnent of the capabilities of management of TIE-1. The Board cannot base their assessment on subjective opinions of others and Eremises of manecement.

The versistence of Licensee to further their case for restert in the face of their own failure to fulfill their prior co=mitments is stronn evidence of maragenent's improper attitude toward the public hesith and saf et r, and the potential hazards of nuclear power generation.

, The Licensing Board erred in rejecting our position. See August 27, 1981 PID at pera. 537, 541, 549, 550, Footnote 58. ~

Following the Reopened Hearing, the Licensing Board changed its position concerning the traraing program. The Board found Licensee irresponsible (see July 27,19G2 PID at para. 2411) but not untrustworthy. (Id. para. 2412)

The Board's conclusions were obviously contradictory, and the Board's trust in the Licensee was misplaced and without ba-is.

Since the close of the hearing, Licensee has provided new evidence of its inadequate training program. Provided as Attach =ent 1 are selected pages from the report of Data Design Lab (September 1932) which cudited a "new" training program. Provided at Attachment 2 are satecced pages from the EF.R audit (February 1923) uhich reveal the operat:rs' nisgivings about the training program. Provided at Attachtent 2 are selected pages from the LETA report (February 1903) which are highly critical of the training

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erg:nizatisn. Provid:d ct Att:chment is o table frcm o rap:rt of an in-house audit (Lessons Learned Workshop December 22, 1983) which reveals that only two of seventeen identified training lessons learned objectives are "in place".

The inappropriate personnel assignments in the training departa'ent ,

which have occurred since the close of the record are of concera.

Dr. Coe, the Director of Training, has no applicable education or experience.

Fredericks, now supervisor of licensed operate training,. ,

was an operator on duty during the accident. Aside from his almost sure involvement in the falsification of leak rates, wasn't this one of the

" dummies" described by Kuhns before the Commission on December 5,1933?

Another training-related integrity issue is the Book allegation of Licensee's falsification of training attendance records. The NRC

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investigation of this matter was unsatisfactory. The , investigators excused the allegations as exaggerations due to Book's temperament, hardly a credible explanation since B&W found Eook a suitable witness about this matter. NRC did not interview those in the training department with first-hand information about the accuracy and meaning of the records.

It is rather remarkable that NRC paid no attention to what we believed was similar falsification of training attendance records entered into the record of the Restart Proceeding, although we brought this matter to the attention See Aamodt Findings, lurch 3, ic32 at para. 363-5. This of all parties.

matter should be pursued. Training records, in general, appear to be deliberately misrepresented when it favors Licensee to do so.

See Id.,

at para. 277-201.

before the Appeal Soard Ue have argued / that the specific : raining natterg nou listed by the management integrity issues . (J anuary 11, 1954)

Commission , were

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W2 wruld cwrit th2 Appeal Board's dscisien, howIvar we aos providing our arguments to each issue listed by the Consnission, not addressed supra.

(I.B.1.) Does the delay it obtaining a TMI-1 replica training simulator reflect adversely on management's attitude toward training?

Yes. .. Licenses was aware in December 1979 of the Etchyison report which was highly critical of the 3&W siculator training and which strongly reco:xnended the purchase of an exact replica simulator.

(The B&W simulator only simulates the stea= supply side.)

However,. Licenseo did not place its order for a simulator ur.:11 last year. The prelimary work toward preparation of specifiestions did not begin until after the conclusion of the hearing. The simulator would be of the most value prior to restart to provide operators with "on-hands" experience. The part-task simulator is not a valid substitute for a full-scale replica simulator as Licensee has suggested.

(I.B.2) Does the amount:of time that THI-1 operators will spend annually in simulator training reflect -

adversely on management's attitude toward training?

Yes. The Commission ordered increased training at the simulator.

Licensee provided 4 additional hours of training in TMI-2 accident events in 1980, otherwise the amount of annual siculator training is the sene as before the accident. This schedule, one veek Et the B&W simulator, only allous 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> "onihar.ds" experience. This fs11s far shert of TVA's suggested minicum, two weeks "on-hands" experience or. EUREG-066Cs recoc:mendation of 160-220 hr.arnually. (In addition, effective training time is reduced by che differences between the Unit 1 control room and the simulator. Some operarors needed several daily 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> cessions to become sufficiently aceuainted for training.)

The operators do not have time to run throu;h tne 25 manipulations required as an annual exercise by the Denter le:ter of :: arch 23, 1900.

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. (I.B.3.) Does manag: ment's fcitura to establish a training program that is equivalent to a college corriculum reflect adversely on management's attitude towards training?

This question does not accurately reflect our concerns. We simply the level of agreement between asked tha_tjthose t subjects identified b2 /the NRC Staff and the Licens-e es college-level be taught at that level. In a June 28, 1979 mnmorandu:

referenced at the end of the Commission's August 9,1979 Order for appropriate augmented training of licensed operators, the/ level of the following subjects (to improve the operators' response to the unexpected) was agreed to be college level: thermodvnamics, fluid fle'w .and heat transfer.

We wou11 expect that an agreement would be kept. It was not. These courses t raditionally which/ require third-level college mathematics are. taught without the requisite mathematical expertise of either the instructors or the operators.

Is this serious? It appeared to be so. Judge Milho111n, an engineer I himself, found that the operators lacked understanding in these very subj ects. Denpite the extensive training claiced by Licensee, ,

operators who testified in the cheating hearing did not understand principles of natural circulation.

(I.B.4.) Does failure to require operators to attain 100% test score on the NRC's operating license exam reflect adversely on management's attitude toward training?

Our position This question does not accurately reflect our concerns.

has been cirilar to that of INP0's -- that the operators should be  ;

trained and tested to fit the job. There is it. formation that all operators should know 100%. It was definition of this kind of information uith suitable testing that we vere seeking. Licensee has not designed such a training and testing program. Evidence of the significance of Licensee's failure was the variation in answers and incorrect ansvers provided in Octotat 1 081 to the questioq on the URC licensing exa=

concerning HPI injection. The URC provided in EUREG/CR-1270, Vol. II

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, at Appendix H, Tr91ning ObMetivss. Thssa cbjsetivan provida some of the information all operators should know 100%.Some of these objectives are stated as follows:

o Operator should be able to diagnose a failed open PORV with 100%

accuracy (no time limited stated),

o Operator should be able to respond to an inoperative PORV with 1007.

accuracy (no time limited stated). '

o Operator should be able to bring pressu:e and temperature back to normal with 1007. accuracy (no time limited stated).

o Operator should be able to recognize a turbine trip immediately with 100% accuracy (no time limited stated) .

o Operator should be able to diagnose a turbine tripped situation and identify the cause for the trip.with 1007, accuracy (no response time requirement stated),

o Operator should be able to determine that the automatic response is or is not correct with 1007. accuracy (no time requirement stated).

(Refers to Turbine Trip) o Operator should be able to respond with ic=ediate actions immediately with 1007. accuracy and without reference to procedures. (Refers to Turbine Trip) o Operator should be able to reduce feedwater to produce a 15% neutron power level with 1007. accuracy J(no time limited stated).

o Operator should be able to control rods to produce a 157. neutron power icvel with 100% accuracy (no time limit stated).

? o Operator should be able to control station parancters to shutdown status i with 1007, accuracy.  ;

o Operator should be able to determine that critical parameterst are or are not in tolerance with 1007. accuracy (no time limit stated). -

o Operator should be able to control Tave, P4 pressure, and steam header pressure with 1007. accuracy + or -? (no. time limit stated).

, - o Operator should be able to c.ontrol PZR level to 240" + cr -? with 1007.

accuracy (no time limit stated),

, o Operator should be able to control DISG 1evels to 30" + or - ? with 100%

accuracy (no time limit stated),

o Operator should be able to determine vacuum status with 1007, accuracy, o Operator should be able to verify header pressure at 885 psi + or - ?

with 1007. accuracy (no time limit etated).

o Operator should be able to control reactor pwer to zero + or -? with 1007. accuracy (no time limit stated).

o Operator should be able to determine turbine trip due to loss of FW pumps with 1007. accuracy (no time limit).

Thirty-six additional objectives that an operator should be trained to 1007. accuracy are listed. These include scenarios other than Turbine

Trip and Inoperative PORV, houever they are far from all-inclusive.

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(I.3,5.) Does licsnsso maintain en cdsquate cw ranssa of cp2rator

, cttituda, festar morals cod snsura en cpprscintion of the significance of operator action?

No. Licensee has, by choice, been ineffective relative to the attitudes, .

morale and training of the operators. The result has been high attrition.

Only two of the seven Shift Technical Advisors in training during the hearies remain.

in 1930 The CARP reviewers warned Licensee /of the operators' bitter attitude toward the licensing exam, however, it was only when the operators' attitude toward the exam provided a conveniente ' xcuse for the cheating, that Licensee

' feigned to address the problem, weekly Licens'ee continues to be uninterested in proble=s associated with/ shift rotation, notably attrition, denying any effect, despite the observations of the QARP reviewers. The RHR audit confirmed the effset on morale, finding the operators denoralized by an environment they described as a " windowless rotating shift". ,

' Although Licensee was advised to form " quality circles".of operators and managers, and management was advised to make frequent visits to the "backshif t",

this advise, provided by human engineers in 1980, =ay only now be taken, according to Kuhns in his appearance before the Co= mission on December 5,1983 The sirgle apparent attempt to boost morale was a $1300 bonus paid immediately before the operators testified in the hearing on cheating, and we believe this bonus was a payoff for cooperation.

Licensee contracted for an audit of the operaters' attitudes. The operators expressed annoyance because they did not believe that aryore would take their opinions seriously. This same opirio, was expressed in the .In-House audit rade at Unit 2 in 1978.

From our acquaintance with the OARP review and Licensee's response to it and use of it, we believe it is fair to say that the audits merely provide Licersee with'available propaganda uhich, if neede(, car be fronted and bached with suitably deceptive and complimentary su=maries ard :orclusions.

A

. Th' Cheating on Exaninations, .

The matter of management involvement in the cheating on' tests at Unit I has been appealed. We vould await the Appeal Board's decision.

To summari=a our position. we found Ross, the supervisor of operations, irvelved in compromise of the NRC examination by broadening of the answer keys and distracting the proctors. We found that Ross changed his own answers af ter reviewing the answers with the NRC examiners.

There was management involvement at the corporate level. Arnold was the company contact during the litigation, when Licensee used a company lawyer as an " independent investigator" to explain away obvious cheating.

Arnold testified that he had not asked "0" and "W", at any time, why they cheated extensively on the NRC exam and a prior audit because he was not interested in their reasons since thelcoceany would take all conceiveable steps to prevent cheating.

Training department management, Long, Brown and Newton, testified that they had no knowledge of "open book" testing or other compromises of company tests, not although they couldfhave avoided knowing. Long was specifically asked', by the Licensing Board, to seek this information and given 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to do so. Long and Newton lied that PQS Corp. was not avcilable to audit the operators in 1981, whereas the president, Frank Kelly, testified that PQS was never asked.

Hukill, vice-president of TMI-1, never pursued a statement cmde to him by operator "00" that cheating was commonplace and accepted at T12. Hukill certified operators whom he had never intervieaed prior to the April 1981 Licensing exam and who were unprepared to take the exam.

l l Licensee's counsel violated the spirit of the sequestration c der, if not I

the order itself, by ' informing two operators (appearing as the intervenors' witnesses) of the testimony of a prior witness relative to their behavior.

The Commonuealth's lawyer briieved that Licensee's counsel's interpretation l

l of the order uas different that that intended by Judge "ilhc111n.

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Arnold insistid t.n ths prassnca cf a managtment efficici dcring th2 initici NRC interviews of the operators. Although the investigators excluded management from subsequent interviews, the operators were, by then, " locked-into" testimony acceptable'to management.

When evidence surfaced of a co=pany scheme tc aid examinees during the ERC exam in April 1981, the informant, an STA "KK", was interviewed by a TMI manager, Toole, and sent with the company lawyer, John Wilson, to his ERC interview.

The evidence is overwhelmin3 that there was a company scheme for helping the operators pass the licensing exam. We believe that t.he engineers, "KK",

"W" and "FF", provided limited information concerning solicitation of them for answers in case the investigation revealed the scheme.

There was a " rumor" that someone was stationed in the training department

. hallway to provide answers to examinees. Why would a rumor have existed if I

there was no basis? We beliete the " rumor" testimony was litigation strategy

-designed for damage control in the event that the scheme was revealed.

. Someone was stationed in the hall of the training departmen;;, by the coffee machine, to provide answers either from his own expertise, use of "uld" examines ir. a training office, or by calling an STA in the control roca.

"00" interpreted "U's" presence at the coffee rachine as an offer of help.

Shipman, en engineer who writts procedure s, ad=itted previding an answer to an egaminee at the coffee cachine.

Houever, the most compelling evidence is the fact that the calls soliciting information from the STAc in the control room were rade over the telephone speaker s; stem. There was no need to hide the solicitation 'of information for examinees.

Other compelling evidence is Shipnan's attitude at the time he provided the answer -- that he had not done anything wrong, whereas he testified that similar behavior in the ::avy could hate been unconscionable.

, Wa hava fully cxpr2sard our views an tha chrating at THI in findings (130 pages) filed on January 18.c d. 20 and March 3,1982 The cheating on tests at TFE-1 is additional evidence of the company'=

functional policy to achieve its goals, in this case. the licensing of the maxicum number of operators in order to have enough operators for staffits the plant for restart.

The The Influence of Financial Considerations on Technical Decisions

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Clear 1v financial considerations outweight: technical decisions concerning the operations at TMI. That is clear 1v eviden t from the extensive operation of the two nuclear plants in violation of technical specifications. The operation of Unit 2, in this manner, was clear 1v to avoid costly power replacement while Unit I was dowa for refueling. lThe rapid escalation in the price of oil had resulted in a large differential in cost between nuclear fuel and

> replacement power. (Dieckamp, .ff. Tr.13,437, at 1-2) The Board noted that the organization allows inevitable financial influence upon technical decisions with two of the highest nuclear company officiers on the GPU Board.

of Directors. From this we deduce that the decisions to operate in violation of technical specifications originated with the Board of Directors, that this board places financial considerations way above technical decisions inview of the risk of operating in violation of technical specifications, and this board will resort to criminality in order to satisfy financial considerations.

This we believe is the functional co=pany policy.

The Licensing Board made a gross error in concluding that technical decisions were not undermined by financial considerations. The Commission made a gross error in deciding that Kuhns and other board membere can be ,

s epa ra ted . from the criminal acts at the plant.

Clearly, the Hartman matter and the leah rate falsifications at Unit I nust be examined in a hearin; in order to examine the functional company policy.

Cimrtv, th2 Hartman cettsr cnd th21sak r ta folcificaticus at Unit 1 must be exscined in a hearing in order to examine and understand the functional company policy.

Respectfully submitted, js Ls g /.

Efrman 0. Aa=odt

'v'4W.LU '. :L Marjgie M. Aamodt February 18, 1984 Service:

Docketing & Service Branch Atomic Safety & Licensing Board Panel

• Atomic Safety & Licensing Board Appeal' Panel s Judge Gary J. Edles, Chairman Judge Christine N. Kehl Judge John M. Buck i Jack R. Goldberg, Esq. .

Geerge F. Trowbridge, Esq.

• Douglas Blazey, Esq.

David E. Cole, Esq.

Michael W. Maupin, Esq.

Ellyn R. Weiss, Esq.

Louise Bradford Jane Lee l

^ Bob Edgar, Congressman Edward J. Markey, Chairman Oversight Committee Arlen Specter, Senator l J ohn Heinz, Senator i Michael McBride, Esq. _

biL444t: 4.. . $i n L4 f te w'A Y.arj or,if M. Asmodt I

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b ATTACHMEhT 1 Pa ge s 1-19, 1-20, 1-21, 1-22, 1-23, 1-24, 1-25 ASSESSEMEhT OF SELECTED TMI-1 TRAINING PROGRAMS, Volume 1, September 10, 1982 (eciphasis added)

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t 1-3.2.6. Program Evaluation.

a. Evaluation data is cellected on various training programs. However, there is no sy::tematic means for analyzing this data and applying the results to evaluate and improve the instructor cevelopment program as recommended by INPO guidelines.

1-3.3. General Emolcyee Training.

a. The five separate courses which comprise the TMI-1 general employee train-ing and requalification progrcm were attended by 2320 GPU Nuclear and con-tractor personnel during the period January 1-July 31,1982.

b. The content'of the general employee training courses meets the standards of ANSI /ANS-3.1-1978, "American National Standard for Selecti'on ~and Training of Nuclear Power Plant Personnel," Section 5.4 and is consistent with recommendations contained in INPO guidelines.

c. The amount of material covered in the general employee training courses requires a rapid pace of instruction. A total 'of 2181 trainees passed ii general employee trairl ing courses with a minimum grade of 80% during the period January 1-July 31,1982. This is a 94% successful completion rate.

d. The general employee training instructors are competent, well motivated and convey to new employees an excellent first impression of the GPU Nuclear organization.

e. Learning objectives are used in general employee training courses. Lesson plans are developed around the objectives. Instruction, reviews, and test questions arc based on the objectives.

f. Test questions in general do not conform to optimum practices for measure-ment of achievement and for cuestion construction.

I l 1-3.4. Auxiliary Ooerator Traininc.

a. The supervisor and the instructors assigned ta TMI-1 auxiliary operator training have ' the background, technical knowledge and the necessary in-structor skills to perform their jobs satisfactorily. They meet the education and experience requirements set forth in the TMI Training Department Administrative Manual for non-licensed operator training posi-tions. All have attended the TMI Training Department initial instructor development course.

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b. The TMI-1 auxiliary operator initial training program consists of some 39 weeks of classroom instruction followed by an 11 month on-the-job training (0JT) period to become a fully qualified Auxiliary Operator-A (AO-A). In comparison, the program recommended by INPO guidelines includes about 41 weeks of classroom training plus about 12 weeks of formalized 0JT tc reach this same level of qualification.

c. Thirty-five of 38 major topic and suttopic areas recommended by INPO

'iidelines are covered in the TMI-1 auxiliary operator classroom chase of instruction.

d. The structure and secuence of' trainino in the TMT-' nrocram deus not

_p arallel the INP0 guidelines. The THI-1 program begins with a classroom

, phase of about 39 weeks of instruction followed by an 11 month on-the-job phase and concludes with written and oral cnmprehensive examinations to fully qualify the auxiliary operator. The program recommended by the INPO guidelines divides training and qualification into three distinct and successive phases, each of wh'ich builcs on the other and has its own classroom, OJT, qualification, and job assignment progression.

e. Learning objectives are used throughout auxiliary operator classroom in-struction. Lesson plins are developed around the objectives. Instruc-tion, reviews, and test questions are based on the objectives.

f. Learning objectives are not based on valicated external criteria such as job and task analyses. Learning objectives for classroom ir.struction are based more on theory and design criteria than on operational criteria.

g. Test questions relate directly to the learning objectives of tne course.

Test grades average from 85% to 98%. Many of the test questions do not conform with optimum practices for measurement of Lchievement and for test question construction. Analysis of test question answers is not routinely performed to cneck validity of questions.

h. Written test security practices are screculoutly followed and firmly en-forced.

i. The 11 month on-the-job trainino prooram is loosely structured around a combination of individual study assignments ahd practical factor check-offs.

J. There_are no standards established for satisfactory accomplishment of OJT checkoffs. This makes it difficult to assure that all trainees are Der-forming to the desired standard or to compare the performance of trainees on different shifts.

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k. Thers are no standards, established for oral examination questions and responses. These examinations are employe:: mainly in the GJT phase of traiting. Qualified operators who examir,e trainees during OJT have not been trained in testino orocedures _or te:ncicues for conductino OJT. It is important that these TMI-1 Operations 3ecartment personnel perceive themselves as adjunct nembers of the TMI Training Department.

1. Job performance data is not systematically oathered and maintained in personnel records for assessing the effectiveness of the auxiliary opera-tor training program.

m. A formal and active retraining program exists. Auxiliary operators are on a .six shift rotation. Approximately one week in seven is used for retraining. '

1-3.5. Licensed Reactor Ooerator Training.

a. i The three instructors ass'gned to TMI-1 licensed operato.r training main-tain current SRO qualification in the TMI-I plant and meet the education

and experience requirements set forth in the TMI Training Department Administrative Manual / They have been assigned as TMI Training Department instructors an average of five years. Two of the three instructors have completed some college work and all three have high school diplomas,

b. The TMI-1 CR0 training program is based on regulatory requirements, industry standards, past practices, and the individual expertise and ex-perience of competent individuals involved in developing and approving the program. The content is n_ot based on a systematic, plant-specific analysis of tasks recuired to be performed by a TMI-1 CR0. _

, c. In the following subject areas, the TMI-1 c:urse content and instruction hours are consistent with or exceed the recommendations of INPO guide-lines:

_(1) Reactor heat transfer and fluid flow (2) Health physics (3) Plant technology, systems and procedures (4) Control room training i (5) Simulator training l

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d. In the following subject areas, the TMI-1 course content includes signi-ficantly fewer hcurs of instruction than recommended by INPO guidelines:

(1) Mathematics (2) Reactor theory (3) Reactor chemistry (4) Materials science

e. In the following subject areas, the TMI-1 course content includes signi-ficantly fawer documented hours of instruction than recommended by INP0 guidelines, but an additional undetermined amount of instruction is accom-piished during OJT.

(1) Transient prevention, mitigation and rcsponse (2) Plant experiences and modifications (3) Administrative requirements for CR0

f. The 38 week TMI-1 program includes a total of approximately 1405 hours0.0163 days <br />0.39 hours <br />0.00232 weeks <br />5.346025e-4 months <br /> of instruction as compared to approximately 1195 instruction hours in the INPO recommended program.

g. TMI-1 simulator and OJT course content includes the 13 plant evolutions

,' recommended by INPO guidelines to be performed or their performance simu-lated during OJT or si'mulator training.

h. { The OJT phase of training includes many tasks which must be accomplished by simulated performance during the present extended shutdown rather than

', by actual performance as woulo be expecteo at a normal operaticnal unit.

The TMI-1 OJT is not augmented by observation training at an operational unit or other special training to compensate for the reduced opportunities that trainees have to gain meaningful operating experience in the shutdown plant.

i. The seven-volume Operator Training Manual, while usable, is of limiteo vags a training document in its present form due to lack of currency, conflicts with other descriptive material, verbiage, illegible illustra-tions, and incomplete coverage of plant systems.

j. The pressure / temperature plot training program is innovative and effective in its use of computer-aided instruction and the real time visual display which duplicates the display provided for plant operation.

k. In general, most handout material used in the TMI-1 CR0 training program is more like lesson plans or technical manual chaoters than instructional material to promote trainee interaction er organize note taking.

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1. OJT instructional material consists of 22 checkoff sheets listing individ-L ual tasks to be accomplished and the required progress rate. Detailed guides are provided for studying une integrated plant operating pecce-dures. Detailed criteria are net proviced for other tasks to guice study by trainees and examinations by staff personnel. .

m. Instructors competently explained system cetails and answered trainee questions during three lecture presentations which were observed. In one of these lectures. the instructor stated heat transfer equations without an explanation to develop an understanding of the principles involveo.

In another lecture the non-licensed operator instructor maintained poor c_ontrol of the combined class of CR0 and A0 trainees.

n. During the site visit, CR0 and A0 classes attended plant system lectures as a combined group. Instructors gnd trainees commented that the dif-

_ferent backgrounds and learning objectives of the two groups cause effec-

.tiveness of the instruction to be reduced.

o. TMI-1 licensed reactor operator trainees are tested throughout the train-ing program with a variety of oral, written and performance quizzes, i examinations and checkoffs,

p. Personnel interviewed *were well indoctrinated on the absolute requirement ,

not to give or receive help on examinations. Examination security proce-dures.were observed to be followed without exception,

q. Four of five CR0 trainees passed the February 1982 NRC written license examination. The fifth trainee failed one section of the examination.

All five trainees passed the NRC oral license examination.

r. Licensed reetne coerator job performance is net routinely evaluated,

' documented. and maintained in norsonnel records.

. s. Ipprovedlessonplansinsomestageofdevelopmentareusedforallclass-room instruction in the CR0 training program. About 51 of 64 lesson plans used for CR0 training require upgrading to conform with present procedures for lesson plan development and approval.

t. Training records of 15 trainees were reviewed and all records contained required information on training attendance and test results. Some rec-ords were filed by ' training session and not by individual trainee. The

, retrieval of all training records on an individual is made time consuN Iiy this method of filing.

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k u. GPU -Nuclear has acted positively on recommendations and findings concern-ing training which are contained in reports of past investigations and evaluations.

1-3.6. Licensed Senior Reactor Ooerator Trainino,

a. The TMI-1 SRO training program is basec cn regulatory requirements, past practices, industry standards, and the individual expertise and experience of competent individuals involved in developing and approving the program.

The content is not based on a s'ystematic, Diant-specific analysis of tasks required to be performec by a TMI-1 SRO.

b. The 26 week TMI-1 SRO training program includes approximately 862 hours0.00998 days <br />0.239 hours <br />0.00143 weeks <br />3.27991e-4 months <br /> of instruction as compared to 911 hours0.0105 days <br />0.253 hours <br />0.00151 weeks <br />3.466355e-4 months <br /> of instruction in the program recommended by INPO guidelines.

c. The TMI-1 SRO training orogram is consistent with or exceeds the content recommended by INPO gu,delines in the following four of seven subject areas:

(1) Specialized education - leadership / communication / analytical skills (2) Advanced transien't and accident analysis (3) Plant operations - administrative requirements (4) Simulator training

d. The content of the TMI-1 program is less than the content recommended by INPO guidelines in the following three subject areas:

-(1) Training in procedures and the bases for procedures (Administrative procedures for maintenance and technical support; duties of load system dispatcher)

(2) In plant training (Instruction. in evolutions and SRO duties)

(3) Advanced electrical components and systems training

e. The OJT for TMI-1 SRO trainees is based on requirements for qualifying personnel at operational units with normally expected operating and shut-down periods. During the present extendec TMI-1 shutdown, the OJT phase of the program has not been augmented with observation training at operat-ing units or other special training to cocpensate for the reduced oppor-tunities trainees have to obtain meaningful operating experience in the shutdown TMI-1 plant.

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f. TMI-1 OJT tasks do not include evolutions anc coerations to be conducted, oI) served or simulated by SRO trainees .as recommended by INDO guidelines.

g. Detailec criteria are not provicea for sa .isf actory accomplisnment of OJT tasks.

h. Nine of 24 lesson plans used for SRO traini'nc nave obiectives wnich re-flect SRO level of knowledge requirements. Tne TMI Training Department stated the remaining lesson plans are gng upgraded to provide different objectives for SRO training.

i. Two of four TMI-1 SRO trainees passed the June 1982 NRC written license examination.

j. Training records of two TMI-1 SRO trainees were reviewed and found to contain required information on training attendance and test grades.

k. The TMI-1 program description prerequisites for SRO training permit satis-fying experience requirements without having exoerience as a CR0 at TMI-1.

This experience prerequisite is not consistent with INPO guicelines wnich recommend that an SRO candidate have at least six months experience as a CR0 at the unit on which the individual is training as an SRO. The INPO guidelines provide for experience waivers on a case-by-case basis.

1-3.7. Licensed Ooerator Recualification Training.

a. The TMI-1 licensed operator requalification training program is now being conducted for the first time in accordance with the present program description. This program is based on 61d corresponds closely to the requalf fication program recommended by INPO guidelines. The TMI-1 program exceeds the INPO program by including approximately-240 hours of instruc-tion per year in the preplanned lecture series compared to the INPO recom-

. mended content of 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />.

b. The THI-1 program requires attendance at requalification lectures based on requalification examination grades anc provides for excusing absence from requalification training for up to one week per year.

The INP0 recommendations and 10 CFR 55 Appendix A recairements specify lecture at-tendance by all licensed operators.

c. The 10 CFR 55 Appendix A requalification pregram requirements provide for systematic evaluation of licensed operator performance and the inclusion 1-25

l ATTACHMEhT 2 EXCERPIS FROM REPORIS OF TWO AUDITS (RHR, BETA)

DATED 1983 With Summary of Effect on Licensing Board's Decisions (This material was provided to the Boards and parties as Appendiz B in Aamodt Response to Appeal Board

> dated July 1,1983.)

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• Cohcern~ing the adeoueev of trainine for overetors, the RER '

findings conflict with the Ideensing Board's findings and con-clusions at # 202, 207, 224, 228, 230, 241, 259, 262, 264,.539, 554, 584 (c) of'the J.ugust 27, 1981 FID and 52342, 2343 of'the July 27, 1982 PID. The RHR findings below appear on the fifth through seventh pages following Table 11 in the report of the study.

RER Findings Close to three quarters of the operators . .. we're cis-satisfied with the traintag for licensing and even a greater proportion strongly were dissatisfied with requalification training.

Operators complained of a lack of convergency between training, testing and ability to operate the plant.

Three out of four denied that training prepared them for

, what they actually do. In their perception . training prepared individuals to pass exams and is successful at this but it does not grepare them sufficiently to operate.

It is apparently the policy of the training department to include only material in the training programs on which operators will be tested. There is very strong concensus that training should include material on whey they would not be tested.

Those who come u a disadvantage in (p learning from thenuclear plant feel left behind and at theory).

(Navy trainees) would..like to see more systems training to help them understand the role of the individual pieces of equipment within the total plant.

T.here.is strong agreement that there is not enough training on plant conditions.

These RER findings, .not on the record, agree with record evidence which was rejected by the licensing 3oard G ,

. w in their findinga citsd ebevo and is pressnted and/or discussed in lemodt Findings, May 15,19s i a #16-20, 86, 101-103, 109; lemodt Reply Pindings, June 29,1981 a t #31, 34, 36, 37, 60, 60 (a ),

81, 85, 94-97, 100, 102, 103, 113s115, 118-124, 127, 130, 132, and Aamodt Findings, March 3,1982 (Reopened Proceeding) et #333, 363, 368.

BETA did not attempt to make a first-hand determination of the quality of the training effort to find out if licensed operators were being taught the correct material in quality or quanitity, (SETA 57). SEIA 's attention was to the functioning of the GPUN organization including plant management.' Their findings were that GPUN does not have the capability to identify, problems, fashion suitable remedies and implement them in the training area. These findings conflict with the Board's assumption that identified deficiencies would be addressed and promises kept. See August 27,1981 PID at #537, 550-554, 550.

July 27,1982 FID at #2332, 2336, 2341, 2344-2347.

Concerning the espability of GPUN to effectuate..defici6ncies in training of onerators, 3ETi reported a nuater of findings on pages 55, 57, 59, 63, 70, 77,113 and 114 some of which ere presented below.

l 3ete Pindings The Hecdquarter training group is not concentrating enough on coordinating plant training efforts.

. .the headquarter!s role in traininc. . .is not being pursued to the extent that it should...there are people in the headquarters organization that could be doing this function but they are not.

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Becauce o'f the many problems being found in the training.

. programs a t TMI-1 . . , (you) would assu=e(d) the't there would be noticeable evidence of Technical Functions involve-ment with corrective. effort. BETA could detect very little, end it is not clear that there is at this time much interest in thehaving(any, either plant s), or on the part the Training of Technical Divisien. Functions,this BETA considers to be a mistake, particulerly with respect to operator training.

..to much emphesis is being placed on prqving to the .world that the training program is good end not enough on doing what should be done to produce e competent ?.perator.

..more attention is being paid to the " trappings" of training rather than to e concerted effort on obtaining an effective end product.

(Ne). .often heard the expression, "thbags will never change, they have been that way too long".

Management must be in a position to use its judgment. (The problem that it cannot) manifests itself throughout the entire organization at all levels.

We frequently encountered senior people in GpUN who. felt that the (K Lepartment was not responsive to the absolute need for QA support...that QA was not urgently concerned with resolving problems and clearing deficiencies.

RHR findings confirm BETA findings. The pertinent RHR findings appear on the page following Table 5 and at. the second page after Table 12.

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RER Findings (The operators) fault their leadership for crisis management

. . . lack of management effort in bring about coordination within thiststructure. They keep saying "there is no one in charge".

Operators.. . spontaneously inquir(ed) whether e aything will come of these interviews.. .From some previous inquiries they have seen no action and from others, temporary action which quickly petered out.

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The Iemodt findings, although based on other evidence, are consistent with the auditors' findings. See 1.amodt Findings, May 15, 1981 et #76-95, 106-108; Jac.odt Reply Findings, June 2 9, 1981 at #77-79, 92, 94, 95, 101, 104-105; ;s:cdt Findings, Merch 3, 1982 (Reopened Proceeding) at #347.

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4 Cenenrnink attendance in traininc sessione, a problem area identified in the 1976 audit (See Jacodt Comments, April 22, 1983 at 8-9), the consultants found that the problem remained in 1983. The consultants' findings conflict with the licensing Board 's findings (1.ugust 27,1981 PID et s101-102, 169). ,

RHR Findings Operators complain that not enough time is devoted to requalification training. Even what is scheduled is often cancelled at the last moment. (sixth page after Table '11)

There is dissatisfaction with .the (requalification) training.

Insufficient time is devoted to this. (first page after Table 2/3)

The Aamodt findings are consistent with the consultants' findings. See lemodt Findings, March 3,1982 (Reopened Proceeding) at #334,337, 363-365. The new information supports the Aamodt c6nclusion that the GPUN exhibit of numbers of hours operators attended requalification training was falsified or misrepresented.

See Id. at #365. .

Concerning staffing of the plent with licensed overetors and the role of the Shift Technicel Idvisor, the RHR study indicated =~-

that some inexperienced operators are being used in positions where the'y do not feel capable.

RHR Finding i

New operators are expected to perform like ones with ten 1 years experience. (second page after Table 11)

The licensing Board noted that staffing was hottly contested issue (l ugust 27,1981 PID F79). which they believed was satisfact-o711y resolved (Id. at #569-572). We believed thet the evidence did not support the Board's conclusion concerning the staffing of the control room, dee J acod: Findings, (Reopened Proceeding),

erch 3,1982 at e340-342, 328, 329, 336, 345-348; Jacodt Findings, Eey 15, 1981 et e53; letod Reply Findings, June 29, 1981 at

1. 70-74, 82, 108.

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Concernin't thn training and rola of the Shift Technical Advisor, BETA found a number of problems which call into question theLLicensing Board's findings, IuEust 27,1981 IID at #80-82 but are consistent with our findings, June 29,1981 at #66-69.

EET! Findings Chere ere a number of problems essociated with the STA progrem. . 2hese problems involve attrition, the STA training program, and proper utilization of the STAS,

. . .in their status as qualified STA s.

. ..there is a serious lack of understanding on the part of the Shift Supervisors.. .on the role of the STI.

. . .there is an element of distrust of the STA s ' ability and of.their motives.

The Shift Technical Advisor (STI) progran...needs to be reviewed and strengthened.

oncerning the behavior of instractors in the TMI

, Trainine Department, BETI identified problens in addition to

. that admitted by the Licensing Board (July 27,1982 PID at

1. 2333, 2335, 2337, 2341-2344, 2347(2).

EETA Findings

. . .there should be concern over cla ssroot performance (page 58).

. . . job inattention noted (Id.)

l . . . supervisors, who were present, did not reect to l situetions where instructors were not performing their l assigned tasks.. . (this) appears typical _ of the normal i mode of operetion(Id.).

l . . .the Training Depertment. . . lacked the degree of toughness, I accountability, and insistence on perferrance needed in the l nuclear profession. (page 57)

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Ihe capsbilities of the instructors hed been a concern in the mein hearing which it was apparent the Board had not resolved. See Acmodt Findings et #88, 89, 105, 81; additional Jamodt Findings, Farch 4, 1982 a t F255-25E, 277-281, 282-286. -

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6 Concermin[ attitudes that fostsr sefety, 1. e., recognition of dangers of nuclear technology, piscing safety before efficiency, need for cooperation, discipline and best effort, both consultants alar 61ng problems.

RHR Findings

. .e ma jority of Trainees. . (disagreed) Thet top manegement is more concerned cbout public safety than it is about Generating electricity. (at first pege following Table 13)

L majority of operators, but only a slight one, would not put efficiency second to safetye Only one subgroup, R0s at TMI have a majority placing safety above efficiency.

It is perha ps significent that one quarter agreed.. .that operators like themselves lived so closely to their tech-nology that they tended to underesticate the potential denEer. (second page following Table 10)

. . . putting safety ehead' of efficiency is. . .a difficult adjustment to make. It requires undoing of habits and values one has grown accustomed to take for granted.

(first page following Table 10)

These findings indicate ,thet the Idcensing Board's conclusion that operators' attitudes "did not appear to the .-

Board to be s problem" wa s ill-founded. Eie lugust 27, 1981 PID et e267. This issue was not examined by the Licensing Board despite several efforts et consciousness reising. See Aamodt, ff. Tr. 12, 931 et 6-9; Tr. 20,365-369 Aerodt, Smith, Tourte11otte; 2r. 24,256-257 Aemodt, Eilhollin. The issue of attitude was only f

considered as it related to the cheating on KRC examinations.

3E1A described behavior which is a reflection of the l

l e ttitudes found in the RHR study:

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. BETA Finding

. . .there . existed an attitude, not only within the TMI Training Department, but also at the plant of almost patronizing the students. There seemed always to be excuses why students did poorly, why operators made mistakes, or if there were cheating, why it occurred (page 57).

The above finding was based on observations made in Earch and April of 1982, efter the Reopened Proceeding on cheating.

> hha t sparse record exists in the Restart Proceeding concerning operators' and management's attitudes, aside from specific matter of the NRC examination process, is noted in our findings, May 15, 1981 at #74-76, 80, The licencing Board denied our request to depose employees by use of a written questionnaire, to determine attitudes and opinions on a number of subjects on technicalities. (Memorandum and Order on Aamodts ' March 20, 1980 Motions to Compel licensee to Respond to Discovery Requests,

' April 10, 1980 at 7-9)  :

Concerning selection of operators and cenerers, 'the BETA and RHR studies provide evidence that the licensing Board made 3

a gross error in denying f amodt Contention 1 which stated It is contended that TMI-1 should not open until a program of psychologicel testing and counseling of operator perconnel and manegement be instituted ar. routinely

- maintained to observe and/or alleviate or emeliorate fatigue, boredom, hostility, confusion, substance abuse, end/or other characteristics deemed inconsistent or contrary to the safe operetion of said nuclear plant.

i 1/ First Speciel Prehearing Conference Order, December 18, 1979 ct pa6e 321 Tr. 432-393 435+

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. Tha EETA 'ctudy nottd oc one " contributing causn" to inefficient or poor management the personal appearance and demeanor of supervisors and managers. (paEe 106,107 (h)).

Even more troubling is EETA's implication that the managers and supervisors were not aware that their appearance did not measure up to ecceptable standards. (pege 109(k))

The explanetion for these 3ETAffindings may be provided by the RHR study. Concerning disciplinary sanctions for viol'e ting regulations, RHR found the following:

While this is not a major priority concern of operators, it is one which generated a lot of ecotion at TMI when stiff sanctions were promulgated for those discovered bringing mind altering substances into the parking lots at EMI. This was not en issue at Oyster Creek where parking lots are not within a security check zone.

There is strong acceptance of.' regulations on mind altering substances. However, a majority dise rree that discitlinarv trocedures are fair. They also agree that when it comes to disciplinary practices there are two standards: a tough set for oDerators and an ea sier set for tor canecement.

(third page after in ole 11)

The RHR study is not clear on this subject. The findihg The RER study is not totelly clear, however, the . ,

finding does indicate that the possession of mind altering sub-stances and their use is of more than passing concern to the operators. Also indicated is the existence and resentment of a double standard. Implied is that the operators are aware

, of drug use emong top management or other wrong. doings, not specified.

Improper selection of supervisors was identified by BETA (pege 77):

Soo often people are made supervisor who, if the truth were known, reelly do not want to be supervisors. Some people have en inherent disteste for being toss. Others have grown up in a community of peers, having been close personal friends with them for years and are unwilling to alienete those relationships even though they may take the job when offered.

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.9 The BETA study notsd as ono " contributing cause" to inefficiency was the personal appearance and demeanor of supervisors and managers. (pages 106-109; 107(h); 109(k))

The RHR study noted "significant personal and family problems" among 10-15% of the operators end a " reluctance" to use the stress control services provided by'GPU. (third' page of report) i I.

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ATTACHMEhT 3

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Attachment 9, a Table from Report of the LESSONS LEARNED WORKSHOP (August 24,25, 1983)

Dated December 22, 1983 S

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ATTACHMENT 9 Sumary of Lessons Learned Response Status Based on Working-Group Assessment Items in Implementation Status Category l 1 1 2 l 3A l 3B Number l In i In l Review Needed of l Place l Progress l(Prompt) l (Long-Items l l l l term) lTMIl OC l TMIl OC l TMIl OC l TMIl OC i l 1 l l l l 1 1 I I I I l l l Work Group it: Operations, Maintenance,l l l l l l l l and Radiological Controisi l l l l l l l l l 1 1 I i l 1 Generic 1l l l 11 1l l l l

. Procedures 2l l l l l 1l 11 1l 1 Rad Con 10l 7l 7l 21 2l l 1 l 1l Conduct of Operations 12 1 5 1 4l 6l 6l l 1l 1l 1 Operations Trng. Supp. 4l2l 1l 1l 1I i 11 1l 1 Maintenance 4l l l 3l l l 11 11 3 Chemistry 1l l l 1l 1l l l l Logs / Records 211l 11 1l 1l l l l Spare Parts 1l l l l l 1 1

• 1 l' l Group Total 37 l15 l 13 1 15 1 12 l 21 6l 5l 6 I I I I I I I I Work Group #2: Technical Support i l l l l l 1 l I I I I I I I I Engineering / Analysis -

4*l 2 l 2l 31 3l l l l Plant Modifications 1l l l l l l l 11 1 Technical Information 311l l 21 3l l l l On-Demano Tech Capability 5131 3i 1l 1l l l 11 1 Group Total 13 1 6 1 5l 61 7 1 -- I -- l 2l 2 I l l l l l l 1 l l l l l 1 1 I Work Group #3: Other Support l l l l- l l l l 1 l l 1 I I I I

! Training 8*l 1 l 11 7I 7l 11 1l l Organization / Management 4*l 1 l 11 31 3l 1l 1l l Comunications 2l l l 11 1l 'l l 1l 1 l- Reccrds & Documents 11 _l l 11 1'i l l I i Group Total 15 l 21 2 1 12 l 12 1 2.I 2 l 11 1 l l( I l ._ . l l l 1 I i 'l l I -l l l l .I Work Group #4: Emergency Response l l l l l l l l l l l 1 I I l l Recognition 6l4l 21 1l 2l l l 1l 2 Declaration 313l 2I I 11 I l l Comunications 11 16 l 7l 41 3I I l 11 1 Response Readiness 11*l 6 I E1 31 3l l l 11 1 Group Total 31 121 1 19 I e1 9l -- I -- l 3l 4 OVERALL TOTAL 96 .

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l l-CATEGORY TOTALS

• 100 144 l 39 I 41 1 40 1 4i S I 11 1 13

• one item split into two parts with separate status ranking

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