ML20098B803

Supplemental Response to Licensee First Set of Interrogatories Re Training Weaknesses.Related Correspondence

ML20098B803
Person / Time
Site:	Three Mile Island
Issue date:	09/24/1984
From:	Bernabei L, Doroshow J CHRISTIC INSTITUTE, GOVERNMENT ACCOUNTABILITY PROJECT, THREE MILE ISLAND ALERT
To:	METROPOLITAN EDISON CO.
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ML20098B801	List: ML20098B799 ML20098B803 ML20098B807
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SP, NUDOCS 8409260283
Download: ML20098B803 (9)

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'*- UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensik B r In the Matter of -)

) ~

METROPOLITAN EDISON COMPANY ) Docket No. 50-289

) (Restart-Management Phase)

(Three Mile Island Nuclear }

' Station, Unit.1) )

THREE MILE ISLAND ALERT'S SUPPLEMENTAL RESPONSE TO LICENSEE'S FIRST SET OF INTERROGATORIES Interrogatory Nos. T-4 and T-5 (a) 12323-2328; 2335-2347.

(b) Inspection Report 50-289,-84-05, which identified

" weaknesses" at p. 4-5; Notice of Violation dated July 22, 1983,

p. 3.

(c) No disciplinary action was taken voluntarily or in

-some cases:at all, by Licensee against the following individuals for conduct described. in the following paragraphs:

Special Master Report 2d PID Robert C. Arnold 1237 John Herbein 1233 2306

. Gary Miller 1220-237 2272-2320 -

Jim Floyd 1220-237 2272-2320 Michael Ross 1137-178 Henry Shipman 194-110- 2139-2146 Charles Husted 1101-111 2148-2168 Mr.'I 124 Mr. A 124 Mr. P 1107-108 Mr. V 1112-132 Mr. GG 182-93 2133-2137

• Mr. G 126-77 2096-2121 Mr. H 126-77 2096-2121 Mr. MM 182-93

• September 18, 1984 letter from Deborah B. Bauser to the Appeal Board, with attached memorandum to file from H.D. Hukill.

8409260283 840924 gDRADOCK 05000289 PDR

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l Interrogatory No. T-7 (a) i These pages ,,are referenced in the OARP Special Report at Fages 10-12.

Interrogatory Nos. T-14 and T-15(a) l 1

(1) .12 - ALAB-772, p. 71, note 56.

(2)- 13~- ALAB-772, p. 71, note 56, in light of the OARP Special Report, pp. 45; 75, 11; 76, 16.

(3) 14 - ALAB-772, p. 71, note 56.

(4) 110.- ALAB-772, p. 71, note 56.

-Interrogatory No. T-19(a)

(1) The quality of instruction:

Milhollin Report, 1126-77, 241-248, 251; ASLB PID 12324; 2334-2347.

(2) The quality of instructors:

Milhollin Report, 1126-77; 101-111, 241-248; ASBL PID 12148-2168; 2334-2347.

(3) Poor training department management integrity and attitudes:

Milhollin Report, 194-111, 183, 316-317, 137-178.

ASLB PID 111138-2163, 2324, 2396, 2401-2403, 2407, 2411-2412.

1s_t ASLB PID - 1110 NUREG-0680, Supp. 5 at 11-8.

ALAB 772 at p. 71, note 56.

(4) Poor integrity and attitude of overall licensee management:

Milhollin Report, 1338 NUREG-0680, Supp. 5, Table 3.1.

t. )

O TMIA's Response to Licensee's Interrogatories T-4 and T-5, paragraph 9.

(5) Management's failure to adequately respond to training problems:

Milhollin Report 1184-237, 250-254, 332-335.

ASLB PID - 12252, 2246, 2270, 2306-2307, 2318-2319, 2323-2328, 2331, 2411-2412.

I NUREG-06 80, ' Supp. 5 at 7-1 to 7-11.

Special Report at 130, 169.

ALAB-772 at 63, 64, 70, note 54, 71, 72, 75.

(6) Lack of integrity by the overall operations staff:

Milhollin Report at 18, 137-178,94-110, 24, 107-108, 112-132, 82-93, 338. .

ASLB PID - 12110, 2065, 2135, 2119, 2139-21d6, 2133-2137.

(7) Lack of respect for training by operators, training instructors, and training department personnel:

Milhollin Report, 119, 220-237, 248, 322-331, 338.

ASLB PID 12325-2328, 2416, 2396-2407, 2411-2412.

ALAB 772, at 64 and 75.

And citations listed in subsections 1, 2, 3, 4 above.

In addition, each criticism listed in Interrogatory 67 of TMIA's Second Set of Interrogatories to Licensee, except subsections (x), (aa) and (bb) , as cited in the RHR Report, and each criticism listed in Interrogatory 70 at TMIA's Second Set of Interrogatories to Licensee, at the pages cited therein.

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Interrogatory No. T-19(b)

WhileLthe Special Master considered it to be the Licensing A

. Board's duty to develop specific recommendations regarding the tultimate' restart decision, and presumably whatever license condi-

.tionsishould-be. imposed to allow restart -(see, Milhollin Report at '1343) , , he . recognized that his~ conclusions would have " potential for determining the ultimate issues before the Licensing Board."

~ Iji . To the extent the Special Master's conclusions influenced tJus Licensing Board's decision to impose license conditions (PID,' ' 12347) , .these can ' be - found .at Milhollin, 1251.

Interrogatory No. T-25 i . (1) ' Stiff sanctions for drug abuse -- RHR at: II Explanatory E . Material, Motivation ~(Disciplinary Sanctions for Violating Regulations).

(2) Double standard for-disciplinary practices -- RHR at:

. II, Explanatory Material, gotivation (Disciplinary Sanc-tions for Violating Regulations).

(3) Insufficient supply of trainees - .RHR at: .II Explanatory

. Material, Supply of Trainees.

Interrogatory No.-T-29

The'RHR and BETA reports.

Interrogatory Nos . T- 30 TMIA has relied upon the foilowing portions of the

.Special_ Report in formulating its response to Interrogatory T-29: l l

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-5.

9: 1 (1)

SpecialfReport at 1-3.

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'(2)- Id. at?3-4,:71-73 (understanding of individuals who c'h eated derives -from GPUN -management) ; 81. (uncritical accept-ance.of management. memoranda); 84- 86.

See also, Special. Report at 67 (GPU Nuclear has removed all

~

individuals to whom NRC . Boards lor . Commission raised objections) ;:

19 (best way;to' evaluate training programnis to lool. at steps GPU l

has taken'to develop: training program).  !

'(3). Id.' at 7 (confidenceLin innovative approach has been fulfilled and justified); 7-8 -(cheating of operators different

'than for professionals); . 10 (steps.taken by GPU in response to .

'first OARP Report sufficient to solve problems); 16' (Committee not privyito:information about assignments and promotions within GPU: Nuclear-and therefore does not consider whether discipline appropriately taken and/or current management-of-Training Depart .

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t 4 -ment ~ appropriately assigned);_25-27'(security measures will prevent-

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cheating, rather than'a-program which commands respect by opera-tors); 28-37, (implementing the recommendations made by10ARP Review Committee in June, 1980-would resolve.the, problems found by the Appeal LBoard, -the ASLB and Judge _ Milhollin, although these problems had'not even been detected.by the OARP Review Committee in June, 3

1980); 44-45 (no indication that new programs rely less on memori-

zation:oriemploy different teaching methods); 45 (no' indication -

~that management audits without operator confidence in integrity ,

of manag ment sufficient to cure lack of integrity in' training

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o program); 46 (no answerf to ' ALAB concern that operators' skills deteriorating from lack of use); 46 (premise in last paragraph

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that high morale bf operators is demonstrated by low turnover where decisions and other audits indicate other indicators / evidence of morale problems); 47 (answer to ALAB concern about numerous

_ violations of operating procedures was that in narrow sense the

. violations were not attributable to improper / inadequate training);

47-48-(no support for statement that management totally supports 4

operators, when evidence cited in decisions indicates the reverse) ;

48-49 (no indication of basis / methodology for Kelly evaluation, in light of criticism formerly of GPU evaluation of exams) ; 48-49 (no indication of basis / evidence to support statement that program no longer overly emphasizes memorization); 52 (failed to answer adequately NRC Staff criticism that some operators needed additional training to improve operational skills which. declined during prolonged shutdown) ; 53-54 (no analysis of how program will resolve important problem that memorization previously stressed in training program); 55-57 (no analysis of serious question of whether or not format of GPU and NRC exams are adequate to test operators' skills) ;

65-68 (Review Committee appears to de-emphasize the importance of the cheating incidents by stating that cheating can be motivated by good intentions; does not state the root cause for the cheating; demonstrates no understanding of the particular individuals who were found to have participated in the cheating incidents; offers no guidance regarding appropriate discipline against these individuals; answers the Appcal Board's question by repeating its opinion that GPU training program has made " extra-ordinary progress": suggests that Special Master acted imprudently

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by making judgments.about witnesses' credibility on the basis of their demeanor; and suggests that GPU has taken the cheating incidents and related NRC decisions too seriously); 69 (Dr.

Gardner fails to answer question about how cheating incidents, if known prior to 1980 opinion, would have influenced that opinion);

70-71 (Dr. Gardner's answers to questions posed on these pages indicate .that he does not believe operators' adherence to regula-tions and procedures and integrity are necessarily important in-dependent of whether or not they possess the skills necessary to operate the reactor safely) ; 72-73 (Committee could not answer ALAB question because little. time available and did-not speak with operators or monitor classes; reviewed only materials s.

prepared by GPU Nuclear); 73-74 (Committee refuses to answer

! ALAB question because subject to pending enforcement action; Committee appears to take its responsibilities to evaluate program 1

less seriously than GPU's best interest with regard to enforcement action); 75-79 ~(Committee largely relies on management's repre-sentations to determine whether or not adequate communication b'etween top management and operational staff; indicates it does not' take finding seriously that operators feel there exists a lack of communication which creates poor operator attitude).

(4) Id. at 7-8; 65-68; 70 (Gardner's primary concern is evaluation of- operator skills; shows little concern for operator integrity) ; 72.(little appreciation' demonstrated of importance .

of. adequate discipline; no understanding of participation by

- specific individuals in cheating incidents) . ,

(5) Id. at 72-73 (little time to speak to operators or monitor classes); 20-21 (indicates only review of paper program) .

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>. -(6) See TMIA response to subpart (2) above.

TMIA also believes that the Reconstituted OARP Review Commit-tee ' evaluation of the training program varies radically from the l

evaluation of'the program which are drawn in the BETA and RHR Reports. By comparison, it is obvious that if the Review Commit-

. tee' did not find the same problems it did not address these criticisms and problems.

(7) Special Report at 25-27. This portion of the report appears to conclude that security procedures will solve the cheating. problems detected in the past. It does not analyze and/or examine whether poor operator attitudes were responsible for cheating and whether structural problems and lack of manage-ment. attention and integrity fostered these problems, as indicated in the relevant NRC decisions. See also Special Report at 46 and 80 regarding operator attitudes.

(8) jgg. at 28-41. The Review Committee states;that GPU has implemented most of the Review Committee recommendations but does-not examine that implementation to determine if in fact the -

underlying problems have been resolved. The BETA and RHR Reports indicate that even though corrective actions recommended by the Review Committee have been taken, the program is still inadequate to resolve the-underlying problems.

(9) See citations listed'in TMIA's Response to Licensee's First Set of Interrogatories and TMIA response to subpart (3) above.

(10). See citations in TMIA's Response to Licensee's First Set of Interrogatories; id. at 53-54 (no analysis of whether new program will resolve problems concerning memorization method of teaching); 55-57 (no analysis of whether current format of GPU

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. and NRC exams adequate to test operators' skills) ; 65-69 (no analysis of root cause of cheating); 75-79 Ono analysis of com-munication betweq'n management and operators) .

'(11) See citations in TMIA's Response to Licensee's First I

Set of Interrogatories; id at 20; 44-45, 72-73 (Review Committee's l

limited time and failure to speak to operators or monitor classes adequately);

l (12) See citations in TMIA's Response to Licensee's First Set of Interrogatories.

(13) See citations in TMIA's Pesponse to Licensee's First Set of Interrogatories.

(14) Id. at 75-81; 72-73.

(15) See TMIA response to subparts 6, 9, 10. Further, the purpose of the Report, apparently to convince the Commission to permit restart prior to a decision on the merits on the training issue, indicates GPU's orientation to solve only those problems it is required by the NRC.to address and its lack of appreciation of the necessity to develop the capacity itself to identify problems. Id. at 3.

Respectfully submitted, O'3L W.G SIM Joanne Doroshow The Christic Institute 1324 North Capitol Washington, D.C. 20002 (202) 797-8106 A.M wb Ly(ne Bernabei vhrnment Accountability Project 5 Connecticut Ave. N.W.

l hington, D.C. 20036 l (202) 232-8550 DATED: September 24, 1984 Attorneys for Three Mile Island Alert

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