ML20112E283
| ML20112E283 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/22/1985 |
| From: | Au T PENNSYLVANIA, COMMONWEALTH OF |
| To: | |
| Shared Package | |
| ML20112E266 | List: |
| References | |
| SP, NUDOCS 8503260480 | |
| Download: ML20112E283 (2) | |
Text
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WITED STATES OF MERICA NUCLIAR REGULA'IORY C@tRSSIW
- w iTEC BEFDRE THE ATWIC SAFEIY AND LICENSING BOARD UWC In the Matter of
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ETROPOLITAN EDISW CWPANY Docket No. 50-289-SP (Restart Rmand onrarf g.g g.
Managment - Training); 3 f. m yn (Three Mile Island Nuclear d' 0n Station, Unit No.~ 1)
CatDMEAL'IH OF PENNSYLVANIA'S SUPPIDENI'AL.
BRIEF IN RESPWSE TO 'IHE PROPOSED FINDINGS OF UCS (11 283-287)
On March 13, 1985, the At mic Safety and Licensing Board requested the views of the parties concerning the Union of Concerned Scientists Proposed Findings 11 283-287. After review of the Union of Concerned Scientists Proposed Findings and the Licensee's Supplemental Proposed Findings, the Cmmonwealth of Pennsylvania hereby files a supplemental brief to address the significance of UCS Proposed Findings 11 283-287.
Licensee adnits that it does not conduct formal on-the-job evaluations of control roan operator performance. Licensee characterizes the daily, monthly, and annual routines of the operators as " mundane" (Licensee Suppleental Proposed Findings, at 3), and therefore implies the activities are not worthy of evaluation.
By contrast, licensee
. points to the mastery of emplex skills that the operators nust acquire in the training program. The Licensee suggests that on-the-job evaluations would serve no useful purpose.
The Ocmnonwealth agrees that the development of cmplex skills is:
necessary to the training of a cmpetant operator.
Skills can be measured and evaluated in the training program. However, the evaluation of on-the-job performance is.also necessary to determine cmpetent day-to-day performance, a matter unrelated to the acquisition of knowledge or skills.
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The day-to-day tasks of the licensed operator are not as " mundane" as Licensee suggests. Routine activities, if perfonned incorrectly, can have far reaching effects. For exanple, one of the daily activities of the licensed operator is the perfonnance of reactor coolant leak rate tests. Failure ' the managenent to properly supervise and evaluate the operators' conduct of TMI-2 leak rate tests led to the indictment and conviction of Metropolitan Edison Co. in a criminal case (See Statement of the Prosecutor, Feb. 28,1984). Moreover, lack of attention to a mundane matter (whether a valve was open or closed) contributed signi-ficantly to the severity of the TMI-2 accident.
On-the-job evaluations check on a different aspect of operator perfonnance. Evaluations could detect deficiencies'in operator perfonnance, which sinulator e<ercises cannot discover. On-the-j ob evaluations at IME-1 could have detected the " lack of understanding concerning recordkeeping requirements" and the ignorance of a " loop seal" in the instnraentation system.
Inattention to these day-to-day probleus fonned the basis for the Appeal Board's renand in ALAB-772 (at 153). Because a procedure is routine or mundane does not mean that it is always properly implemented.
For these reasons, the Camonwealth of Pennsylvania believes that the lack of fonnal on-the-job evaluations of licensed operators is a significant finding, which nust be addressed by the Board.
Respectfully submitted, 7tl,1-< $ ~
TH WAS Y. AU
/
Assistant Counsel Comnonwealth of Pennsylvania 505 Executive House, P.O. Box 2357 Harrisburg, Pennsylvania 17120 Date: March 22, 1985 -...
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