ML20112K034
| ML20112K034 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 04/05/1985 |
| From: | Bradford L THREE MILE ISLAND ALERT |
| To: | |
| References | |
| CON-#285-441 SP, NUDOCS 8504090307 | |
| Download: ML20112K034 (8) | |
Text
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April 5, 1985 t
E 5 ETED mt UNITED STATES OF AMERICA L
NUCLEAR REGULATORY COMMISSIO"
- E R -8 Pi2:32 BEFORE illE ATOMIC SAFETY AND LICENSING BOARD.,,
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in u-CCCKET M x 5ur;yj*
a.i A EH In the Matter of
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METROPOLITAN EDISON COMPANY
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Docket No. 50-289 SP
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(Restart Remand 6h' * ' '
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(Three Mile Island Nuclear
)
Management - Training)
Station, Unit No. 1
)
TMIA'S COMMENTS AND RESPONSE TO LICENSEE'S COMMENTS ON COMMISSION POLICY'bTATEMENT ON TRAINING AND QUALIFICATION OF NUCLEAR POWER PLANT PERSONNEL On March 14, 1985, the NRC issued a " Commission Policy Statement on Training and Qualification of Nuclear Power Plant Personnel,"
(Policy Statement).
On March.20, 1985, the Atomic Safety and Licensing Board issued, " Memorandum Inviting Cemments on Commission Policy Statement on Training and Qualificntiors of Nuclear Power
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Plant Personnel."
On March 28, 1985, Licensce filed Comments in response to the Policy Statement.
On March 28, 1985, the Board issued n' Memorandum-and Order in which it, on its own initiation, extended the time for parties other than Licensee, to file comments and re=ponses to Licensee's comments.until April 5, 1985.
This filing i
is in accordance with this April 5, 1985 order.
As. discussed more fully below, the five critoria c"tlined in the Commission's Policy Statement'at 3-4'and characterized by the 8504090307 850405 '
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NRC as being, "... elements essential to (an) acceptable training program," provide a helpful framework for evaluating the adequacy of a training program.
However, the Board must retain responsibility 1
for determining whether GPU's training program complies with those criteria.
The Board must,
... independently evaluate... Licensee's implementation of improvement programs to ensure that desired results are achieved."
Policy Statement at 1.
Indeed, the NRC can not relinquish responsibilities mandated to it by Congress to protect the public's health and safety.
With regard to this Licensee's training program, the Board has no alternative but to conclude, based on the record evidence, that the TMI training program does not meet the five criteria established in the Policy Stntement.
Licensee essentially admits its program does not comply with the fifth criteria and confuses it with criteria number four by narrowly construing the significance of criteria five.1 Furthermore, at the close of the record, Licensee had not I
completed its job-task analysis and therefore was not in compliance with criteria one.
The Board has asked the parties to consider what effect the Policy Statement should have on their partial initial decision.
The issue before the Board is the adequacy of Licensee's training program, and the five essential elements enumerated in the Policy Statement 1/
Criteria five addresses the evaluation of operators, 'in the job setting' as a measure of assessing the relationship of training to actual plant' performance of operators.
To the extent that GPU conducts this type of evaluation it is limited to operator. response and performance during identified emergency conditions (simulator training and in-plant drills).
This.failing is especially ironic for this utility, whose inability to detect and correct routine problems led to the 1979 accident at TMI-2. 1
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provide some helpful guidelines in this regard.
However, there appears to'be a fundamental flaw in the NRC's position that INPO accreditation will provide assurance of an acceptable training program.
This flaw is most obvious when reviewing the evidence in this proceeding.
The Policy Statement has set forth five elements which the Commission has decreed are essential to an acceptable training program.
These five elements constit'ute minimum standards by which to judge a train-ing program.
These standards have not been met at TMI.
Therefore, INPO's willingness to grant accreditation to the TMI training program despite the deficiencies of that program, demonstrates that the NRC's reliance on INPO's accreditation program is misplaced.
The fifth criteria adopted by the Commission in its Policy Statement provides the ultimate test of the adequacy of the training program.
Only by evaluating on-the-job performance can the NRC assess whether the training program has a realistic relationship to the performance of the operators and the plant.
There can be no substitution for this real-world evaluation, and the Commission appears, by its ordering of the essential elements to recognize this fact.
This ultimate evaluation must be desianed to measure the ability of operators to recognize and respond to seemingly insignificant initiating events which could lead to more serious events.
Licensee, in supplemental findings, argues that there is no 2/
In its comments, Licensee urges the Board to rely upon INPO's accreditation of the TMI training program as a basis for the Board's decision.
None of the.various INPO accreditation team reports are in evidence in this proceeding; they have not been subjected to the scr.itiny of cross-examination.
Despite Licensee's assertions to the contrary, it is the burden of Licensee to demonstrate that its training program is adequate. --
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need to evaluate operators as they perform seemingly routine day-to-day functions, and in its Comments on the Commission's Policy Statement, Licensee continues to deny the importance of evaluating routine 1
performance; and claims that in spite of this shortcoming in its 4
training program, criteria five has been met at TMI.
This claim is based on two false premises.
-First, Licensee confuses direct evaluation of the training program (criteria four) with evaluation of on-the-job performance.
Secondly, Licensee claims that because operators are tested at the simulator and during in-plant drills, the fifth criteria is met.
Licensee is flatly wrong in its interpretation of criteria five.
The in-training testing referenced in Licenses's Comments at 6-8 J
evaluate only how well operators have assimilated their training.
This type of evaluation does not test the ability of the training program to reflect actual conditions in the plant.
The simulator testing and in-plant drills test only the oper-ators' ability to respond to identified emergencies.
The operators' ability to recognize and respond to initiating events in an otherwise
' mundane' setting can only be tested by evaluation of the operators' day-to-day performance in the job setting.
This is particularly critical at TMI with its long history of poor performance and training.
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Conclusion The Board should utilize the criteria enumerated in the Policy-Statement at 3-4 when measuring the adequacy of Licensee's training program.
Based on those criteria, the Board must reach a conclusion that the TMI training program has not met the standard as.an acceptable
program; and further, that INPO's accreditation in the face of these weaknesses is deficient.
l Respectfully submitted,
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Louise Bradford For Three Mile Island Alert, Inc.
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'65 A?R -8 P12:32 NUCLEAR REGULATORY COMMISSION OFFICE..! 3E giU p,by BEFORE THE ATOMIC SAFETY AND LICENSING BONM5KEilNG A SERVICf.
BRANCH In the Matter of
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METROPOLITAN EDISON COMPANY
)
Docket No. 50-289 I
(Restart-Management Remand)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
CERTIFICATE OF SERVICE I hereby certify that copies of "TMIA'S Comments and Response to Licensee's Comments on Commission Policy Statement on Training n
and Qualification of Nuclear Power Plant Personnel" were served this 5th day of April, 1985, by service in the U.
S. Mail to the attached service-list.
t c. < *~%
^ct Louise ~Bradford TMI Alert, Inc.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter
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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 Appeal Board Thomas M. Roberts, Commissioner U.S. Nuclear Regulatory Commission 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 Appeal Washington, D.C.
20555 Board U.S. Nuclear Regulatory Commissica' 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 Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commissicn Washington, D.C.
20555 Washington, D.C.
20555 i
Administrative Judge.
sAdministrative Judge Gary J..Edles, Chairman Sheldon J. Wolfe Atomic Safety & Licensing Appeal Atomic Safety & Licensing Board Board U.S. Nuclear Regulatory.Commissicn U.S. Nuclear Regulatory Commission Washington, D.C.
20555
. Washington, D.C.
20555 i
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' Administrative' Judge Gustave A. Linenberger, Jr.
Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission
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Washington, D.C.
20555 Docketing and Service Section (3)
Office of the Secretary U.S. Nuclear Regulatory Ccmmission Washington, D.C.
20555 Atomic Safety & Licensing Board Panel U.S. Nuclear Regulatory Commission i
Washington,.D.C.
20555 Atomic Safety & Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission l
Washington, D.C.
20555 Jack R.
Goldberg, Esq. -
Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington,,0.C.
20555 Thomas Y. Au, Esq.
Office of Chief Counsel Department of Environmental Resources 505 Executive House P.O. Bcx 2357 Harrisburg, PA 17120 Ernest L Blake, Jr.
Shaw, Pittman, Potts & Trowbridge 1800 M Street N.W.
Washington, D.C.
20036 Lynne Bernabei, Esq.
Government Accountability Project
?.f55 Connecticut Avenue-Washington, D.C.
20036 Ellyn R. We'ss, Esq.
i Harr.on, Weiss & Jordan 2001 S Street, N.W., Suite 430 Wash.ington, D.C.
20003 l
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