ML20147E767

Forwards INPO Accreditation:Board Members Perspective, Presented at ANS 1984 Annual Meeting in New Orleans.Proposed Rule Should Contain Min Requirements to Avoid Discouraging INPO Initiatives

ML20147E767
Person / Time
Site:	05000000
Issue date:	09/24/1984
From:	Remick F AFFILIATION NOT ASSIGNED
To:	Thompson H Office of Nuclear Reactor Regulation
Shared Package
ML20147E666	List: ML20147E662 ML20147E681 ML20147E767 ML20147E897 ML20147E945 ML20147F032 ML20147F144 ML20147F390 ML20147F504 ML20147F630
References
FOIA-87-787 NUDOCS 8801210214
Download: ML20147E767 (11)

Text

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h mg 24 Septenber 1984 Mr. Hugh L. Thompson, Director Division of Human Factors Safety Office ef Nuclear Reactor Regulation U.S. Nuclear Reactor Regulation Washington, D.C. 20555

Dear Hugh:

Reference is made to your letter to me dated 17 September 1984 requesting my views on several matters relating to proposed NRC rulemaking for trainin and qualifications of civilian nuclear power plant personnel (SECY-84-76.

I wish to address the first paragraph of your letter wherein you indicate that "we have been told that you have indicated a belief that a rule is not necessary." I can think of only two occasions in which I have publicly discussed the proposed rulemaking and industry's concerr s. One of these occasions was in a paper entitled, "INPO Accreditation: A Board Member's Perspective," which I presented at the 1984 Annual Meetir 9 of the ANS in New Orleans in June 1984 (copy attached). Although I madi a modestly snide remark about the proposed rule (page 3), I did not take any position on whether a rule is necessary. The second occasion was in a letter to you dated 27 April 1984 responding to your request for coments (copy attached).

My third coment' was: "Whether the NRC position should be made through rulemaking or by policy statement, and whether one or the other is permitted or required by Section 306 of P.L.97-425 are matters that I am not prepared to address." My position remains unchanged on this point, as I beligve that a determination of what is required or necessary according to Section 306 is a legal question that should best be addressed by OELD, OGC and others.

However, putting aside the legal question of whether a rule is necessary, I do have some additional views on the question from a policy standpoint. In my penultimate coninent to you on 27 April I indicated:

In sumary, in light of what I sincerely belien =.re laudable utility industry initiatives for the inprovement of training, I recomend that at this time the Comission act in a manner which results in a minimum amount of requireinents, a limited amount of prescriptive guidance, a prudent amount of monitoring, and a maximum amount of encouragement for continued utility initiatives towards attaining quality in training and excellence in nuclear power plant operations.

The above coment was intended to be a pleading for promulgat5ng only minimum requirements through a rule, if a rule is legally necessary under Section 305. From a policy perspective, my position remains the same.

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Hugh L. Thompson 2 24 September 1984 The reasons I recommend minimum requirements in any rule that enight be found necessary under Section 306 are the following. INP0 and the nuclear utility industry are striving to attain quality in training that goes beyond meeting the minimum requirements of a prescriptive regulation. If the NRC comes along and codifies into requirements the voluntary commitments, it is argued that the nuclear utility industry support of INP0 would be destroyed.

Although I do not know if this would occur, it is a risk that I recommend strongly against taking. I have observed support for INPO accreditation grow over the past two years. Further, I have had occasion to personally ob-serve what this support has accomplished from the standpoint of utility commitments towards training facilities, training staffs and the quality of training programs; not only for licensed personnel, but also for other nuclear facility personnel. Rules and regulations would not have produced this sup-port or this commitment. To unwittingly destroy this support and comnitment would be regulatory foolhardiness. As I indicated to you on 27 April: "To destroy this initiative would set back training program improvements to pre-TMI-2 acci6ent days.'

You asked me also to provide comments on the various merits or problems underlying the three proposed versions contained in SECY 84-76A and SECY 84-76B (Alternatives I and II). Because of a need to divert my time to prepare for providing testimony to Congress on the HEU/ LEU conversion question for non-power reactors, I will provide my comments on SECY 84-76A & B at a later date.

Sincerely yours, d

For est J. Remick East Hamilton Avenue tate College, PA 16801 FJR:ge cc: R. F. Fraley, ACRS Z. T. Pate, INPO Attachments L

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.- IUP0 ACCREDITATION A BOARD MEMBER'S PERSPECTIVE 1984 ANNUAL MEETING THE AMERICAN NUCLEAR SOCIETY NEW ORLEANS, LOUIS!ANA JUNE 3-8, 1984 '

BY  ;

FORREST J. REMICK THE PENNSYLVANIA STATE UNIVERSITY i 1

. IN AUGUST 19'83, A MILESTONE WAS REACHED AT THE INSTITUTE OF NUCLEAR POWER OPERATIONS (INP0) WHEN THE FIRST UTILITY TRAINING PROGRAMS WERE ACCREDITED. .

. LICENSED OPERATOR TRAINING, NON-LICENSED OPERATOR TRAINING, LICENSED OPERATOR REQUALIFICATION TRAINING ANS SHIFT TECHNICAL, ADVISOR TRAIN-ING PROGRAMS WERE ACCREDITED FOR DUKE POWER COMPANY'S OCONEE NUCLEAR STATION.

. ACCREDITATION FOLLOWED IN JANUARY 1984 FOR THREE TRAINING PROGRAMS AT ARKANSAS POWER AND l!GHT COMPANY'S ARKANSAS NUCLEAR ONE AND FOR EIGHT TRAINING PROGRAMS AT IENNESSEE VALLEY AUTHORITY'S SEQUOYAH NUCLEAR PLANT.

l . AND IN MAY 1984 THREE TRAINING PROGRAMS WERE ACCREDITED AT CAROLINA l POWER AND l!GHT COMPANY'S H. B. ROBINSON STEAM ELECTRIC PLANT AND AT BALTIMORE GAS AND ELECTalC COMPANY'S CALVERT CLIFFS NUCLEAR POWER I PLANT.

. IHUS, 21 TRAINING PROGRAMS AT 5 PLANTS OR STATIONS HAVE BEEN ACCREDITED TO DATE, AND THE INP0 ACCREDITATION PROGRAM IS WELL UNDERWAY.

. THE INSTITUTE OF NUCLEAR POWER OPERATIONS WAS ESTABLISHED BY TH'-

NUCLEAR UTILITY INDUSTRY IN ORDER TO PURSUE AND ATTAIN QUALITY AND EXCELLENCE IN NUCLEAR POWER PLANT OPERATION.

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.'THE PURPOSE OF INP0'S ACCREDITATION PROGRAM IS TO ASSIST MEMBER UTILITIES, WHICH INCLUDES ALL U.S. NUCLEAR UTILITIES, IN DEVELOP!NG TRAINING PROGRAMS THAT WILL PROVIDE WELL-QUALIFIED, COMPETENT PERSONNEL WHO WILL OPERATE THEIR NUCLEAR POWER PLANTS WITH QUALITY AND EXCELLENCE.

. INP0 HAS ESTABLISHED CRITERIA FOR:

. . IRAINING PROGRAMS PROGRAM CONTENT TRAINEE EVALUATION AND QUAL 1rlCATION METHODS

. . IRAINING PROCESS ORGANIZATION AND ADMINISTRATION RESOURCES AND FACILITIES PROGRAM DEVELOPMENT AND IMPLEMENTATION

. . IRAINING STAFF SIZE AND WORKuvAD QUALIFICATIONS '

DEVELO'PMENT AND EVALUATION

. IO OBTAIN ACCREDITATION, A UTItlTY MUST DEMONSTRATE ThAT ITS TRAINING MEETS THESE INP0 ACCREDITATION CRITERIA.

. INP0 ASSISTS ITS MEMBERS IN DEVELOPING TRAINING PROGRAMS WHICH ARE BASED ON A CLOSED-LOOP, SYSTEMATIC APPROACH AND WHICH WILL MEET THESE CRITERIA.

. THE PROGRAMS MUST BE PERFORMANCE-BASED. IHAT IS, THEY MUST BE BASED ON AN ANALYSIS OF THE JOBS, TASKS, SKILLS AND KNOWLEDGE REQUIRED FOR THE JOB POSITION THAT THE TRAINEE WILL OCCUPY.

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. IHE INP0 APPROACH AND CRITERIA ARE GENERALLY CONSISTENT WITH THE SYSTEMS APPROACH TO TRAINING (SAI) WHICH THE NUCLEAR REGULATORY COMMISSION IS CONSIDERING FOR PROMULGATION AS A MODIFICATION OF 10 CFR PART 50.

. HOWE ER, INP0 ACCREDITATION CURRENTLY INCLUDES TEN TRAINING PROGRAMS, WHEREAS EARLY DRAFTS OF THE NRC PROPOSED RULE INCLUDED TRAINING PROG'AMS d FO'R THE TWENTY-FIVE JOB POSITIONS LISTED IN APPENDIX B 0F ANSI /ANS-3.1--1981.

. THE NRC PROPOSED RULE INCLUDED ESSENTIALLY ALL PERSONNEL AT A NUCLEAR POWER PLANT EXCEPT CLERICAL AND JANITORIAL POSITIONS.

. THE TEN TRAINING PROGRAMS CURRENTLY COVERED BY INPO INCLUDE:

.. OPERATIONS AREA NON-LICENSED OPERATORS l! CENSED OPERATORS LICENSED OPERATOR REQUALIFICATION-

.. MAINTENANCE AND IECHNICAL SUPPORT AREA SHIFT IECHNICAL ADvtSOR INSTRUMENT AND CONTROL IECHNICIAN ELECTRICAL MAINTENANCE PERSONNEL MECHANICAL MAINTENANCE PERSONNEL CHEMISTRY IECHNICIAN RADIOLOGICAL PROTECTION TECHNICIAN

, MANAGER AND IECHNICAL STAFF

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. I INDICATED THAT TO BE ACCREDITED, TRAINING PROGRAMS MUST BE BASED ON A SYSTEMATIC APPROACH. IN GENERAL, THIS MEANS THAT THEY MUST CONTAIN THE FOLLOWING ESSENTIAL INGREDIENTSI

.. A SYSTEMATIC ANALYSIS OF JOBS TO DETERMINE WHAT TASKS THE PERFORMER OF THE JOB MUST BE ABLE TO PERFORM.

.. PERFORMANCE-BASED LEARNING OBJECTIVES DERIVED FROM THE ANALYSIS

i. IRAINING DESIGNED, DEVELOPED AND IMPLEMENTED TO ACHIEVE THE PERFORMANCE-BASED OBJECTIVES.

.. EVALUATION OF TRAINEES CONDUCTED DURING TRAINING. SUCH EVALUATION SHOULD BE MADE AGAINST PERFORMANCE STANDARDS STATED IN THE LEARNING OBJECTIVES.

.. EVALUATION OF THE EFFECTIVENESS OF THE TRAINING PROGRAM.

SUCH EVALUATION SHOULD INCLUDE PROVISIONS FOR REVISION BASED ON TRAINEES' DEMONSTRATED ABILITY TO PERFORM IN ACTUAL JOB SETTING.

IRAINING SYSTEM MANAGEMENT MODELS THAT GENERALLY CONTAIN THESE INGREDIENTS INCLUDE INSTRUCTIONAL SYSTEM DEVELOPMENT (ISD), TRAINING

SYSTEM DEVELOPMENT (TSD), CRITERION REFERENCED INSTRUCTION (CRI), THE NRC'S PROPOSED SYSTEMS APPROACH TO TRAINING (SAT), ETC.

. INP0'S ACCREDITATION PROCESS HAS THREE MAJOR PARTS:

.. ACCREDITATION SELF-EVALUATION 4

CONDUCTED BY THE UTILITY RESULTS IN SELF-EVALUATION REPORT (SER)

. . ACCREDITATION IEAM EVALUATION CONDUCTED BY INP0 AND PEER EVALUATORS RESULTS IN ACCREDITATION REPORT

.. ACCREDITATION DECISION BY ACCREDITING BOARD s

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. IHE MEMBERSHIP OF THE ACCREDIT!NG BOARD CONSISTS OF FIVE MEMBERS AS FOLLOWS:

.. TWO MEMBERS FROM INP0 MEMBER UTILITIES BILLY R. CLEMENTS, VICE PRESIDENT, NUCLEAR, TEXAS UTILITIES GENERATING COMPANY CORDELL REED, VICE PRESIDENT, COMMONWEALTH EDISON COMPANY, CHAIRMAN OF THE ACCREDITING BOARD '

.. ONE MEMBER FROM A NON-NUCLEAR, INDUSTRIAL IRAINING ORGANIZATION JOHN E. CARROLL, UNITED AIRLINES (RET.)

.. ONE MEMBER FROM THE POST-SECONDARY EDUCATION COMMUNITY RUSSELL R. O'NEILL, DEAN OF ENGINEERING AND APPLIED SCIENCE (RET.), UNIVERSITY OF CALIFORNIA AT LOS ANGELES

.. ONE MEMBER RECOMMENDED BY THE NRC FORREST J. REMICK, ASSISTANT VICE PRESIDENT FOR l RESEARCH AND GRADUATE STUDIES, IHE PENNSYLVANIA STATE UNIVERSITY 4

. IN ADDITION, EACH ACCREDITING BOARD MEMBER HAS AN ALTERNATE. IHE ALTERNATE MEMBERS IN THE SAME ORDER ARE:

. . DENNIS E. GILBERTS, SENIOR VICE PRESIDENT, NORTHERN STATES POWER COMPANY SAMUEL J. TUTHILL, SENIOR VICE PRESIDENT, IOWA ELECTRIC LIGHT AND POWER COMPANY .

.. CHARLES J. SENER, ASSISTANT VICE PRESIDENT, BELL -

COMMUNICATIONS RESEARCH, INC. '

.. WILLIAM R. KIMEL, DEAN, COLLEGE OF ENGINEERING, UNIVERSITY OF MISSOURI-COLUMBIA l

.. GORDON E. ROBINSON, ASSOCIATE PROFESSOR OF NUCLEAR ENGINEERING, IHE PENNSYLVANIA STATE UNIVERSITY

. WHEN ACCREDITATION IS AWARDED, THE ACCREDITATION WILL NORMALL REMAIN QN EFFECT FOR FOUR YEARS, WITH A REPORT SUBMITTED TO THE INP0 ACCREDITING BOARD FOR APPROVAL AT THE END OF TWO YEARS.

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'. IT IS MY VIEW THAT IF A UTILITY IS TO REAP THE POTENTIAL FULL BENEFITS OF THE ACCREDITATION PROCESS, IT MUST MAKE IT ABUNDANTLY CLEAR AT THE ONSET THAT:

,, EXCELLENCE IN NUCLEAR POWER PLANT OPERATION IS THE GOAL OF THE UTILITY. .

.. EXCELLENCE WILL BE ATTAINED THROUGH THE QUALITY OF PLANT OPERATION PERSONNEL AND THROUGH.THE QUALITY OF THEIR TRAINING.

.. THE ACCREDITATION PROCESF WILL BE UTILIZED FULLY TO DEVELOP AND EVALUATE THE QUALITY OF THE TRAINING PROGRAMS.

.. A CONSCIENTIOUS, THOROUGH, OPEN AND HONEST SELF-EVALUATION WILL BE MADE OF THE QUALITY OF THE TRAINING PROGRAMS AND HOW WELL THEY MEET THE INP0 CRITERIA.

.. THE SELF-EVALUATION REPORT WILL TELL IT AS IT IS.

. . WEAKNESSES OR SHORTCOMINGS WILL BE ADDRESSED AND CORRECTIVE ACTION WILL BE INITIATED 'AMEDIATELY.

. I BELIEVE THAT IF WELL DONE, SELF-EVALUATION IS THE MOST IMPORTANT PART OF THE ACCREDITATION PROCESS.

. HOWEVER, TO BE WELL DONE, SOME OF THE MOST VALUABLE PLANT OPERATIONS PERSONNEL MUST BE A PART OF THE SELF-EVALUATION TEAM. IHE TEAM SHOULD NOT CONSIST SOLELY OF TRAINING PERSONNEL.

. FURTHER, THE SELF-EVALUATION TEAM MUST BE TOUGH; THEY MUST BE TOUGHER THAN AN NRC INSPECTOR, TOUGHER THAN AN INPO EVALUATOR.

. A WELL-DONE SELF-EVALUATION WILL REQUIRE A MAJOR EFFORT. HOWEVER, THE GREATER THE EFFORT REQUIRED, THE MORE IT IS PROBABLY NEEDED.

. AS PART OF THE SELF-EVALUATION, IT IS IMPORTANT'THAT IN-DEPTH QUESTIONS BE ADDRESSED. A DESCRIPTION OF WHAT IS BE!NG DONE BY WHOM TO WHOM IS FAR FROM BEING ADEQUATE.

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'.buESTIONSSHOULDINCLUDE:

.. WHAT IS THE TRA!NING PROGRAM SPECIFICALLY ATTEMPTING TO ACCOMPLISH 7

.. IHAT IS, WHAT KNOWLEDGE AND SKILLS MUST PLANT PERSONNEL POSSESS TO PERFORM ' 9 TASKS OF THEIR JOB 7 i

.. IS THE TRAINING PROGRAM EFFECTIVELY DESIGNED TO ENABLE i PLANT PE.RSONNEL TO ACQUIRE THE KNOWLEDGE AND SKILLS 7  ;

. WHAT ARE THE HONEST STRENGTHS AND SUCCESSES OF THE TRAINING PROGRAMS 7 IHESE SHOULD BE ENUMERATED. l

.. WHAT ARE THE WEAKNESSES, LIMITATIONS AND INADEQUACIES 7 l

-(E.G., DO THE RESULTS OF THE TRAINING PROGRAM MEET THE  !

TRUE DESIRES OF THE TRAINING STAFF AND THE OPERATIONS i STAFF 7 ARE THEY TRULY SATISFIED WITH THE PRODUCT 7)

IF NOT, OPENLY ADMIT IT. HOWEVER, CORRECTIVE ACTION I

SHOULD BE UNDERTAKEN IMMEDI ATELY. ONE SHOULD NOT WA!T FOR INP0 TO POINT OUT THE INADEQUACIES.

. .. WHAT WOULD IT TAKE TO RAISE THE PROGRAM TO ONE OF EXCELLENCE 7 j

. A COMPETENT SELF-EVALVATION TEAM CAN PROVIDE BETTER IN-DEPTH INSIGHT j INTO THE QUALITY OF THE TRAINING PROGRAMS THAN OTHERS WILL BE ABLE >

I TO DO.

I l . FURTHER, IF THE SELF-EVALUATION TEAM ACCURATELY ASSESSES THE

) STRENGTHS AND WEAKNESSES OF THE TRAIN!HG PROGRAMS, IT WILL BE

, MOSTLY THEIR IDEAS AND RECOMMENDATIONS THAT WILL LEAD THE WAY TO EXCELLENCE--IN CONTRAST TO RECOMMENDATIONS IMPOSED BY l OUTSIDERS OR BY TOP MANAGEMENT.  !

! . IHE lilP0 ACCREDITATION TEAM VISIT WILL PROVIDE AN INDEPENDENT i

CHECK ON THE THOROUGHNESS OF THE SELF-EVALVATION, AND WILL PROVIDE i AN -!NDEPENDENT COMPARISON OF HOW THE TRAINING PROGRAMS MEET THE INP0 CRITERI A AND STACK UP WITH THE STATE OF THE ART.

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. IHE INP0 EVALUATION TEAM WILL BE COMPOSED OF PEERS FROM OTHER UTILITIES AS WELL AS PROFESSIONAL INP0 EVALUATION TEAM MEMBERS. i THE TEAM MAY INCLUDE FROM TIME TO TIME AN ACCREDITING BOARD MEMBER <

OR AN NRC OBSERVER. INCIDENTALLY, SERVING AS AN INP0 PEER EVALUATOR CAN BE AN EXCELLENT OPPORTUNITY TO PREPARE FOR ONE'S OWN ACCREDITATION SELF-EVALUATION.

. I BELIEVE THAT WALT COAKLEY WILL BE DISCUSSING SOME OF THE TRAINING WEAKNESS $S IDENTIFIED BY THE INP0 ACCREDITATION TEAMS. WITHOUT STEALING HIS THUNDER, THERE ARE SEVERAL OBSERVATIONS l'D LIKE TO MAKE FROM THE PERSPECTIVE OF A BOARD MEMBER:

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.. I STRONGLY BELIEVE THAT THE PURSUIT AND ATTAINMENT OF EXCELLENCE IN OPERATIONS IS ABSOLUTELY DEPENDENT ON THE QUALITY OF PLANT PERSONNEL AND ON THE QUALITY OF THEIR TRAINING.

. . IHEREFORE, ACCREDITATION, WHICH I BELIEVE CAN HELP ATTAIN QUALITY IN TRAINING, MAY BE ONE OF THE MOST -

IMPORTANT PROGRAMS CURRENTLY IN PROGRESS AT INP0.

.. I SINCERELY BELIEVE THAT THE ACCREDITATION PROCESS HAS AND IS LEADING TO SIGNIFICANT IMPROVEMEN'TS IN THE QUALITY OF TRAINING. IT IS A TREMENDOUS UNDERTAKING AND IS COSTLY. HOWEVER, IT IS MY IMPRESSION THAT THOSE INVOLVED AGREE THAT IT IS LEADING TO THE IMPROVEMENT OF QUALITY IN TRAINING PROGRAMS.

. . IO BE ACCREDITED, TRA!NING PROGRAMS MUST BE SYSTEMATICALLY DESIGNED AND IMPLEMENTED AND MUST BE PERFORMANCE-BASED.

--MY OBSERVATION: MANY TRAINING PROGRAMS ARE SYSTEMATICALLY DESIGNED, BUT WHEN IT COMES TO SYSTEMATIC IMPLEMENTATION, I

THE RECORD IS MUCH MORE SPOTTY.

.. IHIS SYSTEMATIC APPROACH AND PERFORMANCE-BASED TRAINING MUST INCLUDE THE IN-PLANT, ON-THE-JOB PORTION OF THE '

TRAINING AS WELL AS THE TRAINING CONDUCTED AT THE TRAINING CENTER.

--MY OBSERVATION: IN-PLANT, ON-THE-JOB TRAINING IS LESS l s, SYSTEMATIC AND LESS PERFORMANCE-BASED.

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j PERFORMANCE-BASED TRAINING THAT IS SYSTEMATICALLY APPROAC MUST EXTEND TO INCLUDE MAINTENANCE AND KEY CRAFT PERSONNEL.

--MY OBSERVATION: THERE IS STILL MUCH TO BE DONE IN THE AREA 0F TRAINING PROGRAMS FOR MAINTENANCE AND CRAFT  !

PERSONNEL. '

.. IRAINING AND PLANT OPERATIONS CANNOT BE VIEWED AS COMPLETELY SEPARATE FUNCTIONS. IRAINING CANNOT BE LOOKED AT BY PLANT f

OPERATIONS PERSONNEL AS SOMEONE ELSE S RESPONSIBILITY.

TRAINING MUST BE THE JOINT RESPONSIBILITY OF BOTH OPERATIONS j- AND TRAINING PERSONNEL.

.. IOP-NOT'HC OPERATIONS PERSONNEL, INCLUDING LICENSED PERSONNEL, SHOULD BE ENCOURAGED TO ROTATE IN AND OUT OF TRAINING.

q --MY OBSERVATION: SUCHROTAYIONISSOMETIMESDISCOURAGED, NOT CONSIDERED IMPORTANT OR RESULTS IN APPRECIABLE PAY RFDUCTION. POLICIES SHOULD BE DEVELOPED TO ENCOURAGE

6UCH ROTATION.

..'IHE EVALUATION OF TRAINING PROGRAM EFFECTIVENESS MUST BE ROUTINELY AND SYSTEMATICALLY PERFORMED. IHIS EVALUATION l CLOSES THE LOOP OF THE TRAINING PROCESS.

--MY OBSERVATION: MORE ATTENTION MUST BE DIRECTED TOWARDS IMPROVING THIS EVALUATION.

. THE SELF-EVALUATION MUST BE DONE THOROUGHLY, CONSCIENTIOUSLY,  ;

AND PROFESSIONALLY. THE REPORT SHOULD TELL IT AS IT IS.

IF DONE OTHERWISE, ONE ONLY KIDS ONESELF.

. IF A UTILITY HAS DONE A THOROUGH. JOB 0F SELF-EVALUATION, THERE SHOULD BE FEW SURPRISES FOLLOWING THE INP0 ACCREDITATION TEAM VISIT AND UPON l

RECEIPT OF THE' ACCREDITATION REPORT. -

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. FURTHER, IF THE TRAINING PROGRAMS GENERALLY MEET THE INP0 CRITERIA,

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AND IF THE WEAKNESSES AND SHORTCOMINGS HAVE BEEN THOROUGHLY ADDRESSED  !

l WITH EFFECTIVE CORRECTIVE ACTIONS, ACCREDITATION BY THE ACCREDITING '

f BOARD SHOULD BE FORTHCOMING. '

! . MORE IMPORTANTLY, THE INDUSTRY GOAL OF ATTAINING QUALITY AND EXCELLENCE i IN NUCLEAR POWER PLANT OPERATION SHOULD BE MORE READILY ACHIEVED.

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