ML20127L931
| ML20127L931 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 06/25/1985 |
| From: | Bradford L, Shohet G GOVERNMENT ACCOUNTABILITY PROJECT, THREE MILE ISLAND ALERT |
| To: | |
| References | |
| CON-#385-621 SP, NUDOCS 8507010001 | |
| Download: ML20127L931 (8) | |
Text
r UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board
'85 JUN 28 A10:51 In the Matter of
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Docket No. g g
]q[D METROPOLITAN EDISON COMPANY
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(Three Mile Island Nuclear
)
(RestartRomandb$
Station, Unit No. 1)
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Management)
TMIA'S RESPONSE TO LICENSEE'S PROPOSED EVALUATION PLAN I.
Preliminary Statement After business hours, on May 28, 1985, TMIA received a copy of Licensen's Proposed Evaluation Plan.
The following day the Commission ordered the restart of TMI-1, CLI-85-09.
Since that time TMIA counsel has been occupied with litigation in the Third Circuit Court of Appeals to enjoin the Commission's restart order. TMIA has nonetheless made a good-faith effort to comply with the Licensing Board's order asking for comments on the company's plan and has previded comments to Licensee in a timely manner.
On June 11 and June 14, 1985, TMIA participated in informal discussions with Licensee's counsel.
These written comments are substantially similar to those already provided orally to Licensee.
Finally, TMIA fully endorses the recommendations and com-ments made by the Union of Concerned Scientists ("UCS"), USC's Comments on Licensee's Plan for Post-Training Evaluation (June 17, 1985), and submits the following additional comments:
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Shift supervisors who perform training evaluations should be carefully trained and evaluated.
It is apparent from Licensee's May 28, 1985 Proposed Evalua-tion Plan, as revised June 17, 1985, that it intends to rely heavily on its shift supervisors to evaluate operators for train-ing-related deficiencies and identify necessary training program changes.
This evaluation is to be performed by supervisors for abnormal and potentially reportable events as well as routine on-the-job performance.
See Licensee's Proposed Evaluation Plan, (June 17, 1985) attachments 2, 4, and enclosure 7 to attachment 2
(" Licensee's Plan").
However, Licensee has not demonstrated that the shift supor-visors are capable of detecting training-related deficiencies.
According to Licensee, all TMI-l shift supervisors are previously qualified as senior reactor operators ("SRos").
The record indi-cates that SRos are given classes in decision analysis and a course that teaches supervisory skills (e.g., effective communi-cation, listening, employee performance, and delegation).
Addi-tionally, SRos participate in an on-the-job training program which consists of several shift foreman tasks including "admini-strative procedures" and " shift foreman duties."
Metropolitan Edison Co., LBP (May 3, 1985), slip. op., at 102-103, paro. 161-162; ff. Tr. 32, 409, at 12-13.
Although in all likelihood these training experiences assist shift supervisors in determining whether training deficiencies WTMIA received a copy of the revised plan on June 19, 1985.
All references to Licensee's Plan are to the version dated June 17, 1985. t
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exist, no specific education is provided that is designed to prepare shift supervisors for their role in evaluating training deficiencies.
TMIA recommends that Licensee modify its plan to train shift supervisors for the specific evaluation duties required of them.
Expert assistance is certainly available should the Licensing Board deem it necessary.
Further, UCS has offered to make its expert, Dr. James J. Regan, available to Licensee if raquested to do so.
Regardless of whether Licensee adopts this suggestion the company should nonetheless develop a plan to judge the perfor-mance of shift supervisors in training evaluation.
Licensee may be able to incorporate such a plan in its SRO on-the-job training program.
TMIA suggests, however, that this evaluation of shift supervisors be done outside the training program.
Additionally, the Supervisor of Licensed Operator Training, Operating Training Manager, and Manager of Plant Operations TMI-l should encourage feedback from the shift supervisors to identify ways to make supervisor evaluations more efficient and effective.
2.]The initial and requalification SRO training program description of Licensee's Plan Attachment 6, now includes a category concerning the SRO's ability to evaluate on-the-job performance of personnel.
Although the revision is an improvement it still does not guarantee that SROs will be taught to detect and report training-related deficiencies.
31 For example, the forms that are used to evaluate operators have some very broad categories.
See Licensee's Plan, attachments 5 and 6.
Supervisorr may have difficulty isolating specific deficiencies with an operator's performance using these forms.
Licensee should consider drafting narrower evaluation categories and reducing the time between operator evaluations to remedy this criticism.
Shift supervisors will undoubtedly have some useful insights and should be consulted. L
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2.
Operator evaluations should be performed more frequently and licenses should evaluate the performance of its shift supervisors on a requiar basis.
Under the proposed evaluation plan, shift supervisors will be able to reach general conclusions about operator performance i
and training at six-month intervals.
But in order to feedback
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specific information and recommendations into the training pro-gram, evaluations should be performed more frequently.
The problem noted supra at 3, n.3, with the evaluation form is exacerbated by a six month period between evaluations.
Supervisors should also keep a weekly log of events that bear on training using the same categories found on the forms.
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t In this way they can create a more accurate record of training-related deficiencies.
Licensee should poll its supervisors on a monthly basis to see what deficiencies have been identified and address any concerns that the supervisors identify.
During the l
t first year of operation, the company should reevaluate its train-j f
ing program every three months.
After the first year, a semi-annual reappraisal may be sufficient.
of course, Licensee should j
modify its training program to remedy deficiencies as soon as j
they are identified.
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I A/The proposed plan provides a a six-month evaluation period during the first year and only a yearly one thereafter.
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III.
Conclusion If the company adopts TMIA's suggestions listed above, the gap between the objective evaluation scheme urged by Ucs and THIA and Licensee's " subjective" approach would be narrowed.
At present, Licensee's proposed plan does not ensure that training-related deficiencies will be identified.'
Respectfully submitted, (h
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' Lynne Ber,naiei t
b George Shoh%t Government Accountability Project 1555 connecticut Avenue N.W.
Suite 202 Washington, D.C. 20036 (202) 232-8550 m,/
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Louise Bradford TMIA
' 1011 Green Street Harrisburg, PA 17102 (717) 233-3072 counsel for Three Mile Island Alert Dated:
June 25, 1985
4 UNITED STATRS OF AMERICA NUCLEAR REGULATORY COMMISSION DRdETED BEFORE Tile ATOMIC SAFETY AND LICENSING BOARD U3NSC In the Pktter of I
15 JJN 28 A10:51 3
METROPOLITAN EDISON COMPANY r
bfffCEOF$E(,HtTA--OCHETING &
(Three Mile Island Nuclear l
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I BRANCH Station, Unit No. 1)
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CERTIFICATE OF SERVICE I hereby certif y that copies of THI A's Respeace To I,1censeels 'Propoded Evaluation Plan in the above-captioned proceeding have been served on the parties identified in the attached Service I,ist by deposit in the United 5t tes mail, first class this 25th day of June, 1985
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~ V-A George Shohgh-0 6
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e UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 13 the Matter of 4
0-289 ce METROPOLITAN EDISON COMPANY (Restart Romand on (Three Mile Island Nuclear Management)
Station, Unit No. 1)
)
SERVICE LIST Administrative Judge Decketing and Service Section Gary J. Edles, Chairman Office of the Secretary Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Wa:hington, DC 20555 Administrative Judge Jack R. Goldberg, Esq.
J hn H.' Buck Office of the Executive Legal Dir.
Atomic Safety and Licensing Appeal Hoard U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 C :hington, DC 20555 Administrative Judge Deborah Bauser Christine N. Kohl Shaw, Pittman, Potts & Trowbridge Atomic Safety and Licensing Appeal Board 1800 M Street, NW, U.S. Nuclear Regulatory Commission Washington, DC 20036 Ccchington, DC'20555 Administrative Judge Mrs. Louise Bradford Iv:n W. Smith, Chairman TMI Alert Atomic Safety & Licensing Board 1011 Green Street U.S. Nuclear Regulatory Commission Harrisburg, Pa 17102 C:shington, DC 20535 Ad2inistrative Judge Joanne Doroshaw, Esq.
Sh31 don J. Wolfe The Christic Institute Atomic Safety & Licensing Board 1324 North Capitol Street U.S. Nuclear Regulatory Commission Washington, DC 20002 Washington, DC 20555 Administrative Judge Mr. & Mrs. Norman Aemodt Guttave A. Linanberger, Jr.
200 North Church Street Atomic Safety & Licensing Board Parkesburg, PA 19365 U.S. Nuclear Regulatory Commission W chington, DC 20555 Michael F. McBride, Esq.
LeBoeuf, Lamb, Leiby & McRae 1333 New Hampshire Ave., NW, #1100 Washington, DC 20036 m
e e,
Michael W. Maupin, Esq.
Ellyn R. Weiss, Esq.
Nunton & Williams 707 East Main Street 2001 S. Street,NW, !!uito 430 P.O. Box 1535 washingt n, DC 20009 Richmond, VA 23212 Thomas Y. Au, Esq.
Office of Chief Counsel Dept. of Environmental Resourses 5050 Executive Houses P.O. Box 2357
-Harrisburg, PA 17120 L
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