ML20096D738
| ML20096D738 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/04/1984 |
| From: | Weiss E HARMON & WEISS, UNION OF CONCERNED SCIENTISTS |
| To: | METROPOLITAN EDISON CO. |
| References | |
| SP, NUDOCS 8409060268 | |
| Download: ML20096D738 (14) | |
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UCS 9/4 /8U U!!T*ED 9T ATF:' 0F AW R?fA MUCLPAR PEGULATORY COMM" !ON CCCKET[g
'E PEFORE THE ATOFTC SAFETY AND LTCENSTNG BOARD E!I MI Tn the Matter of
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METROPOLITAN FDISON COMPANY
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Docke t No. I50-ER9 SP-
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( Pest art-Man ag ement Femand)
(Three Mile Island Fuelear
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Station, Unit No. 1)
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UNTON OF CONCEPNED SCIENTTSTS' PES PO'!SF TO LTCFNSEE 'S F TRST SET OF INTERROGATORirS AND FTRST RFOUEST FOR PRODf!CTION OF DOCUMENTS TO UCS U-1( a). State the name, present or last known address, and present or last employer of each person, other than affiant, who provided information upon which UCS reviewed in answering each interrogatory herein.
( b). Identify all such information which was provided by each such person and the specific interrogatory response in which such information is contained.
These interrogatory responses were prepared by affiant aftar general discussions with Pobert D. Fo11ard, Union of foncerned Fcientists, and William S. Jordan, Harmon, Weiss and Jordan, concerning UCS's positions in this pro-ce ed i ng. The responses were reviewed in their totality by Robert D.
Pollard.
U-2 (a).
Identify all douctnents upon which you relied in answering each interrogatory herein.
( b).
Tdentify the specific interrogatory response (s) to which each such docinant relates.
The doctnents are identified in the responses.
U-1( a).
Identify any othar source o f in formation, not previously idantified in response to interrogatories U 1 or U-2, which was used in answering the interrogatories set forth herein.
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Tdentify the speci fic. interrogatory response ( s) to which each source Lof information relates.
p" Tach source of 'information is 1dentified in the appropriate response.
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U4
' Identify the concerns UCS has about the adequacy of the licensed l operator = training program at.TMI.
At5 this stage, prior' to discovery, UCS's concerns are generally the same as those' identified by the Special Master, ASLB and Appeal ~ Board.
U The concerns are summed up by the Appeal Board as follows:
"Is the instruction adequate to prepare the operators to operate the plant-safely?"
A LA B-772, S 1.'o p, a t 6 3.
More ' specific concerns at this time relate to 1) whether the content of the trainingL program enccupasses the skills and knowledge necessary to operate the plantlunder: accident or unusual conditions, 2) whether the tests are adequate to accurately evaluate whether, the operators, possess these skills and knowledge,-3) whether memorization plays too great a role in-the training and testing ' programs, 4)- whether the training' and tests are in confomance.with current: plant procedures and design, 5) whether the tests are properly
' reviewed for difficulty ~ and validity, 6) whether GPU management has instilled a:
the appropriate attitude. in its. training and operations staff, 7) whether the program is being properly implemented,- 8) whether. the OARP Peview Comittee
- conclusions are. correct and ba::ed on adequate first-hand knowledge and observation,- 9) whether the instructors are qualified and effective., "Ihese Leoncerns are subject -to modification and addition based upon the information to be gained through on-going discovery.
U-5.
Tdentify the basis for.each of-the concerns identified in response to interrogatory U-4
- 1 LB P-82-14 R, 15 NRC' 91 P (1982) and transcript citations therein,
. including but not limited to 15 NRC 1014-1020 e
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LBP-82-34R ~ and transcript citations therein, including but not c
l limited - to.15 ' NRC.-1014-1020, 1026-1035, 1054-5.
3.7 1LBP-82-348 :and transcript citations therein, including but not-
' limited to 15( NRC 1014-1020, 1026-1035,.1054-1055.
- 4.. - General knowledge.concerning the frequency and. large number. of c'ontinuing changes to the TMT-1 plant procedures',- including ATOG procedures, and L the nany changes in plant design.
5.
.LBP-82-34B and transcript ' citation therein, including but not lbnited to 15-NRC 1014-1020, 1026-1015.
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6.
LBP-82-34B and transcript citations therein, including but not limited to 15 NRC 954-965.1044-104 6, 990 101 ?, 104c-1054 GPU's treatment of-
' individuals such as G & H Shipman,. Husted, Long, and Newton. GPU's position
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that Floyd did not cheat when he handed in the work of another as reflected in its litigation position and - in the '"Fpeiker - Report."
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7.
The basis ' for this concern is a combination of these cited above.
gg 8.
_ Die Fpecial Report of _ the Peconstituted OARP Review Committee, June 12,.1984 9.
The fact that' disdain, for' the training - program was widespread,
-including-anong training instructors.
(Fee ALAB-772. at 64 -and transcript citations); the' consist'ent findings of the' Fpecial Master and ASLB regarding 1the' actual content and method of instructon of the TMI 1 training, program, the emphasis -in menorization at the ex pense of or as a substitute for understanding (e.g. 15 NRC 1014-1020)1 licensee's treatment of individuals such as Messrs. Rusted, Long, Newton, and Frederick; the fact that the current T
head of licensed operator training, Frederick, has. flunked his exrmination.
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J U -6.
' Identify the remedy:that UCS considers appropriate to respond to each of the concerns -identified. in response' to interrogatory U 4 UCS has notL 00nnulated a comprehensive list of remedies at 'this stage
!nor detennined _ whether it will. undertake.to do so. ~ At a minimum..UCS would
- consider 'it ' necessary thatj an independent' team of ed ucational psychologists
- and persons. faniliar with nuclear plant < design and operations. review the -
contentf or the training program 1and its past and current implementation, interview operators and-instructors, review the OARP-related as well as current' qualification and requalification written and oral tests for difficulty and validity.. determine the extent to which memorization is used as a substitute for understanding, conpare the training and tests against current procedures and plant design.
By " independent," UCS means persons not in the pay of GPU or the NRC, not thoroughly identified with or dependent upon the nuclear -industry and not in a position of having to defend the' accuracy of previous testimony given ~.in this case.
UCS also. believes that questions of attitude and integrity are involved in this issue and we seriously doubt that GPU training programs can be -
effectively administered by persons who bear responsibility for the conditions which caused widespread disdain for the training program, persons who bear responsibility for GPU's response to the cheating episodes - a response which UCS considers egregiously inadequate, persons who do not ' acknowledge or understand that the training program revealed by the evidence in the creating L hearings.was a failure. ~ 1here has been a wide gul f in this case between theory'and l practice, or between how'the program was characterized on paper versuslhow it was actually carried out.
The. existence of so wide a gulf, and
- the factIthat it :would presumably never have been discovered had not obvious cheating ' occurred on HPC ex ens, indicates the large degree to which the
'efec!Ireness of.the training program is dependent upon the persons and
' organi zation bnplementing it.
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-S-U -7
. Does UCS consider menorization an inappropriate learning technique? If so, _ ex plain why.
If not, explain the basis on which UCS would assess whether memorization is being used as an effective. learning technique.
Memorization in-excess or as a substitute for or at the expense of understanding is --inappropriate. It does not reveal much about an operator's ability to confront a new and dif ferent situation. _If used to excess, it detracts-fron.his/her ability to learn the necessary concepts. Nor does an operator's ability,to stout. memorized phrases provide assurance that he/she possesses the skills necessary to oparate a nuclear pl a n t.
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U-8.
How would UCS determine 'what training is necessary to ensure that operators are able to run the plant?
. Fee the first paragraph in response to question U 6 above.
.U-9.;: Tdentify the specific subject-area ( s) in Licensee's licensed operator training program that UCS believes require enhancement.
U-10. For each subject-area identified In response to Interrogatory U-9,
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explain the basis for UCS' view that training in that area should be enhanced.
' U-1 1.
Explain how,:in UCS' view, each of the subjects identified in response to Interrogatory U-4 should be enhanced.
UCS is not currently in possession of' sufficient information to permit it to respond to'these questions.
U-12.
In UCS' view, does the fonnat of Licensee's exams encourage cheating?
Provide the : basis for ' your answer.
. In - UCS's view, the format and implementation described at 10.iRC 1014-1020 and citations therein encourages cheating because memorization of word - fonnulas was enphasized as a substitute for understanding and the same
- questions asked over egain on make-up rounds.
Tt beenme known to candidates
'that the : examiners were looking for certain key words. Therefore, cheating could -be an ef fective way to pass the test.
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. U-13
-Tdhntify the standard on which UCS relies to determine whether the t ronnat of ~ Licensee's ex ams encourage cheating.
UCS believes: that1an exam encourages cheating to the extent that it is overly: reliant on rote memorization.
The appropriate degree of reliance is'a matter of judgment L U-14.. Does DCS.believe licensed ' operators should be required to spend additional t'ime at. the simulator?
If so, explain the basis for your answer.
U -15. - Does.DCS believe licensed LoperatorsEshould be tested on the simulator?
' If'so, ex plain the. basis for-your answer.
UCS has not-yet formed an opinion on these subjects.
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- U-16.
Does UCS believe that the licensed operators are capable of safely operating TMI-1 during normal operation or accident conditions? If not, a
explain the basis for your ' answer, ' expecially as it relates t'o any perceived deficiencies in the training program.
DCS believes that the answer to th,is question is indeterminate. We believe that-the system of GPU training and.GPU and NRC testing as _ described on the evidentiary record in this case does not provide reasonable assurance that the operators are capable of: safely operating D1T-1 Whether some or how many are so capable is a matter of conjecture.
Iden' ify any documents on which UCS relies to support its position in U-17.
t response to Interrogatory U-16.
t UCS relies on the decision of the Special Master and portions of the
' decision of the Licensing Poard and transcript citations in both.
- U-18. - What capabilities,- if any, would you require operators to have that you believe they' presently lack?
' As = noted above (U-16), we :believe that, on the basis of the current evidentiary' record, it is not possible to make a reliable judgment as to which skills operators have and which they lack.
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U-19.
in ItCS' opinion, do Licensee's exams reliably measure the operators' ability to safely operate TMI-1? TT not, why not?
UCS believes that the exams as described on the evidentiary record do not. reliably measure the operators' ability to safely operate TMI-1 for the g
general reasons stated 'at paragraph 251 of the Report of the Special Master, 15 NRC 1020..
U-2 0.
Identify each deficiency UCS believes exists in Licensee's examinations.
At this stege, we 'would concur with the statement of deficiencies of the Special Paster, cited above. We expcot during the process of discovery that our' listing of deficiencies may well change.
UW21 Ebes UCS believe the NRC exams should be relied upon as a reliable measure of an operator's ability to safely operate D1T-17 If not, why not?
UCS believes that the NRC rules require that the NRC exam be a reliable measure of the operators' ability to safely operate TMT-1.
Tn particular, 10.
C' R 55.11(b)' requires that each applicant for a license pass a written F
exanination and operating test "to determine that he has learned to operate and, in the case of. a senior operator, to operate and to direct the licensed activities of licensed operators in a canpetent and safe manner."
See also 10 CFR 55.20, 55.22, 55.23 (content of ex ans).
In additon, in this case, the Commission's order of August 9,1979.. required retraining and re-examination by both GPU and NRC of all D1I-1. operators in areas related to the TMI-1 accident. CLI-79-8, 10 NRC 141, 144-5 (1979).
UCS thinks it beyond serious dispute that such requirements for NRC examinations necessarily imply that the exaninations given must be a reliable measure of the operators' ability to safely operate the plant.
Powever, the evidentiary record in this case also indicates that the NRC exams are not a reliable measure of the operators' ability to safely operate
.. the plant.
As 'noted in the Report of the Fpecial Paster, the NRC ex aminers were{ heavily dependent upon the TMT-1 staff for answers to the questions, and 3,
the.NRC exams relied -heavily upon rote memorization, were not respected by the Loperators, and asked about design details rather than testing ability to solve a prcblem.15 NRC 1026-1035.
. U-2 2.
Does UCS believe the NRC exams are relied upon by Licensee's a reliable measure of an operator's ability to safely operate V11-17 Explain the basis for UCS' view.
.GPU has no choice but to " rely" on NRC exams; its operators must pass those exams or they will not be pennitted to operate TMI-1 Whether GPU
-believes that the NRC exams are, in fact, a reliable measure of an operator's ability to safely operate V4I-1' is within GPU's own knowledge.
U-23
' Identify the concerns UCS has about the TMI licensed operator training progran, if any, based on its review of,,t,he RHR Report.
- U-2 4. -Identify each specific portion (i.e., particular page(s) and particular t
statement (s) of the RHR Report on which UCS relies in formulating its response to Interrogatory U-23.
UCS has not canpleted its review of the RHR Report. - As a preliminary matter, we consider it a matter of concern that a substantial number. of operators express doubts about the relevance of the training to their actual operational duties
"... only 60% of those who responded agreed that the content of the last exam was job relevant and only one third agreed that the oral portion of the exam tested how one would act in an emergency."
" Priority
' Concerns of Licensed Puolear Operators at TMT and Oyster Creek and Suggested Action Steps," Final Peport, March 15,19P3, (hereinafter "RHR Report"),
unnumber page headed " Licensing, Requalification and Training.
Other concerns relate to:
1.
A significant minority of operators do not believe that the requalification progran promoted safety. Id.
_g.
Almost 3/4 of the operators were dissatisfied with the training for 2.
l licensing and even more with the requalification training. Id.
3.
Most operators considered the training department as not oriented to L the needs of the operators.
Id., next unnumbered page.
-4
- Most operators believe there is not enough training on plant conditions.. Id.
.5.
Three'out of four operators believe that the training does not prepare them for. what they actually do; instead, it prepares them to pass ex am s.
Id.
There are many other specific findings contained in the PHR Report, written in.1983, which undermine the opinions of the OARP Review Comnittee and indicate that the Special Master was correct in his finding: regarding the content and edninistration of the CPU training programs and that these
~'
conditions persist.
U-25.. Identify the concerns UCS has about the TMI licensed operator training program, if any, based on its review of the PETA Peport.
U-2 6.
Identify each specific. portion (i.e., particular page(s) and particular statement (s) of the BETA Report on which UCS relies.in formulating its response to Interrogatory U-25.
UCS has not reviewed the BETA Report.
U-27.
Identify any criticisms UCS has of the Special Report of the Reconstituted OARP Review Committee, dated June 12, 1984 U-2 8.
Identify each specific portion (i.e., particular page(s) and particular statement (s) of the Special Peport of the Reconstituted OARP Review Committee on which UCS relies in fonnulating its response to Interrogatory U-27.
. UCS's review of the Special Peport is ongoing.
In general, our criticisms new are as follows:
- 1. The Special Report is conclusory in nature. While a great many documents are listed in Table A-2 as having been "provided by GPU !!uclear to L..
t'
.' the Committee for their review," the Peport does not indicate how many were actually reviewed, nor does the body of the Report, in all but a few cases,
~
indicate which documents support which conclusions. One must thus take the conclusions of the the Committee largely on faith.
- 2. The Committee states in many places that its time and resources were
- "l im it ed." Indeed, the Camnittee itself concedes that "the primary bases the Committee members have for re-assessing the effectiveness of the training program is the material provided to the Cawnittee by GPU Nuclear..., its Ldiscussions with management personnel, mostly from the Training and Education Deparbnent, and the performance of operators on NPC administered and NRC-sanctioned, GPU Nuclear administered exaninations." (p. 73) Only one operator was even interviewed. (Tabic A-1)
The Committee did not conduct a
" quality assurance check" on the docunents given it by GPU. (p.3) It is our
^
ootnion that such a limited "revie5F 1s manifestly insufficient to enable the Committee to reach an informed judgment regarding the remanded issues.
- 3. UCS questions whether the qualifications of the/ committee members are adequate to permit them as a conmittee to reach many of the conclusions contained in Chapter V.
4 The conclusions in Chapter V are highly generalized and relate in many cases tc GPU managements' "committment" and "detennination" rather than to the actual content or effectiveness of the training program. Consid ering that 15 out of 17 individuals " contacted" by the Cannittee were GPU management (Table A-1), this 'is not surprising.
- 5. The special Report does not evidence an understanding or grasp of the nature or scope of the cheating and lack of integrity documented in the evidentiary record. ( See e.g., p. 65 )
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- 6.. The Committee evaded.the ' questions of integrity and judgment by
- relying on-; paper qualifications.
'(e.g., pp. 16-19)
E Submitted by:-
s E11ynh. Vei38 Harmon, Weiss & Jordan General Counsel
. Union of Concerned Scientists
(
Dated : September 4, 1984 am.o*-
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' UNITED STATES OF AMERICA
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NUCLEAR REGULATORY COMMISSION
'Before' the Atomic Safet y and LJ censing' Board In the Matter of'
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. METROPOLITAN EDISON. COMPANY
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Docket No. 50-289 SP F
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(Restart - Management Phase)
~(Three Mile Island Nuclear
)
' Station, Unit No.1)
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l-AFFIDAVIT,QF ELLYN R. WEISS-I, Ellyn R. Weiss, having been sworn,. do hereby_ affirm that the answers contained in the foregoing " Union of Concerned Scientists' Response to licensee's 'First Set of Interrogatories
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and'First Request for Projection of-Documents to UCS" are'true and accurate to the best of my knowledge and belief.
1 Ellyn R. Weiss Washington, D.C.
Sworn and subscribed before me this 1
- W day;of September,~1984:
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'G Notary-Public-My Commismon Expires April 30, 1987
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- s UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSTON j
In the Matter-of
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METROPOLITAN EDTSON COMPANY
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Docket No. 50-289 SP
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(Pestart-Mamangement Renand)
(Three Mile Island Nuclear
)
Station,-Unit No.1)
)
CERTIFTCATE OF SERVICE I hereby certify that copies of UNTON OF CONCERNED SCIENTTSTS' RESPONSE TO LICENSEE'S FIRST SET OF INTERROGATORIES AND FIRST RE00EST 'FOR PRODUCTION OF DOCUMENTS TO UCS" have been served on _the following persons by deposit.in the United States mail, first class postage prepaid,.this 4th day of September 1984, except as. indicated by an asterisk.
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Nunzio Palladino, Chairman Dr. Peginald L. Gotchy U.S. Nuclear Pegulatory Cannission Atomic Safety and Licensing Appeal Washington, D.C. 20555 Board U.S. Nuclear Regulatory Commission Jones-Asselstine, Connissioner Washington D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Judge Christine N. Kohl Atomic Safety and Licensing Appea?.
Fred erick Bernthal, Commissioner Board U.S. Nuclear Regulatory. Cannission U.S. Nuclear Pegulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Thomas Roberts, Comnissioner Ivan W. Snith, 01 airman '
U.S. Nuclear Pegulatory Commission Atomic Safety and Licensing Board Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Lando ' Zech,' Commissioner U.S. Nuclear Pegulatory Cannission Sheldon J. Wol fe, Alternate 01 airman Washington, D.C. 20555 Atonic Safety and Licensing Board U.S. Nuclear Pegulatory Commission
.Garyc J. Edles, Chairman Washington, D.C. 20555 Atomic Safety and Licersing Appeal Poard Gustave A. Linenberger, Jr.
U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Poard Washington, D.C. 20555 U.S. Nuclear Pegulatory Commission Washington, D.C. 20555 Dr. John. H. Buck Atomic Safety and Licensing Appeal Mrs. Marjorie Aamodt Board R. D. #5 U.S. Nuclear Regulatory Commission Coatsville, PA 19320 Washington D.C. 20555 O
.1
. Maxine Waelfling, Esquire
- William S. Jordan, IIT
. Office of -Chief Counsel Harmon, Weiss ' & Jordan
- Department of Fhvironmental Resources 2001 S Street, N.W.
505 - Executive House Suite 410
, P.O. Box 2357 Washington, D.C. 20009
. Harrisburg, PA #17120 John A. Levin, ' Assistant Counsel Ms. Louise Brad ford Pennsylvania Public Utility Commission Three. Mile Island = Alert P.O. Box 3265
- 1011 Green Street Harrisburg, Pennsylvania 17120 Farrisburg, PA - 17102 Docketing and Service Section Joanne Doroshow Office of the Secretary The Christic~ Institute U.S. Nuclear. Regulatory Commission 1324 North Capitol Street-Washington, D.C. 20555 Washington, D.C. 20002 Jack Goldberg Lynne. Bernabei Of fice of Executive Legal Director Government Accountability Project U. S. Nuclear Regulatory Commission 1555 Connecticut ' Ave., N.W.
Washington, D.C. 20555 Washing ton, D.C. - 20009
- Frnest L. Blake Dr. Judith H. Johnsrud Shaw, Pittman, Potts & Trowbridge Dr. Chauncey Kepford 1800 M Street, N.W.
Environmental Coalition on Washington, D.C. 20036 Nuclear Power 433 orlando Avenue Michael F. McBride State College, PA 16801 LeBoeuf, Lamb, Leiby & McRae 1333 pew Fampshire Ave.,
N.'d.
Suite-1100 Washin6 ton, D.C. 20036 v
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- Hand delivered.
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