ML20099H844
| ML20099H844 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/15/1985 |
| From: | Bauser D GENERAL PUBLIC UTILITIES CORP., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | |
| References | |
| CON-#185-112 SP, NUDOCS 8503190510 | |
| Download: ML20099H844 (19) | |
Text
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CCuETEC USNEC March 15, 1985 15 MA718 P3:40 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION CFFICE 0 SECPGARv 00CXETING & SERVICf.
BRANCH BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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-METROPOLITAN EDISON COMPANY
)
Docket No. 50-289 3P
)
(Restart Remand on
)
Management - Training)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
LICENSEE'S SUPPLEMENTAL PROPOSED FINDINGS OF FACT IN RESPONSE TO THE PROPOSED FINDINGS OF UCS (11 283-287)
In accordance with the understanding reached by the Li-censing Board and the parties during a telephone conference call on March 13, 1985, Licensee hereby files supplemental pro-posed findings of fact which respond to paragraphs 283 through 287 of Union of Concerned Scientists Proposed Findings of Fact and Conclusions of Law on the Issue of Licensed Operator Training at TMI-1 ("UCS Findings").
UCS argues in these paragraphs that, because Licensee does not utilize periodic, formal on-the-job evaluations, it is not possible to conclude that training of control room operators at TMI-1 is accomplishing its intended purpose.
As described in detail below, Licensee belieses that UCS' position is incorrect because UCS misperceives the important elements of the reactor operator's job which require evaluation, and fails to account for the performance-based training system in place at TMI.
s The job of the reactor operator.
While Licensee does not disagree with UCS' premise that the relationship of training to the operator's job performance is very close 1/ and, conse-quently, that monitoring operational performance will provide "the only reliable means" of measuring the effectiveness of training, UCS Findings, V 282, Licensee does disagree with UCS' interpretation of " job performance" and " monitoring operational performance" as it relates to the position of reactor operator.
Licensee further disagrees with UCS' contention that Licensee does not assess the operational performance of its reactor op-erators.
UCS is narrowly defining job performance as the rou-tine skills required in the day-to-day operation of the power plant and, therefore, defines monitoring operational perfor-mance as formally monitoring these routine skills.
Licensee disagrees with these definitions.
In fact, the operator must be capable of responding appro-priately to an extremely wido range of scenarios and events --
scenarios and events for which he must be trained.
- See, e.g.,
Licensee's Findings, 11 137-144 (discussion of scope of requalification training program); cf. 10 C.F.R. 55 55.21-55.23.
This mastery involves the ability to respond properly as a member of a team, as well as the capability to individually perform well under numerous scenarios, both 1/
In our Reply Findings of March 6, 1985, Licensee noted the absence of record support provided by UCS for this proposition an defined by UCS and the lack of qualifications of Dr. Regan, who in fact addressed this question, to comment on the issue.
Soo Licensee's Reply Findings, March 6, 1985, at 8 n.8.
recognizable and unanticipated.
- See, e.g.,
Licensee's Find-ings, 1 141 (discussion of skills training portion of requalification program, designed to enhance individual and team performance).2/
This wide range of capabilities that the operator must be capable of demonstrating contrasts sharply with the daily, monthly, and even annual routine of an opera-tor, which fairly could be characterized as mundane. 3/
Rou-tino on-the-job performance consisting mainly of administrative and monitoring functions does not closely correlate with the bulk of operator training.4/
To be a competent operator, mas-tory of multiple knowledges, skills, and abilition is neces-sary.
It is this mastery -- not simply, or even primarily, offective routine performance -- which qualifies the operator 2/
The complexity of the job of the reactor operator and the importance of training operators to master the necessary skills, knowledges and abilities to perform this job has been a recurront theme in not only the management portion of the restart procooding, but in the design phase, as well.
- See, e.g.,
LDP-81-59, 14 H.R.C.
1211, 1231 (11 625, 744-746) (dis-cussion of importance of training and use of procedures in feed-and-blood cooling modo (UCS Contention 1), and in operator interforence with safety system operation (UCS Contention 10).)
3/
In the original 1980 OARP Report, in the context of human factors, the Committee obnorved that 'ono problem with many high technologies is that the job of the operator is reduced to that of being primarily a monitor,
- s. monitor who may suddenly have to assume greatly increased responsibility should there be, for examplo, equipment failuro."
OARP Report, Licenseo Ex.
27 at 87; cf. Duke Power Co. (William B. McGuiro Nuclear Sta-tion, Unita 1 and 2), LBP-81-13, 13 N.R.C.
652, 665 (" Stress levels in operators of nuclear plants are generally low.
").
4/
This may be why operators sometimes comment that training does not address what they regularly do.
See UCS Tr. Exh. 6 (RHR Report), question 132; Licensee's Findings, V 221 n.74.
Much of it doesn't.
I to run the plant.5/
The direct consequence of this disparity between the oper-l ator's routine and the job's potential demands is that periodic l'
evaluations of the reactor operator (RO) on the job would not add meaningfully to the information Licensee does gather to as-sess whether the operator is a good operator; i.e.,
whether the individual has the range and composite of skills, knowledges and abilities that are required for the job.
See discussion infra concerning purposo and content of Licensee's performance-based training system; see also Tr. 33,421 (Ross).
l In short, routine on-the-job performance evaluations are not reasonable or even legitimate indicia of required operator per-formance and hence, would not provide a meaningful measure of l
the effectiveness of training.
Compare UCS' Findings, 11 282-283 with discussion infra.
Measuring performance.
Licensee agrees with UCS that measuring performance is an extremely important part of 5/
Dr. Regan's testimony specifically focuses on the differ-ence between measuring job performance of a job that is simple and routine (e.g.,
keypunch operator, golf club production line worker), in contrast to a job that requires skills that are not elicited fully except in an emergency.
Regan, ff. Tr. 33,532, at 9, 13.
In the former instance, job output -- e.g.,
" number of keypunches per unit of time" -- constitutes an effective performance measurement.
Id. at 9.
Dr. Regan characterizes the latter instance, such as the job of a reactor operator or a pilot, as "some of the most difficult performance to evaluate."
Id. at 9.
Dr. Regan maintains, however, that there are a num-6er of performance measurements, "one or more" of which could be used to evaluate the effectiveness of training.
These in-clude job knowledge tests, simulation, and walk-throughs.
Id.
at 9-14.
As discussed below and in greater detail in Licens-ee's initial findings, these indicia are among the performance measurements used by Licensee at TMI.
.4
ensuring the effectiveness of training.
UCS Findings, VV 282-283; see, e.g.,
Licensee's Findings, 1 193.6/
- However, because daily on-the-job performance is not an effective barom-eter of training effectiveness, other, direct measures of op-orator performance requirements must be taken.
As discussed in the following paragraphs, if required job performance is mea-sured and is satisfactory, training can gain confidence that it is teaching operators what they need to know.
From such infor-mation, training also can determine where improvements or changes in the program are necessary or appropriate.
The record in this proceeding establishes that Licenseo does assess the TMI-1 operator training program against the required opera-tional perfo'rmance of individuals and crews.2/
Accurately assessing and then measuring required perfor-mance is the very essence of performance-based training.
Performanco-based training mandatos the development and implo-montation of a training program that is based on the 6/
UCS describen Dr. Regan's " fundamental promino" as the principio that "tho training program must be assosaed against operational performance of individuals and systems."
UCS Find-ings, V 44, citing Regan, ff. Tr. 33,532, at 9.
In UCS' words, l
Dr. Regan " considers this measuromont to be the only reliable means of measuring the effectiveness of training."
Id.
Tho question hero is, what does this operational performance really mean when the job in question is the job of the reactor opera-tor?
Soo n.5, supra.
2/
During the March 13 conforance call, UCS nuggested that until it was faced with the Board's concorn about UCS Findings, 11 283-287, Licensoo had not given any thought to measuring job performanco.
Soo also UCS Findingo, V 287.
To the contrary, evaluating operator performance han boon a key factor in the development of Licannoo'n performanco-based training nyatom.
- Sno, e.g.,
Licensee's Findings, 11 98-118 (use of TSD model in development of performance-based training).
performance requirements of the job.
- See, e.g., Licensee's Findings, 9V 101, 103, 114-116, 167-177.
In a performance-based training program, such as the program in place at TMI, training examinations themselves correlate with behavioral learning objectives, which in turn are generated on the basis of job performance requirements, which in turn are specified through the job / task analysis process.
See Licens-ee's Findings, 11 104, 183; see generally id, at VV 97-118.8/
Consequently, performance-based examinations effectively constitute job performance evaluations -- ovaluations of skills, abilition and knowledges required (although perhaps rarely, if ever, used) for the job.
See id. at 9 103-104, 108, 193-197.
At TMI-1, written tests (or performanco evalua-tions) are used to test conceptual and procedural knowledge, and knowledge of systems.
Soo id. at V 104; son also id. at 11 124, 146.
Orals examinations (using a tiered syntom of ad-ministration for roqualifying operators and using senior man-agement to examino now operators) toot concepto, procedures and systema at the control room panol, and test in-depth undor-standing of systems and procedure application throughout the plant.
Soo id. at VV 128, 147, 189-190.
Simulator usage and tonting provido the oporator with experience responding to accident and abnormal aconarios, an well an noconnary plant ovolutions, and allow operations and Training management to 8/
For examplo, each lecturo in the training program in based on a lennon plan which in prepared using the behavior learning objectivos developed for tho subject-mattor.
Liconson's Find-ings, 11 176, 183; Newton et al.,
ff. Tr. 32,409, at 17.
evaluate operator performance under these conditions.
See id.
at 11 73, 127, 141, 142, 175, 196, 218.
Moreover, team perfor-mance can be realistically annenned under the conditions of greatest importance, from a safety standpoint.
See id, at 11 196, 218; Committee, ff. Tr. 31,749, Special Report at 62.
During skilla training, which in an integral part of the roqualification program, operatorn aro evaluated by Operations management in their ability to respond effectively to abnormal plant manipulations, to properly conduct a broad range of plant evolutions, and to apply banin principles of reactor operations using the BPTS.
See Licenneo's Findings at 11 140, 44-47, 112; non also Newton et al.; ff. Tr. 32,409, at Attachmonto 4, 5 and 6.
In addition, operator traineen are meaningfully evaluated by supervisory Operations personnel (SROn) in specific requiro-monts of the job -- OJT chockoute tout the trainoa's familiari-ty with equipment and proceduren.
See id. at 11 125-126, 128, 134.
An a composito,.9/ those evaluations constituto a com-o plato and thorough job performance ovaluation for the job of 9/
The OARP Review Committoo focunod, with particular approv-al, on the multiplo, and continuoun ovaluations of operator performance on which Liconnoe relion.
Soo Liconnee's Findings, 11 309, 312
- non, e,c._,
Committoo, ff. Tr. 31,749, at 20, 20-29.
It should be notod, an woll, that the multiple ovalua-tionn of an operator's capability to perform his job are not conducted by the namo individual -- a factor which adds to the value of the composito picturo gained from those reviewn.
Cf.
Regan, ff. Tr. 33,532, at 12 (subjectivity in non-standardized ovaluations).
In fact, operators are required to be continu-ounty evaluated by all of the peoplo that logically might be able to contribute to an annonsmont of their performanco capa-bilition -- inntructorn, supervinora, Operations and Training management and nonior manaqomont (o.g., Mr. !!ukill).
Spo Liconnoo'n Findings, 11 120, 134, 140, 142, 147, 160, 103-194, 313..
the reactor operator. 10/
See Licensee's Findings, 1 109, 118.
Thus, UCS is incorrect that Licensee does not evaluate job performance; such ovaluations simply do not take the form which may be customary for losa complex jobs.
See n.5, supra.
Most of the capabilities encompanned by Licenseo's performance eval-untions, because of their abnormal and accident applications, are not reflected in the RO's routino job; nor would they be reflected in an on-the-job performanco evaluation.
- Instead, they are reflected in the operator's work at the simulator, in the clanaroom, and during drilla and oral examn.11/
- Moreover, all of those ovaluations are formal, i.e.,
required elements of the training program.
They certainly are not lacking in care,
" sketchy," or otherwise conducted in an unreliable manner.
Comparo UC3 Findings, 1 204.12/
In short, Liconnee comprohon-nively and formally evaluaton the performance required of its operators.
10/
The evidence ontablinhan that Liconneo maximizon opportunition that becomo available to uno on-the-job perfor-mance an a training experience, an a moann of measuring re-quired performance and an an indicator of training effectivo-nean.
Soo Liconnoo's Findings, 174,and Committoo, ff. Tt.
31,749, Special Report at 52 (une of restart roqualification card upon restart authorization).
11/
An important factor in Liconnon's training program, and one pornaps not fully ar prociated by Dr. Regan, in that TMI-1 operatorn are continuously in training.
Roqualification training thereforo providos constant rainforcomont of noc.nonry okilla, knowledges and abilition, indopondent of specitic weak-nonnon othorwino identified.
- Son, e.g.,
Liconnoo's Findings, 1 120.
12/
The existance of subjectivo olomonto in nomo of the ovalu-ation proconson unod by Liconnon was the subject of criticism by Dr. Rogan and UCS, and han boon addronned previously by Liconnoo.
Soo Liconnoo'n Findings, 11 192-194..
i Mr. Ross' understanding and use of performance evaluations.
UCS misunderstands and, in part, mischaracterizes the testimony of Mr. Ross on which UCS relies to indict Mr.
Roas' appreciation of job performance evaluations.
See UCS Findings, 11 284-286.
Mr. Ross' testimony simply echoes the view expressed above, namely, that evaluation of the control room operator while engaged in his normal routine will not be particularly informative vis-a-vis training.
As a preliminary matter, Mr. Rosa did not state that the reactor operator union contract prohibits written evaluations, comparo UCS Findings, 1 284, nor did ho cite the contract's limitations as anything other than essentially an historic rea-son why such on-the-job evaluations are completed annually for (non-union) SROs, 000, e.g.,
UCS Tr. Exh. 8 (evaluation of SRO, Mr. Olive) but are not formally done for Ros.
It was Mr. Ross' view that the union contract does not provide for the use of such ovaluations to make decisiono concerning a reactor opera-tor'n job status (e.g., disminaal), that there are adequate other methods available for annosaing job performance capabili-ties on which operators are trained, and that consequently, there has been no roanon to risk antagonizing the union by instituting such a procono.
Tr. 33,419-22 (Ross).13/
Licensee also disagrees with UCS' interpretation of Mr.
Ross' views about job performance ovaluations.
This is not 13/
Although Liconsoo does not believe routine, periodic on-the-job ovaluations are noconnary, should the Board consider it noconnary to require auch avaluations Licensco is not con-tractually barred from instituting them.
.g.
i surprising, given UCS' focus on on-the-job evaluations, such as UCS Training Exhibit 8, which would not reflect or correspond l
with most of the critical skills, knowledges and abilities re-quired of the reactor operator.
As Mr. Ross explained, these annual evaluations primarily tell you information about an individual's personality and work habits -- e.g., communication skills, attendance.
Tr. 33,420-21 (Ross); see UCS Tr. Exh. 8.
Mr. Ross does not believe that these evaluations would provide useful insights into the effectiveness of the training program.
Tr. 33,421 (Ross).14/
Mr. Ross' comments reflect the fact, previously stated, that the normal routine of an operator is very limited in contrast to the array of potential capabilities in which the operator must be competent.15/
Contrary to UCs' assertion, Mr. Ross' views do not reflect a lack of 14/
Mr. Ross noted that informal periodical assessments of an RO's on-the-job performance are done; the record also reflects Mr. Ross' intimate familiarity, and the daily familiarity of shift supervisors, who participate with the shift in training, with the operators they manage.
See Tr. 32,897, 32,562 (Ross);
Licensee's Findings, 11 137, 141 n.49, 142.
shared by UCS' placed by UCS in on-the-job evaluations is not 15/
The value expert, Dr. Regan.
To the contrary, Dr. Regan characterized evaluations by supervisors on-the-job as probably "the least reliable" way to evaluate training effectiveness.
Regan, ff. Tr. 33,532, at 12; see Licensee's Findings, 1 192.
In fact, Dr. Regan believes that, "In whatever form, ratings are not satisfactory as the only way of measuring job perfor-mance or as a primary means of doing so.
In particular, they are of little use in attempting to make a correlation between training, examination results, and on-the-job performance."
Id. at 12-13 (emphasis added).
Dr. Regan's concern is with the l
subjective nature of such evaluations.
He points to other more objective mechanisms -- job knowledge tests, walk-throughs, i
simulations -- as more reliable indicia of a training program's effectiveness.
Licensee agrees with Dr. Regan's position although, as previously explained, for reasons other than those articulated by Dr. Regan.
understanding or a " prefer (ence] to ignore" the value of job performance evaluations.
See UCS Findings, 286.
Assessing the relationship between training and job performance.
Licensee has described how its performance-based training process, which includes multiple evaluation methods, provides Licensee with the information it needs to evaluate job performance.
As described below, part of this process is effective communication to and assessment by Training of per-formance evaluation results.
In addition, there are a number of cther feedback mechanisms and communication avenues which provide additional assurance that operator training is compared with job performance and that modifications are made to the program, as' necessary, based on these comparisons.ls/
Written and oral examination results -- performance evalu-ations -- are systematically evaluated by Training in order to identify both generic deficiencies among the operators, and significant weaknesses in individual operators.
See Licensee's Findings, 11 190, 197; see also UCS Tr. Exhs. 9-16, concerning Licensee's follow-up on particular weaknesses of an operator (Mr. Olive); Licensee's Findings, SU 153-155 (concerning is/
Dr. Regan identifies the importance of feedback mechanisms from trainees to trainers.
Regan, ff. Tr. 33,532, at 21.
Dr.
Regan's view is shared by the OARP Review Committee.
See e.g.,
Committee, ff. Tr. 31,749, at 17-18.
Feedback mechanisms are an important and integral element of Licensee's performance-based training program.
- See, e.g., Licensee's Findings, VV 195-211, entitled Program Evaluation and Feedback; Newton et al.,
ff. Tr. 32,409, at 29 (The "[p]rimary emphasis has been on developing behavioral learning objectives to match job needs and on being responsive to meaningful feedback from trainees and user group supervisory / management personnel.").
follow-up on particular weaknesses of another operator, Mr.
Moore); id.,
11 156-164 (Mr. Olive);
see also Newton et al.,
ff. Tr. 32,409, at 32 (" program content also reflects individual needs that have been identified through the opera-tors, training and other management personnel."); id. at 45-46.
Simulator exam results -- also performance evaluations -- are formally submitted to Training by the senior managers who eval-uate operators at the simulator during requalification training.
- See, e.g.,
Licensee's Findings, 1 175, 218; Newton et al.,
ff. Tr. 32,409, at 47.
The topics presented in the Fundamental Review series of requalification training reflect the results of the annual exam and the performance of licensed personnel as evaluated by the Manager, Plant Operations and the Operations and Maintenance Director of TMI-1.
The depth of coverage in each topic. addresses deficiencies identified by the annual exam'as well as those identified by Operations.
Newton et al.,
ff. Tr. 32,409, at 15.
In short, performance evalua-tions of the crew and the individual are assessed, and compari-sons are made to the training curriculum and to operators' per-formance in the classroom.
Based on these comparisons, the training program may be modified.
Licensee's Findings, 1 197.17/
17/- For example, feedback from management evaluating simulator
. performance resulted in supplemental training using Licensee's LATOG procedures.
See Licensee's Findings, 11 175, 218; see also Committee, ff. Tr. 31,749, Special Report at 52; Newton et al.,
ff. Tr. 32,409, at 35.
There are a number of other mechanisms or checks and bal-ances in place which ensure that performance deficiencies are addressed sufficiently in the training program.
Perhaps the most fundamental of these mechanisms is the extensive in-volvement of Operations management, at all levels, and the op-erators themselves in the development, implementation and modi-fication of the program.la/
Operations approves the training program curriculum and the schedule for training.
Licensee's Findings, 11 74, 168; see generally id. at 167-177; Committee, ff. Tr. 31,749, at 23.
Operations reviews and comments on the behavioral learning objectives that are contained in the opera-tions Plant Manual (OPM); moreover, all sections of the OPM are formally assigned to plant operators and engineers in order to ensure that it is accurate and current.
Licensee's Findings, 11 74, 113, 176; Tr. 33,423-24 (Leonard).19/
At the completion of each week of requalification training, the shift foreman or supervisor from the crew in training meets with supervisory personnel from the next week's shift, as well as Training man-agement, to comment en the weak of training and suggest refine-ments to the program in the ensuing week (s).
Id.,
1 74; Com-mittee, ff. Tr. 31,749, at 23.
13/
For example, in developing the simulator training portion of requalification training, Operations works with Training to establish a list of topics for classroom training at the si-mulator as well as an outline for simulator drills.
The final.
program is approved by both Operations and Training.
Newton et al.,
ff. Tr. 32,409, at 20.
19/
Also, instructors submit proposed changes to the OPM as a result-of interface with the operators during the training week.
Tr. 33,426 (Leonard). _
.Another important mechanism in place to ensure training corresponds with necessary operator performance is the devotion of a portion of requalification training to selected operation-al events and reportable occurrences at TMI-1 and elsewhere in the industry.
Licensee's Findings, 1 144.
This training is derived using Licensee Event Reports, audit, evaluation, and inspection reports, publications and periodicals covering nu-clear industry information, and NSAC/INPO Significant Event Re-ports.
In this manner, training is conducted on specific, identified generic and site-specific operational performance weakneses.
Id.
'Furthermore, on an annual basis, Licensee conducts formal evaluations of its training programs.
In 1983, this evaluation was conducted by the Operator Training Review Team, a group of individuals (management and staff) from the Training and Opera-tions departments who were formally assigned to review operator training at TMI.
See id.,
11 74, 198.
As a result of this re-view, very specific suggestions were made and implemented to
. enhance the training program's effectiveness, i.e.,
the pro-gram's correlation with job performance requirements. fld.
Other communication avenues between Operations and Training provide additional assurance that the program is rele-
- vantiand effective.
For example, the Vice-President of TMI-1, Mr.'Hukill, meets annually with each operator.
Licensee's Findings, 1F 67.
Management interface meetings with crews are held.
See id. at T 70-71.
Mr. Ross and, at times, Mr. Hukill areLinvolved in the' development of individualized training programs designed to address weaknesses displayed by individual operators.
- See, e.g., UCS Tr. Exh. 10 (reflects Mr. Hukill and Mr. Ross's involvement in Mr. Olive's upgrade program).
Mr.
.Ross attends training and schedules his attendance so that he participates in training with different crews.
Newton et al.,
ff. Tr. 32,409, at 62.
Mr. Hukill also periodically attends training.
Id.,
Licensee's Findings, 1V 68, 73.
The close working relationship between Operations and Training is evi-dence of the effective line of communication between these two groups, which share the common goal of operator competency. 20/
Finally, a number of external audits of TMI-l have con-firmed Licensee's confidence in the effectiveness of its training program --
i.e.,
its correlation with required job performance.
These reviews include the NRC's Operational Read-iness Evaluation, which found that personnel, including opera-tors, were knowledgeable and well-trained.
See Licensee's Findings, 1 207; Newton et al.,
ff. Tr. 32,409, at 52-53.
Sim-ilarly, INPO has found TMI-l personnel well qualified.
Licens-ee's Findings, 1 202.
In fact, there are no facts -- and UCS presents none -- which suggest a contrary finding.
20/
In response to the fact that Operations is very involved in the training program, UCS faults Licensee for blurring the independence of these two organizations.
See UCS Findings, 11 148 (sic-166], 176.
Contrary to UCS suggestion, the close working relationship between Training and Operations in no way violates the QA concept of organizational independence, with separate management reporting chains and discrete responsibil-ities.
- See, e.g.,
LBP-81-32, 14 N.R.C. 381, 407 (Figure 3);
Licensee's Findings, 1 31.
In fact, the interface between Operations and Training was specifically noted with approval by the NRC in its 1984 SALP Report.
Newton et al.,
ff. Tr.
32,409, at 53.
3-l t
[
In summary, in order to decide whether Licensee appropri-(ately evaluates and measures operator job performance, the per-i-
formance of interest first must~be identified.
This perfor-
[
t
. mance is not-routine, on-the-job performance; it is required l
g operator performance.
Consequently, formal on-the-job evalua-tions would not~be particularly useful performance measure-ments.
The evidence presented in this case establishes that through the job / task' analysis process, Licensee has identified operator performance requirements, correlated the requirements with' operator training, and measured operator performance with l
I respect.to these requirements.
Performance-based training, j
[
which includes a composite-of evaluation processes, ensures i
t2unt operator performance of interest is the subject of appro-i priate training.
The effectiveness 1of the performance-based training system at TMI is further enhanced by the numerous
[
~
~ feedback mechanisms between Operations and Training.
- Moreover, periodic. internal and external checks on the effectiveness of the system substantiate-its effectiveness.
Respectfully submitted, I
bM k beit Ernest L.
- Blake, Jr.,
P.C.
Deborah B. Bauser 8
i SHAW, PITTMAN, POTTS & TROWBRIDGE 7
1800 M Street, N.W.
Washington,' D.C.
20036 l
(202) 822-1215-Counsel for Licensee l
i; Dated: -March 15, 1985 i
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DCLkETEE US C March 15e 1985
'85 FM 18 P3:40 UNITED STATES OF AMERICA
{FFICE S CPETA NUCLEAR REGULATORY COMMISSION BRANCH BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
- - ~ -
)
METROPOLITAN EDISON COMPANY
)
Docket No. 50-289
)
(Restart-Management Remand)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's Supplemental Proposed Findings of Fact in Response to the Proposed Findings of UCS (11 283-287)" were served this 15th day of March, 1985, by hand delivery to the parties identified with one asterisk, by Express Mail to the parties identified with two asterisks, and by deposit in the U.S. mail, first class, postage prepaid, to the other parties on the attached Service List.
Deborah B.
Bauser
l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION l
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l
P In the Matter
)
)
i METROPOLITAN EDISON COMPANY
)
Docket No. 50-289 SP
)
(Restart Romand on Management)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
SERVICE LIST Nunzio J.
Palladino, Chairman Administrative Judge U.S. Nuclear Regulatory Commission John H.
Buck Washington, D.C.
20555 Atomic Safety & Licensing Apped Board Thomas M.
Roberts, Commissioner U.S. Nuclear Regulatory Commist U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 Administrative Judge James K. Asselstine, Commissioner Christine N.
Kohl U.S. Nuclear Regulatory Commission Atomic Safety & Licensing Appet Washington, D.C.
20555 Board U.S. Nuclear Regulatory Commist Frederick Bernthal, Commissioner Washington, D.C.
20555 U.S. Nuclear Regulatory Commission Washington, D.C.
20555
- Administrative Judge Ivan W.
Smith, Chairman Lando W.
Zech Jr., Commissioner Atomic Safety & Licensing Boarq U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commisf Washington, D.C.
20555 Washington, D.C.
20555 l
Administrative Judge
- Administrative Judge Gary J. Edles, Chairman Sheldon J. Wolfe Atomic Safety & Licensing Appeal Atomic Safety & Licensing Boarg Board U.S. Nuclear Regulatory Commisl U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555
- Administrative Judge Mr. Henry D. Hukill Gustave A. Linenberger, Jr.
Vice President Atomic Safety & Licensing Board,
GPU Nuclear Corporation U.S. Nuclear Regulatory Commission P.O. Box 480 Washington, D.C.
20555 Middletown, PA 17057 Docketing and Service Section (3)
Mr. and Mrs. Norman Aamodt Office of the Secretary 200 North Church Street U.S. Nuclear Regulatory Commission Parkesburg, PA 19365 Washington, D.C.
20555
- Ms. Louise Bradford Atomic Safety & Licensing Board TMI ALERT Panel 1011 Green Street U.S. Nuclear Regulatory Commission Harrisburg, PA 17102 washington, D.C.
20555
- Joanne Doroshow, Esquire Atomic Safety & Licensing Appeal The Cnristic Institute Board Panel 1324 North Capitol Street U.S. Nuclear Regulatory Commission Washington, D.C.
20002 Washington, D.C.
20555 Lynne Bernabei, Esq.
O **r ment Accountability
- Jack R.
Goldberg, Esq. (4) r Office of the Executive Legal
,f55 Connecticut Avenue Washington, D.C.
20036 U.S c ear Regulatory Commission washington, D.C.
20555
- Ellyn R. Weiss, Esq.
Harmon, Weiss & Jordan
- Thomas Y.
Au, Esq.
2001 S Street, N.W.,
Suite 4 Office of Chief Counsel Washington, D.C.
20003 Capartment of Environmental Resources Michael F. McBride, Esq.
105 Executive House LeBoeuf, Lamb, Leiby & MacRT P.O. Box 2357 1333 New Hampshire Avenue, h ETrrisburg, PA 17120 Suite 1100 Washington, D.C.
20036 Michael W.
Maupin, Esq.
Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, VA 23212