ML20136H270

Intervenor Exhibit I-TMIA-4,consisting of 820830 Interofc Memo Discussing Response Effort to ASLB 820727 Partial Initial Decision Re Exam & Testing Processes & Exam Cheating Incident

ML20136H270
Person / Time
Site:	Three Mile Island
Issue date:	01/02/1985
From:	Long R GENERAL PUBLIC UTILITIES CORP.
To:	Arnold R GENERAL PUBLIC UTILITIES CORP.
References
SP-I-TMIA-004, SP-I-TMIA-4, NUDOCS 8508200245
Download: ML20136H270 (7)

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hrtP.fY l k CORPORATE CONFIDENTIAL 1 Date August 30, 1982

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U v.w MUC Ger Suelect Lessons Learned from ASLB PID of July 27, 1982 To A d A M 4 President '85 FtosliioUMdquarters

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I. INTRODUCTION 6RAhCH The response of the Training & Education Department to thu cheating in-cident began ismediately in July and August, 1981 when the extent of the problem was revealed. Much of the initial response was focused upon the the " mechanics" of Training & Education Department examination and testing processes, since these were clearly found to be too loose and casual.

Formalization of these processes and development of administrative pro-cedures to handle employee misconduct were the primary issues addressed in my testimony before the ASLB Special Master. In this memorandum I will discuss broader issues which come from both a review of the AS!Js PID of July 27, 1982 and my ongoi'ng experience within GPU Nuclear during the past year.

II. ISSUES A. Training and Corporate Credibility Much of the discussion in both the report of the Special Master and the ASLB Partial Initial Decision reveals that employees lack confi-dence in the training process as well as in the various levels of GPUN management. I believe that this concern goes well beyond simply training issues. Employees may also lack confidence in plant procedures, administrative guidelines, corporatu policius, and management direction.

When this lack of confidence exists we can expect to see many types of misconduct, including such things as failure to follow procedures, de-liberato ignoring of administrativu practicus and guidelinus, casual implementation of management directives, and the willingness to take shortcuts wherever they seem to be convenient.

It also appears that employees are not certain that GPUN management is truly concerned and supportive of them in their efforts to comply with the training and operational / administrative requirements imposed upon them. Thus, it is not surprising that employces may be unwilling to admit to their supervisors that they need help in preparing for a particular examination or that they have not been able to satisfactorily complete a particular surveillance procedure or plant evolution. They may feel it is easier to seek unauthorized assistance, or , shortcut the surveillance procedure while indicating on the records that it has been satisfactorily completed, or move right on through a plant evolution even though certain requirements have not been met exactly as specified.

Clearly we will be shortsighted if we- do not look carefully at our entiro corporate conduct of business and particularly the conduct of opurations in the power plants.

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August 30, 1982 Page two l B. Protection of the Integrity of Trainees and the Trainers Upon reflection it appears that one contributing factor to the multi-faceted problems revealed may be the confusion introduced in the training of operators by the fact that the licensed instructors perform in multiple roles. First of all they are trainees who had to receive the training and take the same mock exams and licensing exams administered by the NRC during the extensive retraining puriod following the TMI-2 accident. Second, they also were expected to perform as instructors for the larger number of operations personnel undergoing this retraining examination process; and third, they were expected to proctor and evaluate the progress of the trainees (basically including their own). We did not provide them any special guidance or insight into how to perform in this multiple role environ-Was there a ment nor how to determine which role was more important.

1 need to think through and verbalize the differences in performance depending on what role one was in? For example, when proctoring an

' exam did the instructor think like a student or like a proctor? The

' proctor had certain responsibilities to assure that students perform i

on their own and that the evaluation process demonstrate their true capabilities. However, since the proctor was himself a student, l might not both he and the students feel that they were in "the same

! boat" and that they should help each other get through this one more hurdle imposed upon them?

At the time that the NRC requalification examinations were given in April and October of 1981, there was a feeling on the part of both the trainers and the trainees that the written examination administered by the NRC was not a good measure of their ability to operate the plant.

i Thus the instructors were again placed in the difficult role of teaching material which they (as operators) were not necessarily convinced was really relevant to being an effective operator. This set of circum-stances was perhaps in a way unique to the TMI-1 situation, which was requiring all licensed personnel to be-relicensed. However, even in our ongoing programs the licensed instructors must perform on shift

! periodically, they must participate in an annual requalification program, and they must satisfactorily complete an annual requalification process.

j Although perhaps not with the same intensity as during the 1981 NRC re-certification exam process, this multiple role nature of our licensed operator instructors exists on an ongoing basis.

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August 30, 1982 Page three C. Empicyee Attitudes Although the new training facilities, increased instructional staff, an increased br eadth of training activities have sub-stantially improved our ability to deliver training, I believe we still have a long way to go in effecting employee attitudes towards.the entire nuclear power endeavor. This was certainly confirmed by the recent feedback we received from Drs. D' Arcy and Sauer of RHR, Inc. Employees may feel we have lost sight of our basic responsibility to produce electricity in a reliable and economic manner. The perceived new emphasis on procedures control, quality assurance, highly regimented and documented training, and frequent evaluations of all aspects of plant activities by outside age'ncies may indicate to them a concern with form rather than substance. There is clearly a need to find ways to effectively persuado our employees that our ru.-

sponsibility to the public and the industry demands an exceedingly

. high standard of conduct and an attitude towards performance of our work which is beyond reproach.

III. RESPONSE TO ISSUES ,

A. Restoring and Maintaining Credibility-i .There have been and are a number of activities underway directed towards this restoration and. maintenance of credibility for GPUN in the eyes of our employees. While I do not have any new ideas to suggest in this area, I believe that it is essential for all of us at all levels of management to continually demonstrate our commitment to creating a work environment in which issues are properly identified, addressed, and resolved.

B. Integrity of the Training Process The effort underway to review and revise the examination procedure, and to extend it:to use in a broader range of training activities (in-cluding some outside of the TEE Department) is part of the ongoing activity to assure the integrity of the training program. In addition, we will develop a better understanding of the multiple roles that are required of our licensed operator instructors. We will also look at l

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R. C. Arnold August 30, 1982 Page four this role issue in terms of our instructors in other areas. Specific guidance will be developed for the licensed operator instructors to help recognize and accept their responsibilities in the several roles.

They will also be helped to find ways to clarify these roles to their trainees. Thus, the trainees will understand that the instructor /

proctor relationship with them may require distinctly different be-havior from those which the licensed instructors exhibit when they are performing as licensed operators on shift, or as students in thei r ru-qualification training programs.

We need to continue to develop our capability to produce reliable, valid test instruments. Dr. Eric Gardner, Professor Emeritus of Educational '

Psychology, Syracuse University, has suggested the use of a table of specifications for each examination. The table would basically be a matrix which has a list of the topics to be covered on the examination, compared with identification of the types of behavior required to ef-factively demonstrate mastering of those topic areas. Specific test items or questions are placed in the appropriate position in the matrix.

Completion of such a table allows you to make a deliberate decision as to the percentage or fraction of exam which requires memorization, the fraction which requires analytical capability, the fraction which requires synthesis of ideas, and so on. Along with the ongoing activities of the T&E Department to explore test development techniques, this approach by Dr. Gardner will be considered.

The recent modifications to the content and administration of NRC

, licensing exams has resulted in better acceptance of the usefulness

of the licensing exam to evaluate opera' tor capabilities. We will continue to work with both instructors and trainees to make certain they understand and accept the vital importance of the steps in the i

licensing process. We will also continue to provide inputs to NRC and INPO to help further improve the licensing examination process.

Both in response to circumstances surrounding the PID, and the recent -

l- comparison by DDL of our instructor certification process with draf t l recommendations _being considered by INPO, we will take stups to tighten i . our process for certification of instructors in the T&E Department. As ismediate steps, we will require a practice lecture evaluated by the Training Department staff prior to placing any instructor into the classroom environment. We also will require the Manaque of Plant Training (or Corporatu Training) to. conduct an extensive inturview with each instructor prior to teaching of their first class. This ,

interview will be along the lines of the interviews of candidates for licensed operator positions which are conducted by the operating unit directors. The interview will explore instructor attitudes towards the instructional process, familiarity with the history and concerns I

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! o il R. C. Arnold August 30, 1982

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l raised by the PID, and their commitment to delivery of quality training. ,

The Director of Training & Education will conduct a follow-up interview

, during the first several months following the start of the instructor performance in the classroom.

These steps will begin immediately under a memorandum directive and will

! be formalized in the " criteria for qualifications of training instructors".

The criteria themselves will be developed by the end of 1982 through (a)

review of the draft "INPO Guidelines for Technical Instructor Qualifica-

, tion", (b) review of the DDL report recommendations, (c) review of our Instructor Training Program, and (d) consultation with our instructors and outsiders, as appropriate. .

4 In addition to the above, it should be noted that the Quality Assurance i

Department has been involved with many of the efforts directed to assuming the integrity of the training process. The T&E and QA Departments will continue this cooperative effort and will formalize practices where re-quired.

C. Training's Responsibility for Attitudes I have recognized from the beginning of my assignment as Director of Trainini; & Education the significant responsibility that T&E Department instructors have towards influencing attitudes of our employees. This has been a subject of discussion among the T&E staff from the earliest ,

formation of this group. We will initiate additional activities to clarify for all of our instructional staff their understanding and acceptance of their responsibility for significantly influencing our employees' attitudes. Our training centers should be models for quality performance. This includes such things as physical appearances classroom environments starting classes on time; and providing full measure of per-i formance in the classroom both in terms of time devoted to subject matter

! and the quality of delivery of that matter. We will develop ways to clearly define and establish the value of the licensed operator requali-fication process, as well as the cyclic training for all of our technical positions. The importance of the NRC operator examination as a step in the certification process for an individual to operate the power plant will be emphasized. The basic principles trainers for TMI and Oyster Creek will enhance our ability to develop an alert attitude on the part of employees with regards to readinuss to handle unusual circumstancus.

We will assure that these devices aru fully utilized and that the company's commitment to obtaining them is fully recognized by both trainees and trainers.

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s R. C. Arnold August 30, 1982 Page six IV. CONCLUSION Specific concerns and criticisms in the ASLB PID of July 27, 1982 have been identified and addressed as part of the T&E Nuclear Assurance Division, and GPUN Corporate response effort. In this memorandum, I have developed and identified responses to several broad issues, in-cluding GPUN training and corporate credibility, protection of the integrity of the trainees and the trainers, and employee attitudes.

It is clear that an ongoing, objective examination of the GPUN training and education activities is required to assure the development and maturing'of GPU Nuclear.

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- Robert L. Iong Vice President Nuclear Assurance RLL:kg cc: P. R. Clark i