ML20100H491

Responds to ASLB 850320 Memorandum Inviting Comments on NRC Final Policy Statement on Training & Qualification of Nuclear Power Plant Personnel.Statement Not Relevant to Proceeding.Inpo Evaluations Not Prima Facie Evidence

ML20100H491
Person / Time
Site:	Three Mile Island
Issue date:	04/05/1985
From:	Au T PENNSYLVANIA, COMMONWEALTH OF
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20100H489	List: ML20100H487 ML20100H491
References
SP, NUDOCS 8504090202
Download: ML20100H491 (2)

Text

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April 4,-1985-

. r E LNITED STAIES OF AbERICA'  !

? NUCIEAR REGULATORY CGHISSIN l 1

BEEME THE ATGfIC SAFEIY AND LI NSING BOARD 9>?,[s7 I In the Matter of:

PEI'RTCLIIAM EDISW CGlPANY, -)

'85 IM-3 All 34 "

Docket No. 50 '

)

E ~(Three Mlle Island Nuclear ) . (Restart Remed i Station, Utit No. 1) ) Management - Tr i

h CQtGWEALTH OF PENNSYLVANIA'S RESPWSE TO ' '

} THE BOARD'S PEMORANDlM OF MARCH 20, 1985 r -

i Q1 March 20, 1985, the Atcmic Safety and Licensink Board issued a ,

i ~

Manormidian inviting ccanents on the Ccumission's Final Policy Statement j

f on Training and Qualification of Nuclear Power Plant Personnel.

I j- The Cannxmwealth of Pennsylvania does not believe that the Cam-mission's Final Policy Statanent has any direct relevance to this l proceeding. In the Policy Statement, the NRC considers five elements-as .

- " essential" to acceptable training prograns. Among the five elements

? . i L listed is: " evaluation and revision of the training based on performaice l

of trained personnel in the job setting." Apparently, concern for the  !

l.

j perfonnance of trained personnel in the job setting was a basis for the

[ Board's March 13, 1985 directive to the parties to consent on the proposed -

} findings by the thian of Calcerned Scientists. Q1 March 22, 1985, the

).

Ccananwealth conmented in response to the Board's directive.

~

l I After exanination of the' Ccumission's Final Policy Statenent, the .

f' Qananwealth does not believe that the Policy Statement is relevant to 1 this pr M ng. The Policy Statenent does not address the. def.ciencies L <

in the training progran identified in AIAB-772. Q1 its face, tlm Policy i

} Statenent does not preclude Licensing Board' inquiry into the adequac;' of -

j; 1 w training prograns. .' The Policy Statement states:

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a "It remains the continuing responsibility of the NRC to independently evaluate applicants' and licensecs' inplementation of improvement prograns to ensure that desire results are achieved. (at 1)

(h March 28, 1985, Licensee filed cmments to the Ccenission's Final Policy Stat ment, urging the Board to consider the INPO accreditation of Licensee's training progra as " prima facie evidence" of the adequacy of the training progr a (at 4).

The INPO evaluation of the TMI-l training progre was not a part of the case presented by Licensee. The INPO reports were never introduced into evidence by the Licensee. The testimony of the OARP Feview Cmmittee indicated that the Cmmittee did not attempt to duplicate the effort of the INP0_ accreditation te m or to audit the training progr e. The kmitteewasnotpreparedtotestifyabouttheINPOevaluations. (Tr.

32024-25; 32044-48) The parties had no opportunity to test the bases of -

any INPO finding or conclusion by questioning the authors of the IIFO evaluations. Moreover, the INPO evaluations were not used by the Licensee to specifically address any of the deficiencies identified by the Appeal Board in AIAB-772. The Licensee cannot rely on a docus nt not introduced into evidence as its prima facie evidence.

l For these reasons, the Cmmonwealth believes the Cmmission's Policy Statement is not relevant to the training issues in this proceeding.

i Respectfully submitted, l Y ,88

'nKNAS Y. AU /

Assistant Counsel i

Cmmomealth of Pennsylvania 505 Executive House, P.O. Box 2357 Harrisburg, Pennsylvania 17120 (717) 787-7060 Date: April 4, 1985

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