ML20106G904
| ML20106G904 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 02/13/1985 |
| From: | Bauser D GENERAL PUBLIC UTILITIES CORP., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | |
| Shared Package | |
| ML20106G890 | List: |
| References | |
| SP, NUDOCS 8502150095 | |
| Download: ML20106G904 (254) | |
Text
.
b UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ,.. r-BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 35 FE314 /J0:42
'In the Matter of )
METROPOLITAN EDISON COMPANY ) Doc NoP5b1N89SP
) (Restart"Nemand on
) Management - Training)
(Three Mile Island Nuclear )
Station, Unit No. 1) )
LICENSEE'S PROPOSED FINDINGS OF FACT-AND: CONCLUSIONS OF LAW-ON THE ISSUE OF LICENSED OPERATOR TRAINING AT TMI-1 ,
Ernest L'.'Blake, Jr., P.C.
'Deborah B.-Bauser Wilbert Washington,:II John N. Nassikas, III
~
Counsel for Licensee
, February ~13, 1985'
>Te"N
-N ,N. .
8502150095 850213 DR ADOCK 0500028 y,
4 k.
) UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION t- -
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
'85 FEB 14 A10:43 In the Matter of ).
) LFf ICE _ ,:. ! ;. ,-
METROPOLITAN EDISON COMPANY ) DocNEEK o.j50/289fSP i
) (Restart Remand on
) Management - Training)
(Three Mile Island Nuclear )
Station, Unit No. 1) ,
)
i LICENSEE'S PROPOSED FINDINGS OF-FACT-AND CONCLUSIONS.0F-LAW ON THE. ISSUE OF LICENSED OPERATOR TRAINING AT TMI-1 L
I-
-Ernest:L. Blake, Jr., P.C.
Deborah B. Bauser-l Wilbert Washington,.II l John-N. Nassikas,.III.
[.
Counsel for Licensee f.
l" -February-13, 1985.'
, . r)
I ' .. f l -
L-' -
U
~
l j(~}. TABLE OF CONTENTS 1
- s_g .
Page
!I. Introduction and Background............................ 1-
! A. The Remand on Training............................ 1 I: B. . Participants inLthe Proceeding.................... 5 C. The Scope of the Proceeding....................... 11 II. - Proposed' Findings of Fact.............................. 16 A. Licensed Operator Training at TMI-1............... 16 l
- 1. Organization................................. 16 l
- a. . Key Management Personnel ............... 16
. b. Staff................................... 29
- 2. Training Facilities..........................'34:
- 3. Impact of Cheating........................... 46I L -a. Management Responsibility-for Cheating................................. 46
- b. Management Response to Cheating......... 52-m -
- 1. Communications..'................... 53 l 11. Exam Security..................... 1 62: --
' iii . ? Affected Individuals. . . . . . . . . . . . . . . 66 L s
- 4. The - Licensed ' Operator Training [ Program. . . . . . . 77-
- a. Methodology.............................-77~
- b. . Substance.............................. 91-u-.
- iii . Requal'ification Training. . . . . . . .' . . 104 g _1 -
_- f% - e - - . .
.?)--
, .s ,
m -
(} c. Training Processes..................... 126
- i. Program Development........ ...... 126 ii. Training Delivery................. 133 iii. Exam Administration............... 136 iv. Program Evaluation and Feedback... 146
- d. INPO Accreditation..................... 155
- e. Operator Attitudes Toward Program...... 158
- 5. Summary and Conclusions......................'167
- )B . The Reconstituted OARP Review Committee's Assessment of the TMI-1 Licensed Operator Training Program.. 168
- 1. The Reconstituted OARP Review Committee......~168
- 2. The Committee's Methodology....... ,........ 172
- a. Committee's Initial Review (May-June 1984)........................ 172,-
- b. Committee's Subsequent Assessment...... 183
- c. NRC Staff Recommended Methodology...... 198
- d. UCS (Dr.~~Regan) Recommended' Methodology.215
- e. Comparison of Methodologies............ 220
- 3. The Committee's-Findings.................... 226
~
- a. - Cheating............................... 226
- b. LTra,ining Resources..................... 229
- c. Programs and Procedures................ 233'
- d. . Communications......................... 245 -
- 4. Summary and Conclusions..................... 249-III. Conclusions of Law.................................... 251
-n.
-) L
- .- a
(~ g February 13, 1985
-q)
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter;of )
)
' METROPOLITAN EDISCN COMPANY ) Docket No. 50-289 SP
) (Restart Remand on
) Management - Training)
(Three Mile Island Nuclear )
Station, Unit No. 1) )
LICENSEE'S PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW ON THE ISSUE OF LICENSED OPERATOR TRAINING AT TMI-l~
I. Introduction'and Background A. The Remand on Training
- 1. In May, 1984, the Appeal Boaru remanded this proceed-
-ing to the Licensing Board for further hearings on three dis-crete management-related issues. Metropolitan Edison Co.
(Three Mile Island Nuclear Station, Units i), ALAB-772, 19-N.R.C. 1193-(1984). This partial initial ~ decision addresses
~.the remanded-issue of licensed operator training at Three, Mile
' Island, Unit 1 ("TMI-1").
- 2. In 1979,.theLCommission ordered'TMI-1 to remain shut sdown pending a hearing on a number of issues, including the=
2 g
M
\)
l-l u a
I management capability and technical resources of the Licens-
~]-
J.
ee.1/ CLI-79-8, 10 N.R.C. 141, 143 (1979); see also CLI-80~5, 11 N.R.C. 408 (1980). After an extensive hearing on management issues, including the substantive adequacy of the TMI-1 licensed operator training program, the Licensing Board issued a decision in August 1981 favorable to Licensee. LBP-81-32, 14 N.R.C. 381 (1981). Because of the contemporane'ous discovery of cheating on NRC licensed operator examinations, however, the-
" Board' retained jurisdiction of the case to consider the impact ,
of this new information on its findings and conclusions on Licensee's management competence. Id. at 403 (V 45). The Board subsequently reopened the management proceeding and ap-
. pointed a Special Master to hear evidence on the impact of the cheating incidents at TMI-1. . Further hearings' were conducted, culminating in a recommended decision by the Special Master and
.a. partial initial decision by the Licensing Board. See LBP-82-34B, 15 N.R.C. 918 (1982); LBP-82-56, 16 N.R.C. 281 (1982). The Licensing Board decision found there to have been
- a. breakdown in the-integrity of Licensee's training and testing 1/- Ih 1981, the operating license.for TMI-1 was transferred from-Metropolitan Edison-Company to'the newly formed General Public Utilities subsidiary,. GPU Nuclear Corporation.
CLI-81-17, 14 N.R.C.-299.(1981). .At the same time', the Commis-~
sion instructed the Licensing Board to. consider-the management competence of GPU Nuclear, rather than that of Metropolitan
-Edison, the original TMI-1. licensee. Iji .
f 4 h u
.- l
,,- -, - - ,e -
f -
program at TMI-1. LBP-82-56, supra, 16 N.R.C. at 300 (1 2082).
The Board imposed several conditions on restart directed at ob-taining future assurance of the adequacy of the training pro-gram. Id. at 365, 384 (11 2347, 2420). The Board also con-cluded, however, that the identified weaknesses in the program did not undermine the Board's earlier decisien favoring restart. Id. at 301 (1 2089).
- 3. In ALAB-772, the Appeal Board reviewed the entire record in the TMI-1 restart proceeding on the ability of GPU Nuclear Corporation's management to safely operate TMI-1.
ALAB-772, supra, 19 N.R.C. at 1201. The Appeal Board endorsed-the Licensing Board's_ characterization of the question which h'ad to be answered following.the cheating incidents at TMI-1, -
viz.,:"is the instruction adequate to prepare the operators to operate the plant safely?" Id. at 1232, citing LBP-82-56, supra, 16 N.R.C. at 363 (1 2343). The Appeal Board disagreed with the Board, however,.that this question could be satisfac-torily' resolved from the existent record. ALAB-772,' supra,119 N.R.C. at 1232-33. In the Appeal Board's mind,.the record in
. the reopened proceeding perhaps had raised more questions than
'it satisfactorily'had answered. Id._at 1233.
- 4. In particular, the. Appeal 1 Board was concerned about.
' the-fact that in the reopened proceeding, the Licensing Board:
,y
'? s
-V l -
.0
a A
- s I
.had not heard additional testimony from the panel of experts upon whom the Board had heavily relied in the first instance in approving the TMI-1 training programs. In 1980-81, these ex-
-perts, known as the OARP Review Committee,2/ had reviewed Licensee's training program and,-while recommendations for im-provement were made, the experts strongly endorsed the program.
See'ALAB-772 at 1210-11. In view of the significance of the testimony of the OARP Review Committee to the initial man-agement decision, the Appeal Board found the absence.of further testimony from-these experts during the reopened hearings on
~
cheating to constitute "a significant gap in the record." Id.
at 1234, 1237. Accordingly, the Appeal Board remanded the issue of the adequacy of the TMI-1 licensed operator training.
program-in order to obtain the views of the OARP Review Commit-tee cn1 this subject, given the occurrence.of cheating at TMI since the experts' earlier favorable teatimony.
32/ 'The OARP. Review Committee was a select Committee made,up of experts in thel fields of educational psychology (Dr. Eric Gardner), engineering / human factors-psychology (Dr.1Julien M.
.Christensen),-nuclear engineering education'(Dr. William R.
Kimel),. nuclear power-generation (Dr.' Robert E. Uhrig), and nu-
' clear power plant operator training (Mr. Richard J. Marzec).
TheiOARP Review Committee issued-a Report in 1980 that reviewed the Operator Accelerated Retraining Program ("OARP") conducted at TMI in 1979-1980. The OARP was a one-time intensive program-designed _to significantly improve licensed operator perfor-mance. See LBP-81-32,. supra,-14 N.R.C. at 451-53-(11 196-201).
- (~3
}~J:
L_
^4 l
>+ '
( 5. The Appeal Board: summarized its holding as follows:
The most significant issue requiring fur-ther1 hearing is training. Because the safe operation of the plant is so heavily depen-1 -
. dent upon the operators' skill,Lthe impor-tance.of training cannot be overstated. ,
~
The' cheating and related incidents called
-into, question the adequacy and integrity of licensee's entire training and testing pro-
+
gram. Although we have found that the re-opened record on the cheating itself was as -;
~ fully _ developed as possible, the impact of i j'; those findings on the Licensing Board's earlier conclusions on licensee's training i/6 program was not given the full considera-i tion it warrants. In particular, the Board
_a- should have sought further testimony,-in J ~
light.of the cheating incidents, from the .
OARP Review Committee, whose. views the F : Board previously found so persuasive.
f4 ALAB-772, supra, 19 N.R.C. at 1279. In short,,the Appeal Board' sconcluded thatLit was necessary to reopen the~ record on.Licens-e'e's management competence to determine'whether the OARP Review Committee' continued to endorse the TMI-1' licensed operator y
training program.
!D .
L B. - -Participants in the Proceeding-a Y _
- 6. .On June 28,- 1984, the Licensing BoardJpresided_over'a y, _prehearing-conference'!among the parties for.thelpurpo'e^of s U _ 'defininglthe issues'and'providing forTpreh'e'aring'proceduresjin- -
- the' proceeding remandediby tihe' Appeal / Board inIALAB-7.72. -Ati
-M -that-con'forence,-in-addition to. Licensee'and'the NRC,S'taff,.the i
- ? Commonwealth of Pennsylvania ("the commonwealth"), Three Mile ~
7 .
^
." +
^ u-
- ;s . '
s
'^'
L
-(~S Island Alert ("TMIA") and the Union of Concerned Scientists a ("UCS") were parties to the restart proceeding that expressed an interest in participating in the remand on training. Tr.
27,281-(Ccr.monwealth); 27,280 (TMIA); 27,280-81 (UCS).3/ A schedule was set for discovery and the commencement of the evi-dentiary hearings. See Memorandum and Order Following Prehearing Conference, July 9, 1984. Extensive discovery was
. pursued by the parties from July through November, 1984.4/ The evidentiary hearing began on December 19, 1984 and continued intermittently for 11 days, closing on January 18, 1985.
- 7. The Board encouraged and the intervenors agreed to utilize lead intervenors in the remanded proceeding. Tr.
f27,294 (Chai,rman Smith, Jordan); Memorandum and Order on Lead Intervenors, July 13, 1984. This arrangement was made with the understanding that no intervenor waived its right to pursue its separate interests where the lead intervenor did not fully 3/. The Aamodt Family, who had been active infthe prior liti-gation ofztraining, opted not to participate in this remand on licensed operator training. See Tr. 27,280, 27,292A-93 (Ms.
Aamodt).
4/. Licensee estimated that it. produced over 60,000 pages'of training-related documents in response to one set of discovery requests from TMIA and seven such requests from UCS, In addi -
tion, most of the witnesses were deposed, along with UCS-specified TMI-1 operators who participate in the training program, several other GPU Nuclear personnel, and several NRC-Region I inspectors. See Tr. 31,740 (Bauser) .
d
r; represent the others. However, intervenors were required to s,)
^
make good faith efforts to consolidate their case with the pre-sentation of the lead intervenor before proceeding indepen-dently. If these efforts failed, the intervenor could then seek leave of-the Board te proceed separately. See Board Memo-randum & Order on Lead Intervenors, July 13, 1984; seg generally 10 C.F.R. $ 2.714(e) and Part 2, App. A, 5 III(a)(4).
Of course, the benefit of such consolidation, from the interve-nor's standpoint, was that the lead intervenor bore the brunt of the discovery burden and other responsibilities of partici-pation. See Tr. 27,302 (Chairman Smith). In the remand on training, one of these responsibilities was to designate, on
.the date that prefiled testimony was due, exhibits a party intended to use in support of its case-in-chief. Memorandum and Order (Requiring Identification of Proposed Exhibits),
October 24, 1984.
- 8. The intervenors identified.the subject areas that ,
they were interested in pursuing within the rubric of training by specifying' issues of interest to them. UCS ident'ified two
' issues, which were modified and approved by the Board. These issues related to the substantive adequacy of training to pre-pare' operators to operate TMI-l safely.- Memorandum and Order on Lead'Intervenors, July 13, 1984 at 3; Memorandum and Order on Licensee's July 31,-1984 Comments on Lead Intervenors and Motion to Partially Exclude UCS From Management Phase, August k'_) -
1-e A r.
f k .
30,.1984 at 3-4; see also Tr. 31,736, 31,757 (Chairman
. Smith).5/ TMIA specified four s'ubissues of interest to it.6/
1..
' .e 5/ UCS' proposed subissues were:
(1) Are the operators equipped to safely operate the plant particularly in emergency situations?
(2) Do the NRC and Company examinations reliably men. sura the operators' abil-ity to safely operate the plant?
^
. Memorandum and Order on Lead Intervenors, July 13, 1984 at 2.
After further comments were submitted by the parties on
'the scope of the proceeding, UCS subissue (1) was modified as follows:
~
, .(1) Are the operators trained to safely
~
operate the plant in accordance with
' approved procedures, particularly in
<- emergencies?
' Memorandum and Order on Licensee's July ,31, 1984 Comments'on a Lead Intervenors and Motion.to Partially Exclude UCS from Man-
. agement Phase, August 30, 1984, at 3. In addition, the Board reemphasized the. fact that the NRC examinations were~appropri-
.ately within the scope of UCS.subissue1 (2):only to-the. extent the OARP Review Committee relied upon these exams as a measure of, operator competence. . During discovery,.in response to a
- Board inquiry precipitated by a discovery dispute.between UCS and the NRC Staff,Jthe' Committee made_ clear'that itssopinions.
about Licensee's training program were formed independently of
'the:NRC examinations. . See letter'from Licensee's counsel to .
.the Licensing Board dated September. 27, 1984;- see also'Tr.-
T1,'966-69.(Kimel,1Gardner, Kelly,.Christensen, Uhrig); Tr.
J2,085-87 (Kelly). Accordingly, the NRC exams were not'within
- the scope.of:the remanded proceeding.
6/ TMIA sought lead'intervenor status.,to pursue the following.
. cissue s t'-
.(1) Has'GPU properly responded to the' s _ - (Continued Next Page)'
a ,
~8-F. .
~
tOi M
h
~
- ^b j[ +1
E a
- /i . Because'the wording of-TMIA's proposal suggested that TMIA
~
might. pursue . matters that were res judicata, the Board simply approved TMIA's lead on the training issue to the extent that ALAB-772 authorized an inquiry into cheating and integrity as they_ relate to training. Memorandum Order on Lead Intervenors, Lsupra, at 3;.see also Tr. 31,757-58, 31,784-85 (Chairman
-Smith).
L9. During the course of the proceeding, it was apparent
+
and, indeed,~.TMIA acknowledged that it had not made.an effort l
-(Continued) problems in its training program iden-
~
tified internally . and/or by the Spe-cial Master,' the Licensing Board'and the Appeal Board)
~
(2)- Are the people responsible for.the.
management and implementation of the training. program properly equipped by
^
theirLown experience and attitude to 1- i. impart the information'and values-nec-E /~ essary.for safe operation of TMI-1?
u- s
- - (3) EDo the operators have.the appropriate +
attitudettoward the. training program;
.do they.believe it is. effective?
it (4) ~ How'does'the. history of GPU's problems-
, with-training and its, current training z
~
program = reflect on the competence and-integrity of GPU 1management?;
I I 1
' Memorandum;and Order'on; Lead Intervenors,; July.13, 1984 at 2.
- In its August
- 30,_1984 Memorandum and Order, -the Board -ruled
- that TMIA subissue=(4) was'outside the scope of the1 remanded proceeding.
D,
'9 e
,t , 1 - 4 4 t 1.
9 I
to consolidate its presentation with that of UCS. See Tr.
y(~}. .
31,996 (Bradford); see, e.g., Tr. 32,639-50 (discussion among parties, Board). In its discretion, the Board nevertheless al-lowed TMIA'to pursue on cross-examination its areas of inter-est, which were the issues of integrity and attitude, and as well to offer as exhibits documents in these subject-areas, notwithstanding TMIA's failure to provide advance notice to the parties of these exhibits. See, e.g., 32,239-80 (TMIA Training Exhs. 3A-3M). Although this latitude was permitted, the Board advised TMIA that TMIA was wholly in default of the Board's procedural rulings and was not entitled to surprise the other
-parties by, for'the first time at trial, identifying its affir-mative case. See Tr. 31,986, 32,311-13, 32,249-51 (Chairman Smith, Judge Wolfe).7/
7/ The Board cited a number of reasons for this finding: (1)
'TMIA'had failed to comply with the Board's orders.to review and identify case-in-chief documents in advance;,(2) TMIA appar-ently had not' engaged 11n the type of discovery necessary to effectively cross-examine the witnesses,.instead. choosing to use.the-hearing process as.a discovery mechanism; (3) TMIA's
. experienced trial counsel-in the-case elected not to partici-pate in the remand on training; and (4) frustrating the purpos-es behind the administrative procedure agreed upon by allfpar-=
~
ties, TMIA had failed to comply'with.the Board's order to utilize a lead-intervenor system. Tr. 32,311-13 (Chairman Smith); Tr. 32,645-50 (Chairman Smith); see Tr. 32,236
-( Bradford )'.
t v
h ._.
+
e f {p C. The Scope of the Proceeding QJ
- 10. The focus of the Appeal Board's remand of training is on the views of the OARP Review Committee. However, in Section
~ III.C of ALAB-772, the. Appeal Board raises numerous questions about Licensee's training program. Because of the importance of the issue of training, see ALAB-772, supra, 19 N.R.C. at 1279, and our independent responsibility to ensure that the record in this proceeding is complete,8/ the Board was reluc-tant to interpret narrowly the Appeal' Board's directive re-manding the issue of training. Moreover, while the Appeal:
Board may-have remanded the training issue solely to hear-the views of. Licensee's consultants, the right of other parties to
-confront those views necessarily broadened the scope of.the
' hearing. See Memorandum & Order'Following Prehearing Confer-ence,. July 9, 1984 at 3. However, ALAB-772 specified several'
~
limitations on'the scope.of this proceeding and, by applying m.
.those' limitations, ths Board. essentially provided.acframework within which the evidentiary-proceeding' ensued. ,7
'W, 8f . ~In ALAB-772, the Appeal .' Board made clear -that1the- remand
.was precipitated by "the-Licensing-Board's failure to reconsid-~
er,Las promised:and'in a meaningful way, its earlierifinding-thatDlicensee's': training program was ' comprehensive and. accept-2 i
- able.'" ALAB-772, supra, 19 N.R.C. : at :1233. -In this remanded
-proceeding,Ethe Board 1therefore is. charged with a-particular;
, responsibility tosensure an' extremely. thorough record, indepen-Ldent~oft the-like tesponsibilities conferred on it'bysthe.Com-
' mission?in-its. original institution of'this proceeding. See
.CLIL79-8, E10 ' N. R.C.' 141,1147-49 (1979).
d
.ys, k - ,
s
g_ 11. The broad issue on remand was the adequacy of the f"'/
A- .
training program to prepare the TMI-1 licensed operators to op-
~
erate the plant safely. See Board Memorandum & Order Following Prehearing Conference, July 9, 1984 at 2-3; s e e , -e . g . , Tr.
32,270-74 (Chairman Smith). However, this broad issue was con-fined by the Appeal Board in Section III.C of ALAB-772 to the implications of cheating and other deficiencies which came to
~ light in the reopened proceeding on cheating. In addition, management findings (including findings on the TMI-1 training program) which were not placed in issue.by the Appeal Board ,
were res judicata in the remanded proceeding. Id. at 3. For example, the remand did not permit the relitigation of the
-cheating incidents themselves. Id. at 3, 6.
- 12. Another significant element of the definition of-the scope.of the remanded proceeding was that it addressed the ade-quacy of licensed operator training at TMI-1. Section III.C.
of ALAB-772 addresses only licensed _ operator. training. . Fur-thermore,.the cheating-that precipitated this remand was limit-ed to cheating on licensed. operator examinations and quizzes.
'See ALAB-772, supra,-19.N.R.C.'at 1212-32. In short, the
- record on training for non-licerssed _ personnel is res -judicata !
and was not relitigated.
p; .
.' k,,J .
^
.w,.
p'.
- 13. In addition, ALAB-772 clearly-remanded the issue of
-('}
training in order for the Board to assess the implications-of the cheating incidents on the adequacy of the operator training
-program currently in existence at~TMI-1. ALAB-772, supra, 19 N.R.C. at 1235; see generally id. at 1232-37 (issue is whether past~ deficiencies "still exist," and current status of program and personnel.) However, the Board was reluctant to deny par-tiesLthe?right to pursue a particular past problem insofar as that problem could shed some light on the adequacy of the cur-rent program. See ALAB-774, 19 N.R.C. 1350, 1356.(1984) ("This proceeding was not instituted to provide a forum in which to-litigate directly all possible errors of the past; past training deficiencies are part of the reopened' proceeding only insofar as they shed 'new light.on the adequacy of licensee's existing training program.'"); see, e.g., Tr. 32,220-31 (TMIA cross-examination of Dr. Long about.1979-timeframe).
.14 . Finally, the Board permitted litigation 1of the.NRC license examination only insofar;as this process formed a basis-for the OARP Review Committee's-opinion'of Licensee's program.
Seetn.5,' supra. In'its review, the Committee did-not rely.at all.on,the NRC exam. Id. Consequently, the'NRC exam.was not1
.at-issue.
sd
./M -
- (
~~'-
l: . .
r N
S e-
n w; s
a s
_ ("Y: 15. :Not surprisingly, the parties' interpretation of the pi scope of the. remanded training issue varied, and this fact was reflected in their respective cases-in-chief. The NRC Staff
. considered the remand to be limited strictly to the views of 4
the OARP Review. Committee about licensed operator training at TMI-1. The Staff testimony therefore proposed a methodology by which the Committee could make such an assessment, and compared the' proposed methodology with the approach used by the Commit-tee. See Testimony of Julius J. Persensky, Joseph =J. Buzy and
. Dolores E. Morisseau on the Remanded Training Issue from 7
-ALAB-772~(" Staff"),Jff. Tr. 33,148, at'2.
UCS similarly presentedcan expert witness,.Dr. James J. Regan, who offered his-recommended methodology for analyzing training at TMI-1.
Testimony of Dr. James'J. Regan ("Regan"), ff. Tr. 33,532; see also Surrebuttal Testimony of Dr. James J.-Regan ("Regan'Surre-buttal"), : ff. Tr. 32,693.
The Licensee presented the panel.of
- five' experts-who made'up the Reconstituted'OARP. Review Commit-tee.9/ .See Testimony of the Reconstituted ~OARP Committee (Dr.
'Julien Christensen,1Dr. Eric_Gardner, Mr. Frank Kelly',lDr.
- William Kimel and Dr. Robert.Uhrig)
- on the TMI-1-Licensed-19/ In:May 1984, the OARP Review Committee was1 reconstituted.
1The membershipiremained the~same!withithefexception oflMr.
~
Marzec;swho was unavailable. He.was replaced with Mr. Frank ~
1 Kelly? aniexpert on.' licensed operator. testing, who'previously;
^
testified-in.this proceeding. See 1 224,. infra; compare n.2,'
Laupra; see:LBP-81-32, sup ra ,~ E 14 - N . R .'C . at 460-61;(11 226-29).
^^ :x
- t w_-). -
2 ,
3 1
L
l-(~'s Operator Training Program (" Committee"), ff. Tr. 31,749; Rebut-D' -
tal Testimony of the Reconstituted OARP Committee (" Committee Rebuttal"), ff. Tr. 33,320. While the Staff offered no testi-mony on the actual content of the current TMI-l licensed opera-tor training program, Licensee presented three panels of com-pany witnesses who described the program in detail. This testimony specifically addressed questions contained in Section III.C of ALAB-772 about post-cheating management actions relat-ed'to. training. See Licensee's Testimony of.Dr. Robert L. Long and Dr. Richard P. Coe on the Issue of Licensed Operator Training at TMI-1 ("Long & Coe"), ff. Tr. 32,202; Licensee's Test'imony of Mr. Samuel L. Newton, Mr. Bruce P. Leonard and Mr.
Michael'J. Ross on the Issue of Licensed Operator Training at TMI-1D(" Newton'et al."), ff. Tr. 32,409; Rebuttal Testimony of ,
Dr. Ronald A. Knief and Mr. Bruce P. Leonard ("Knief &
Leonard"), ff. Tr. 33,364. UCS'and TMIA challenged the sub-
@ stantive adequacy of the licensed operator training ~ program, n
'both through: cross-examination of Licensee's witnesses and.
through'the introduction of exhibits offered-for the purpose 'of- -
establishing inadequacies- in ' the: program. See UCS1 Training; Exhs. 1-34; TMIA Training.Exhs.-1-11.
16 .- ~ The Board has' thoroughly considered;the1 adequacy of licensed: operator training at TMI-1. In.so doing, like the L;icensee and'the-intervenors, perhaps.we have'gone further.into.
- ,:q .
( )
\/
h
'# _,l $
~ . -
_the details of training at TMI-1 than the Appeal Board intended-( [_
us to go. However, by examining operator training in consider-
.able detail, we have ensured ourselves, the parties, and the public that th Appeal Board's concerns that prompted this re-mand have been fully addressed. Moreover, by becoming knowl-
_edgeable about the current program, procedures, and people in-
-volved in licensed operator training at TMI-1, the Board is able independently to evaluate the conclusions reached by-the Reconstituted OARP Review Committee. Thus, the Board is in the position itself of being able to " validate" the reliability of the-Committee's findings -- the' issue at the heart of the re-mand' proceeding on' training.
II. Proposed Findings of Fact A. L'icensed Operator Training Program at TMI-1
- 1. Organization
- a. Key Management Personnel.
- 17. The TMI Plant Training 10/ organization,1one 1]L/ See Long & Coe, ff. Tr. 32,202, Attachment 5, for an orga-nization chart of the TMI Plant Training Section.
~
16-
[
$ p 4 - --w-) 9 - y iw y w-9 v--'y-- -t7+
==
~
_ subset of which is Licensed Operator Training, is one of four A ~ '
' sections of the GPU Nuclear Training and Education ("T&E") De-partment,11/ headquartered in Parsipanny, N.J. T&E is one of four departments of the Nuclear Assurance Division ("NAD") of GPU~ Nuclear, which, in turn, is one of six divisions that pro-
' vide _ support to TMI-1, TMI-2 an'd Oyster Creek.12/ The Licens-ing Board is favorably impressed with the diversity of experi-L ence and the depth of quality of the management team resp'onsible'for TMI-1 licensed operator _ training, as the fol-
- lowing career-summaries attest.
~
- 18. Robert L. Long, Vice President'and Director-Nuclear Assurance Division. Effective April 1, 1982, Dr. Long-was-elected.to the position of Vice President-Nuclear Assur-
-ance. The Board: described Dr. Long's credential's in its ini-tial management decision of August, 1981,_whenLDr..Long held
, , , the-position of Director of, Training'and< Education. .See
~
[# LBP-81-32, supra,-14 N.R.C. at1444,(1.171); see also Long & ,
(Coe,-ff.'Tr. 532,202,,at 27-29. _ In summary, 'Dr. ;Long has 3 over?
"twentyiyears of' experience in a variety'of_ aspects of nuclear energy,- reactor' operations, and education and2 training. : He:
.holdscthe_. degrees of B. S'. in-Electrical# Engineering'from k
- ~m 11/'-See g., Attachment'_4,. for-!an organization'chartiof T&E.
, 11_2/ See ._ M. , ' Attachment _3, - for ~ an organization chart of NAD.
9 4
/ C g(A 3 -
1 f
w .
. s ii
Bucknell University (1958) and M.S.E. and Ph.D in Nuclear Engi-neering from ?urdue University (1959 and 1962, respectively).
While with GPU Nuclear, Dr. Long has completed the Edison Elec-
'tric Institute four-week Executive Management Program (1982) and Emergency Support Director training for both TMI and Oyster Creek. Id. at 27.
- 19. Dr. Long served as Director'of Training & Educa-tion from February 1980 to March 1983. During a significant
.part of that time, he also served as Acting Director of the Nu-clear-Assurance Division (February to September 1980) and as Director of NAD (from April 1982 to March 1983). Dr. Long also
- served full-time.for approximately three months in early 1982 as head of the Failure Analysis Task Force for;the TMI-1 Steam Generator Repair-Project. He has had responsibility for. major changes in organization, staff, and function of the diverse
. areas of Nuclear-Safety _ Assessment, Emergency Preparedness,
.. Training & Education,' Quality Assurance, and the~ Systems Labo-ratory. While serving as-Director'of T&E, much of Dr. Long's-2 effort was directed.to the: development of facilities, the hih-Ling and, training of staff, and the evalua' tion and development' of requirements for the TMI. simulator training program, leading _
to the purchase'of the basic principles and' replica simulators.
Id. at 28-29. Of course, Dr. Long also oversaw the.developmen't of.-the training programs which are now in place at TMI. As?
-18 ,
fR v
-discussed more fully infra at 1157-63, as Director of T&E, Dr.
-[^}-
../
Long bore responsibility for the cheating incidents that oc-
' curred. .Id. at 29. The Board of Directors carefully consid-ered this fact in deciding whether to promote him to the Vice Presidency of NAD.
. J_d .
- 20. Richard P. Coe, Director-Training & Education Department. Dr. Richard P. Coe began serving as Director- .
Training & Education for GPU Nuclear on March 14, 1983. He has over twenty years of experience in a variety of educational settings, including public school, university, and industrial education and training. He holds the degrees of-B.A. and M.A.
in Industrial Education, and Ph.D in Educational Administration
- Labor. Relations. From 1961.to 1975, Dr. Coe was a teacher and' administrator in the-field of secondary school education.
As a secondary school administrator, Dr..Coe was involved in the accreditation of high school programs;and served as an ac-creditation peer evaluator. During.the three years he was at L .
the University.of Pittsburgh, Dr. Coe was extensively involved in the development and certification-of: vocational training in-structors. He also was actively-involved in the development of the Competency Based Teacher Educa, tion Program, a nationwide-
_ program centered at Ohio State: University. Following comple-t-_ -
. tion.of his Ph.D degree, Dr. Coe-also' worked as an industrial training manager and consultant in; training.and educational'
-(y lu J .
j,
-(--) development with several large U.S. corporations. He also
. L) .
taught several MBA courses at the university level in organiza-
- tional development and management. Long & Coe, ff. Tr. 32,202, at 29-30. . Prior to joining GPU Nuclear, Dr. Coe completed pro-fessional development programs in decision analysis, budgeting and costs control, performance management, executive develop-ment, and management.of human resources. Dr. Coe has completed GPU Nuclear's six-day management development program and has participated as an instructor in GPU Nuclear's i
- istructor de-velopment program. Id. at 30-31; see Tr. 32,084 (Gardner).
- 21. While Dr. Coe has a non-nuclear backgrouad,-he has extensive experience in industrial education, needs assess-ments, performance-based training, behavitaral. learning objec-
-tives,. and training of instructors. Mo re'ove r, Dr. Coe was rec-ommended to Licensee as an excellent classroom teacher and as an individual with effective interpersonal and management skills. Long & Coe,-ff. Tr. 32,202, at 31; see Tr. 32,084 (Dr.
Gardner described an instructor-training class given by Dr. Coe las "one of..the best presentations-I think Ive seen."). -Dr.
Coe's' strong educational. background'is complemented and sup-ported by the strong nuclear experience of Dr. Long and the managers of plant training at TMI,. Oyster Creek, and corporate headquarters. In Dr. Long's. opinion, since his appointment,
-Dr.'Coe has served effectively as Director-of T&E by providing m.
. s-)~
k
m j'"y s-strong leadership in the development of instructors, management
- and supervisory training, and preparation for accreditation of the licensed operator (and other) training programs by the In-i : stitute of Nuclear Power Operations ("INPO"). Long & Coe, supra, at 32.
- 22. Samuel L. Newton, Manager-Plant Training.
4 Mr. Samuel L. Newton became the Manager-Plant Training in June,
- 1983. Mr. Newton's credentials were described by the Board in its initial management decision of August, 1981, when Mr.
Newton held the position of Operator Training Manager.
LBP-81-32, supra, 14 N.R.C. at 445 (1 175); see also Long &
Coe, ff. Tr. 32,202, at 32-34. In summary, Mr. Newton has nearly twelve years of experience in the Nuclear Navy and ap-proximately 4 1/2 years in the TMI Training Department. 'He has a.B.S. degree with a major in Political-Science and Economics from the U.S. Naval Academy'(1968), and'a Master's degree in
- Management from the U.S. Naval Postgraduate School (1969).
223. .In April 1980, Mr. Newton began his employment-with GPU' Nuclear as the Supervisor of Licensed Operator
.. Training,at TMI. .He was promoted.to Operator Training Manager-
- irr September: 1980. In these positions, Mr. Newton was respon-
. sible ' initially 'for- supervision of -the licensed operator training instructors and' subsequently, as Operator Training f
N../
, r's Manager, for supervision of licensed and non-licensed operator Q)"
and shift technical advisor (STA) instructors. He was actively involved in developing training programs and procedures that were-responsive to the numerous post-TMI-2 accident training reviews and recommendations. Long & Coe, ff. Tr. 32,202, at 33.
- 24. Mr. Newton's promotion to the position of Manager-Plant Training was based on the effectiveness of his response to the cheating incidents and his job performance throughout his entire employment period with GPU Nuclear.
Mr.' Newton also had served effectively as Acting Manager of Plant Training on- several occasions. In the past year and a half,EMr.' Newton has managed the installation and integration into the operator training program of the Basic Principles Trainer Simulator ("BPTS") and_has prepared portions of the TMI training program for INPO accreditation. Id. at 33-34.
- 25. Bruce P. Leonard, Operator Training Manager.
Mr. Bruce P. Leonard became Operator Training Manager on June 1, 1983. He has approximately six years of experience with the Nuclear Navy and two, years in the TMI Training Depart-ment. He holds the degree of B.S. in Engineering - Naval'Ar-chitecture from the U.S. Naval Academy (1976). His Navy training and experience include the one-year Naval Nuclear
(~3 t )
.v
1 L: '
'W ffM 3 ' Power Training School; completion of qualifications as Chief Engineering Officer; a variety of short programs (e.g., Quality e__v-LAssurance,. Water Chemistry Control, and Instructor Training);
and operating and training management _ experience on assignments
-to a nuclear submarine and the S3G prototype reactor. At the S3G prototype.Mr. Leonard was Staff Training Officer and had responsibility for the initial and continuing training of ap-
~
proximately one hundred fifty' Navy Staff instructors. Since-
-joining GPU Nuclear, Mr. Leonard has completed the six-day man-agement development program and short courses in instructor de-velopment and decision-analysis. In November 1982, Mr. Leonard began his: employment with Licensee as Technical Program Spe-cialist in the TMI' Operator Training subsection. His assign-mente included' work'on the review, evaluation, and revision of training programs for licensed-and non-licensed operators and STAS. Long & Coe, ff. Tr. 32,202, . at . 34-35.
- 26. Consistent with the' recommendation _of Admiral
[ ~
Rickover,-as well_as GPU Nuclear's own view asito.itsivalue for.. ,
.the Operator Training Manager, Mr.LLeonard is working toward:
,? obtaining an'SRO license on TMI-1. He has completed four' 1 months lof.an approximately six-month training' program for the X
- zTMI-lLSRO license ~,: including extensive'. training'on TMI-1.sys--
y ..
,temsfand on-shifttoperations.13/- Mr. Leonard has performed E 13/ ' In late: August <1984, the decision.was made to withdraw-
'Mr.tLeonard from1the SRO-training ~ program. This' decision was ,
(Continued Next Page)
&~1 "
+
N h-
rc L*
l r well since joining GPU Nuclear. Id. at 35-36.14/
- 27. Ronald H. Maag, Supervisor-Licensed Operator Training. Mr. Ronald H. Maag recently was= appointed to the po-sition.of Supervisor-Licensed Operator Training after serving as Acting Supervisor since August, 1984. He has approximately
~
eight and one-half years of experience in the Navy, about three years in the TMI-1 Operations Department and about a half year in the Operator Training subsection. Mr. Maag holds an Associ-ate in Science degree (1981). His Navy training and experience
-include.the Machinist Mate A School; the one-year Navy Nuclear Power School; about two and one-half years as a staff prototype instructor; a variety of short programs (e.g., Instructor, Training, Quality. Assurance, and Machine Tool Operator); and n
- (Continued) .
particularly necessary in view of the impact of ALAB-772'and
~-NUREG-0680, Supp. 5 on workload and the= assignment of'supervi -
sors in the Operator Training Subsection. Plans-are for LMr.. Leonard to resume his SRO training by the second quarter of 1985. .Long1& Coe,-ff. Tr. 32,202, fat 35; see also Tr. 32,680 (Newton). In the meantime, GPU' Nuclear is confident that" Mr. Leonard has;the requisite technical knowledge and man-:
agement/ supervisory skills-to manage and direct the activities-of Operator Training.
~ 14/3 UCS questioned.Mr. Leonard's, technical ability to serve in z
, his job,-given his exam-review responsibilities. 'See
~
11D185-186, infra;Lsee Tr. 32,513-31 (Jordan cross-examination of Leonard); but see Tr.'33,054-56 (Leonard); UCSLTr.:Exh. 32.
The Board believes Mr. Leonard has an excellent technical back-ground'for his positior.,'although obtaining an.SRO license will' be very' advantageous to him.
(
[]
i.. x .
k '_ _ . . . . _ _.:__..____ . _ _ _ . . _ _ _ _ ___.____._m____._____m _ _ _ _ _ _ _ _ _ . _ _ _ _ _ . _ _ _ _ _ _ _ . _ _ _ _ _ . _ _ _
7
-about four years of operational and maintenance experience on a A.'
nuclear submarine, where he qualified as a watch supervisor.
Long & Coe, ff. Tr. 32,202 at 36; Tr. 32,946 (Ross).
- 28. Mr. Maag began his employment with GPU Nuclear in January, 1982 as a candidate TMI-l reactor operator. Long &
Coe, supra, at 36. He has completed the RO and SRO license training programs,.as well as the short courses given in super-visory development and decision analysis. Id. Mr. Maag was at the top of his class in the reactor operator replacement pro-gram; lue was at the top of his class in the OJT program. Tr.
~32,946-947 (Leonard). He received his NRC RO license in May, 1983 and his NRC SRO License in May, 1984. Long & Coe, ff. Tr.
'32,202, at 36. He performed the duties of a licensed TMI-l shi~ft foreman'for about two months prior to joining the Training Department as a licensed operator instructor in July,*
1984. Id. at 36-37. The Manager of Plant Operations, RMr. Ross, testified that Mr. Maag's overall performance has been " excellent." Tr. 32,946 (Ross).
- 29. Dennis J. Boltz, Simulator Development Manager..
' Effective January 7, 1985, Mr. Dennis-J. Boltz, previously Supervisor,. Simulation Inst'ruction, assumed the position of Si-mulator Development Manager. Mr. Boltz has approximately eight years of experience in~the TMI-l Operations Department (RO, f5
/\
)
r
t'~] 1974; SRO, 1976), and almost eight years in the T&E Department L.) .
as an instructor and Supervisor. His experience includes six years as a TMI control room operator and 18 months as a TMI Operations shift foreman. Long & Coe, supra, at 38; Tr. 32,488 (Leonard). Mr. Bolt: has been intimately involved with the specification, design, acceptance testing, and instructor training for the Basic Principles Training Simulator, including approximately nine months spent in essentially full-time resi-dence at the simulator manufacturer. Long & Coe, ff. Tr.
32,202, at 38.
- 30. Herb e~rt J. Lapp, Jr., Manager-Educational Development. Mr. Herbert J. Lapp began serving as Manager of Educational Development for GPU Nuclear on October 1, 1984. He has approximately fifteen years of experience in public school and industrial education and training. He holds the degrees of B.S. in Physics and M.A. in Secondary Education. From 1969 to 1980 he served as a high school science instructor, advancing
.to department chairman in science and math. From 1980 until joining GPU Nuclear, he served in training supervisory posi-tions with Commonwealth Edison's nuclear plant training pro-grams. Long & Coe, ff. Tr. 32,202, at 39. Mr. Lapp brings to Licensee considerable experience in developing performance-based training and instructor development programs. He has also served as a peer evaluator on an INPO accreditation team.
_Id.
(
- 31. Michael J. Ross, Manager-Plant Operations.
( ~ Mr. Ross has served as Manager, Plant Operations, TMI-1, since i _ LJanuary 1978. Although the Training Department is organiza-
, .tionally independent of Operations, the Manager, Plant Opera-g tions is heavily involved in operator training both out.of de -
.. i sign'(company procedures and programs mandate this
- invol'vement) , and out of an interest'in ensuring that the oper- ;
i i ators-are trained to operate TMI-1 properly. The Board summa- ; rized Mr. Ross's credent'ials in its initial management decision of August, 1981. LBP-81'-32, supra, 14 N.R.C. at 439 (1 154).
'In summary, Mr. Ross's background' includes over' twenty years of experience in nuclear power plant operationd and supervision.
-Observing that.Mr. Ross may be the most important p. son on the TMI-1 operating team as far as the public health-and' safety is concerned, we-endorsed Licensee's reliance on,Mr. Ross for.his broad and deep knowledge of the practical operating aspects ofi i
- the plant.- Id. at-439-40 (1 155). .In the context of training,.
~ the Board notes that the NRC Staffiasked Mr. Ross tojpartici -
pate in allimited-attendancetNRC forum on-how to give' simulator?
- . examinations. See Tr. 33,064-67f(Ross). The.NRC'StaffLinvited.
Mr. Rss-because/of!his. o experience'and interest in' simulator, 4
<k examinations. Tr. 33,066 (Ross).
- 32. In assessing the qualifications of m'anagementi responsible for licensed operator training,' the' Board. agrees -
'2 with the'!following' observation of the-OARP Review Committee: , - () my . 1 t t _ _ _ _ _ _ . . . _ . _ _ . _.._____.___.__1___m._ _ _ _ _ . _ _ . _ _ _ _ . _ .m_______ ___.__i__.______________._________. ..._.______m__
1 [I]n an organization that is responsible for 7' \_ j effective training on a broad scale (with op-erator, technician, engineer, management, and general employee training being adminis-tered), a special mix of management, educa-tion, and experience is most beneficial to the conduct of training operations. The Com-mittee is of the view that the T&E management in place is performing very well and has been innovative and effective in development.of the GPU Nuclear training programs. The indi-viduals cited by the Appeal Board -- in par-ticular, Dr. Long, Dr. Coe, Mr. Newton and Mr. Leonard -- have the variety of back-grounds recommended in the 1980 OARP Commit-tee Report. They possess the complementary skills and knowledge that, in the Committee's view, are essential to the smooth functioning and effectiveness of the GPU Nuclear training program. Co'mmittee, ff. Tr. 31,749, at 8-9; see also, id. at Attachment 1, Special Report of the Reconstituted OARP Review Committee, June 12, 1984, ("Special Report") at 16-19. We concur with the favorable evaluation by the Committee of the capabilities of the senior people responsible for the TMI-1 licensed operator training program. See Committee, supra, at 10.15/ 15/ The Board notes UCS' concern about the lack of experience of Messrs. Newton, Leonard, and Maag at an operating commercial nuclear power plant. See Tr. 32,214-16 (Jordan cross-examina-tion of Long). The Board is satisfied, however, that these individuals hold the requisite credentials to perform their as-signed responsibilities. We also note that all of these indi-viduals have had some operating experience on the TMI-1 systems that have been utilized during cold. shutdown. Moreover,'there is strong involvement in the training program development and implementation by the plant operating staff, who have extensive experience. See Tr. 32,358-59 (Long); see, e.g., 1 168, infra. s
/S b. Staff N ),
- 33. The GPU Nuclear licensed operator training staff for TMI-1 is larger and more highly qualified than when this Board previously reviewed the training program. In 1981, it consisted of one supervisor and two instructors, who were SRO-licensed. Two contractors also were assigned. None of these individuals held degrees. Newton et al., ff. Tr. 33,409, at 25-26. Today, manpower in the Operator Training section de-voted to TMI-1 licensed operator training consists of one man-ager, one administrative assistant, two staff positions (both with responsibilities as instructors), one supervisor, and three instructors (one who is assigned as Supervisor Non-Licensed Operator Training). Of the six personnel designated to conduct licensed operator training, four have been licensed or certified as senior react'or operators.ls/ The cumulative nuclear power plant experience of the staff is forty-eight years, of which twenty-five years are commercial. The cumula-tive instructor experience for the Operator Training staff is twenty-nine years, of which twenty-two years are in the nuclear field. Five of the staff hold Bachelor's degrees;-one holds a-
-Master's degree as well. Id. at 26; see also Committee, ff.
Tr. 31,749, at 10. 1Q/ Three of these licenses are curre'nt; the other is not, but the instructor is now requalifying for a current SRO license. Tr. 32,486-88 (Leonard). s
) -
( ^'; 34. In addition to GPU Nuclear personnel, two con-x ' tractors will supplement the Operator Training staff through mid-1985. These contractors previously were licensed as senior reactor operators at TMI-1. One served as a shift foreman and the other as a shift supervisor. They have forty years of nu-clear power plant experience, cf which twenty-six are commer-cial. They have eleven years of instructor experience in the nuclear field. Newton et al., ff. Tr. 32,409, at 26. These two instructors ultimately will be replaced by permanent staff. Tr. 32,673 (Leonard).
- 35. Supporting the Operator Training Section is an Administrative Assistant who tracks attendance, documents exam-inations, and maintains records required for certification by the Vice President, TMI-1. The assignment of these tasks to the Adminstrative Assistant has enabled the Supervisor and Man-ager to devote more time to non-administrative tasks. Newton, ff. Tr. 32,409, at 27.
- 36. In addition, the Technical Programs Specialist assists the Operator Training Manager in ongoing review, evalu-ation, and revision of licensed operator programs. This posi-tion also is assigned to instruct operator's in theoretical sub-jects such as reactor theory, heat transfer, fluid flow, and thermodynamics. The addition of the Technical Programs
)
c:- ; {}
, Specialist has provided Training with additional instructor
. availability, and has reduced the workload of the Operator
[ Training Manager and Supervisor, Licensed Operator Training in order that they may devote more time to program development and delivery. Id. at 27-28.
- 37. In addition to Licensed Operator Training, there
' is now a separate Simulator Development section of the TMI-1 l Training Department that consists of one manager and three in-structors. The credentials of Mr. Boltz, the Manager, already have been described. See 1 29, supra. The three instructors assigned to this section are presently in an SRO training pro-gram in preparation for qualification as SRO-licensed simulator instructors. All three have Bachelor's degrees and have eighteen years combined nuclear power plant experience,.of which twelvb is commercial. In addition, two licensed reactor operators are assigned from the Operations Department to assist
. in development of the BPTS and replica simulator programs.
Newton et al.,.ff. Tr. 32,409, at 27. L 38. UCS has pointed out on cross-examination of Mr. Leonard that a number of the' instructors are new and,'Inr. inference, appears to be suggesting that the licensed operator training program instructors are inadequate, or at least, have no proven record on which they can be judged. See Tr.
.ry J
E
r y-~g 32,486-90 (Jordan cross-examination of Leonard and Newton). V However, UCS provided no facts to support this inference. In
. any event, we find satisfactory Licensee's response to UCS' concern. According to Mr. Ross, the effects, both on the training program and on the operators themselves, of the new members of the training organization have been positive: (1) the new instructors have brought fresh plant operating experi-ence into the instructor ranks; (2) this experience has'in-creased the instructors' (and hence the Department's) credibil-ity; (3) the operators therefore can relate better to their instructors, knowing that the instructors have been operators and have experienced what the operators have in the plant; (4) training, therefore, becomes more palatable and acceptable.
Tr. 33,060 (Ross).
- 39. UCS also implies that these instructors, though operationally experienced, are not instructionally competent.
See Tr. 32,486-90 (Jordan cross-examination of Leonard). Prior to being hired as an instructor, however, each candidate has to perform a practice teach, during which his instructional skills are evaluated. Tr. 33,061 (Leonard). As part of the.instruc-tor certification process, each candidate must perform another practice teach, either in the one-week instructor development program or as part of the interim certification process. Id. Furthermore, before an instructor is hired, there is an I v.
evaluation of the individual's credentials, and after an in-7-) - structor is hired there are both informal instructor evalua-tions and required (formal) instructor evaluations. Id. In short, the process employed by Licensee ensures a prospective instructor's teaching ability.
- 40. UCS finally infers that the very fact Licensee has had to hire new instructors indicates a problem of some kind. See Tr. 32,486-90 (Jordan cross-examination of Leonard and Newton). However, Mr. Newton has given two appropriate reasons for the influx: (1) the original licensed operator in-structors have departed from the program for various reasons unrelated to their teaching abilities or to a failure in the training organization, and (2) expansion of the training pro-gram and the budget has resulted in the hiring of new instruc--
tors. Tr. 33,061-63 (Newton).
- 41. The Board is satisfied that since 1981, GPU Nu-clear has increased the licensed operator training staff in order to improve the training programs. We conclude that the present operational and instructor experience in the TMI-1 training department adequately supports the training programs in place. See Newton et al., ff. Tr. 32,409, at 28.
.nw,
/~S 2. Training Facilities v
- 42. One indication of GPU Nuclear's continued com-mitment to training is the improvement in facilities and re-sources available to the instructors from those noted by the OARP Review Committee in 1980.17/
- 43. The majority of classroom training for licensed operators is conducted in a modern training center.lg/ In 17/ In its report dated June 1, 1980, the OARP Review Commit-tee made a number of recommendations for improvement of those activities normally handled by the Training Department. Com-mittee, ff. Tr. 31,749, Special Report at 28. Recommendation C was that CPU should replace the temporary training facilities with a permanent training facility more conducive to learning.
Id. at 30. Recommendation E stated in part that management must overtly support the importance of simulator training. Id. at 31. Ig/ The newly constructed, modern training center, occupied in 1981, is a 20,000 square feet facility specifically built to meet training needs. Each classroom is equipped with zoned lighting and wall screens for projection. Audio-visual equip-ment available to instructors includes overhoad, opaque, and slide projectors, videotape players and monitors, movie and videotape cameras, photographic equipment, and transparency and lettering machines. The inventory of equipment most frequently used by instructors has been significantly increased since 1980, e.g., in 1980 there were 7 videotape players, 8 videotape monitors, 8 overhead projectors, and 2 slide projectors. Now there are 27, 32, 24, and 10, respectively. A monthly mainte-nance schedule has been developed and the equipment is main-tained and repaired by the plant instrumentation and control shop, providing more rapid turnaround than when commercial re-sources were utilized. Administrative support work for licensed operator training is done on word processing equipment and training record data is stored on GPU's main frame IBM com-puter in Reading, Pennsylvania. Access to the main frame is via terminals located in the training center. Newton et al., ff. Tr. 33,409, at 55.
)
L - _ - _
A_ addition to fifteen classrooms, including a large dual-purpose
~
room which is used either as a small auditorium or as two , classrooms, the building houses the Basic Principles Training Simulator ("BPTS") and its support equipment, a control room mockup, modular office spaces for a training staff o'f 62, a ' training library, file room, A-V equipment room, conference . room,. vending machine area and photocopy, storage and rest room u i areas. Newton et al., ff. Tr. 32,409, at 54-55; see also Com-mittee, ff. Tr. 31,749, at 9; id., Special Report at 43. A , second building, identical in size to the existing training center, has been designed. Construction is scheduled to start in the spring of 1985 to support the arrival of the replica si- I mulator. The building, two-thirds of which will be devoted to
' training needs, will house _the replica simulator and the BPTS, and will provide additional instructor work spaces and storage capacity, freeing three additional rooms in the existing build- ,
ing for classroom use. Individual instructor work areas will enhance conditions for one-on-one instructor-student tutoring and counseling. In addition to utilizing the facilities at the' ;
. training center, space is made available on the TMI-l site for
- the conduct of training. An, increasing emphasis on in-plant .
training has moved some classroom training to component loca-tions.- This emphasis is designed for situations where practi . cal, hands-on training has been developed as part of.the
~
lN -' LJ 6
requalification program. In-plant training done over the past (V^T' L two years includes training on circuit breakers, the emergency diesel generators, the remote shutdown panel, the loose parts monitor, and the plant process computer.19/ Newton et al., ff. Tr. 32,409, at 55-56.
- 44. The BPTS was delivered in February 1984 and is now integrated into the licensed operator requalification training program. Id. at 57; see also Committee, ff. Tr.
31,749, at 9-10; id., Special Report at 61. The Reconstituted OARP Review Committee believes that the BPTS is the most advanced basic principles trainer.for licensed operators in the United States. Committee, ff. Tr. 31,749, at 15; see also id., Special Report at 59-64. Furthermore, GPU Nuclear is one of only three U.S. utilities of which the Committee is aware that gives its operators training on both a BPTS and a full-scale simulator. The BPTS is intended to teach operators basic prin-ciples of neutronic behavior, reactor kinetics, thermodymanics, 19/ The T&E Department has conducted in-plant classroom training in conference rooms in the plant to reduce time losses that result from transportation to and from the site. The T&E Department has also taken advantage of facilities at the GPU , Service Corporation building in Reading, Pennsylvania to con-
. duct requalification training for licensed operators. The op-erators have been shown the system power grid distribution cen-
.ter and provided with training on the role of and their interaction with the system dispatchers.- Newton et al., ff.
.Tr. 32,409, at 56-57.
4
\ _, /'
b'- _ _ _ _ _ _ _ _ _ _ _ _ . _ _ . - _. -
- r
-'y heat transfer, fluid flow, and PWR operational characteristics.
~
The BPTS also provides the ability to train operators in the use of the control room pressure-temperature (P/T) plotter which allows operators to diagnose P/T behavior. This replaces the formal training provided on the computer-aided instruction system, although this training tool is still available for self-instruction by the operators." Committee, ff. Tr. 31,749, at 16-17; see also id., Special Report at 59-64; see LBP-81-32, supra, 14 N.R.C. at 449 (E 188) (discussion of computer-aided instruction system).
- 45. The BPTS simulation of plant operation is based on full scope simulator software of a nuclear generating sta-tion similar in design to TMI-1. It provides the capability to-simulate in real time normal and abnormal conditions, both transient and steady state. The trainee console consists of a vertical display panel and horizontal control panel. The dis-play panel contains a mimic drawing illustrating TMI systems and appropriate actuation switches, parameter display meters and annunciators. The control panel contains major controls and some parameter displays. Three CRT's are also available for trend display of plant parameters as well as selected cal-culated data, such as~ spatial xenon concentration or axial and radial core power distribution. An instructor's console with a CRT provides a means of controlling and monitoring operation of
c'x the BPTS operation. The instructor can utilize such features (
)
as initialization to one of 30 plant conditions, backtrack or ability to return to prior conditions, manual time delay or in-sertion of malfunctions, fast time--slow time capability, and control of certain functions external to the control room. Newton et al., ff. Tr. 32,409, at 57-58; see also Committee, ff. Tr. 31,749, at 9-10; id., Special Report, at 61. We note that the BPTS requirements were established by GPU Nuclear en-gineers and instructors. GPU Nuclear personnel performed the job analysis for the BPTS that led to the specification of learning objectives, which resulted in designs for panel lay-out, layout of control rod section, etc. Thus, the simulator was designed to Licensee's specifications. Newton et al., ff. Tr. 32,409, at 57.
- 46. Dr. Kimel has praised the BPTS as a training de-i vice because of the flexibility produced by actual analytical models programmed into the computer circuitry as opposed to other simulators in the industry which are primarily based on table look-ups. Tr. 32,080 (Kimel). According to Dr. Kimel, such flexibility enables the trainees "to gain a real feel for the actual fundamentals based on those analytical models." Id.
Dr. Kimel cites the innovative thinking of GPU Nuclear man-agement, and in particular of Dr. Long, as responsible for the BPTS. Id. Dr. Kimel's comments about the flexibility of the I
1/~T' BPTS and.the' initiative of management apply equally to the rep-LI
' lica simulator project. Tr. 32,120 (Kimel); Tr. 32,929-930 (Newton). See 11 52-55, infra. Dr. Christensen describes the BPTS as Dr. Lon 's successful response to the criticism of over-memorizati(n as a phenomenon in licensed operator training. Tr. 32,081 (Christensen).
- 47. We concur with the conclusion of the OARP Review Committee that in the development of'the BPTS, GPU Nuclear has
' demonstrated impressive design engineering capability and the ability to formulate instructional plans on how to integrate the BPTS into the training program. See Committee, ff. Tr.
31.749,.at 16. In general, the Board shares the Committee's enthusiasm for the EPTS. We believe its purchase, design, and integration into the TMI-1 training program reflect man-agement's commitment to the use of state-of-the-art technology in its program. See Tr. 32,119-20 (Kimel). It also shows man-
'agement initiative and innovation.
- 48. The replica simulator is scheduled for delivery
'in' late 1985. Until then,.the simulator at PSI's training cen-ter'at Lynchburg, Virginia continues to be the best' facility.
for simulator training for TMI-1 operators. The PSI (formerly-B&W) simulator is-used for initial training,-maintenance of
. skills and special training requirements. It is also used,
( m o
n r C(~5; contemporaneously, by senior members of TMI Operations staff to
- d _ - assess operators' capabilities. In addition to its annually 4
scheduled week of simulator training, GPU Nuclear has conducted
- extra training at the Lynchburg simulator in Abnormal Transient
- Operating Guidelines ("ATOG") and steam generator tube rupture scenarios. . Commit, tee , ff. Tr. 31,749, at 17. As described in our initial design decision, see LBP-81-59, 14 N.R.C. 1211, 1255 (11.709-710), the ATOG philosophy is a " symptom-oriented" rather,than " event-oriented" approach to responding to unanticipated plant transients. In anticipation of restart, each TMI-1 operating crew also completed three additional days of; refresher training at the Lynchburg simulator in 1984. Com-mittee, ff.-Tr. 31,749, at 17.
- 49. Quality control is exercised by the Training De -
partment over the content of the PSI simulator training pro-' gram. ' Committee, ff. Tr. 31,749, atL16; see, e.g., Tr. 33,288-89(Christensenobservanceofmodificationtoprogramab
~
the simulator to correspond to extremely'recent plant modifica-tion). 'The combination of the BPTS, which teaches-theory,.and the' full-scale simulator,Ewhich provides for practice,'consti-tutes an excellent and thorough use of simulation technology in Lthe-training;of TMI-1 operators. See Committee, ff. Tr.
.31,749','atil5-17.
a LJ .
p-
- 50. Because TMI-1 has undergone several heatups and
()'s cooldowns as part of hot functional and steam generator testing, the operators also have been provided with experience in the operation of many aystems and equipment at hot operating temperatures and pressures. See id. at 16. Also, of course,
- with fuel-in the reactor, many TMI-1 systems must be checked and tested. In addition, a restart qualification program has been developed that requires each operator to complete specified evolutions which familiarize them with component operations. See 1 174, infra. In addition, 28 specified re-activity manipulations are conducted at the plant or on a si-mulator as part of the requalification program. Id. at 16-17.
All of these activities provide additional training in plant operations.
- 51. A control room mockup has been installed in the training _ center-and is utilized for procedure reviews, oral'ex-
"aminations, and classroom systems training. -The mockup, which
' was previously located in the TMI-1 turbine building and.used
~
in' human factors reviews, is a full-scale plywood model of the L console and control panels and has.been renovated with new pho-tographs of the panels, which showfmeter indications-and.
. readings tct approximate full power operation. -Newton et al.,
ff. Tr. 32,409, at 58. The. mockup has proven'particularly use ' y ful ia^ATOG training,Lenabling operators to' gain'inc'reased 5 9 ..
^
g -
. t
(~') familiarity with the procedures and locations of controls. Tr. LJ 32,905 (Leonard). The operators review the ATOG procedures with instructors and perform a step-by-step walk-through of each procedure and reference the action controls displayed on the mock-up panels. Committee, ff. Tr. 31,749, at 17. Dr. Christensen described a valuable exercise he observed on the mockup, whereby an instructor called on various students to go to the mockup and identify the proper controls to handle the particular transient with which they were dealing. Tr. 32,077-78 (Christensen). The last replacement class favorably received the mockup training; the trainees appreciated the con-trol room atmosphere as well as with the chance to observe the controls during breaks. Tr. at 32,905-06 (Leonard).
- 52. The full-scale simulator is scheduled for deliv-ery in December of 1985, acceptance testing (validation) in January-February of 1986, and actual operation in training dur-ing the second quarter of 1986. Tr. 32,932-33 (Newton);
32,940-41 (Newton). The replica simulator is being manufac-tured by Singer-Link's Simulation Systems Division and will du-plicate the appearance and configuration of the TMI-1 control room. It will provide a complete and accurate simulation of the systems monitored and/or controlled in the main control room and'will display normal plant operations and abnormal con-ditions (malfunctions). The Associated instructor's station m
m
.(~N console provides the instructor with the means to monitor and
\
control training through the use of CRT's, keyboards, and asso-ciated equipment. There will also be a hand-held remote con-trol device which will allow the instructor to manipulate the major instructor's station control features without returning to the CRT keyboard in response to student activities during the course of an exercise. Newton et al., ff. Tr. 32,409, at 58-59.
- 53. An extensive specification for the replica si-mulator was prepared by Licensee and, following an exhaustive review of the bids, Singer-Link was chosen, largely on the basis of advances that they had made in plant process software modeling. The TMI-1 replica is a first-principles simulator, which means that a. specific malfunction does not have to be pra-programmed into the software in order for.the simulator to respond accordingly. The replica will be predictive rather than programmed, such that unanticipated or heretofore unrecognized transients will be capable of being simulated.
The most important advancement was the development of the advanced core model,.which implements the complexities of. core physics and thermohydraulics into 24 radial and 9 axial re-
'gions.20/ Most of the current' generation of simulators have, L 20/ This model permits-high iteration rate, yields a more o accurate depiction of diffusion effects, and providesLgreater.
(Continued Next Fage):
.s l
) -
(~ , not used first principles models and the off-normal behaviors ij have been compared with (or actually used data generated from) the worst case assumptions used in the Final Safety Analysis Report hypothetical accident analyses. Id. at 59-60; see also Tr. 32,929-30 (Newton).
- 54. The adequacy and availability of a full replica simulator as a condition to restart was litigated in the ini-tial management proceeding. LBP-81-32, supra, 14 N.R.C. at 468-70 ( V 252-257), 570 (V 551); see Tr. 32,121-22 (Chairman Smith). Nevertheless, the adequacy of the program, prior to and after installation of the replica simulator, was pursued in the remanded hearing on training. See generally Tr. 31,875-77; 32,072-73; 32,078-81; 32,119-27; 32,768-70; 32,800-03; 32,927-33; 32,940-43.
- 55. As with the BPTS, Licensee has provided consid-erable technical input into the acceptance criteria for the ,
replica simulator. Tr. 32,926-28 (Newton). Beyond its training capabilities, the simulator may be employed to (Continued) accuracy and precision in calculating local anomalies and asym-metric conditions. The primary advantages gained are in the area of modeling of potential fuel failure from locally high heat flux, and more accurate depiction of core flux patterns and the thermohydraulics of accident conditions. Newton et al., ff. Tr."32,409, at 59-60.
. experiment on modified procedures before implementing them.
Tr. 32,931 (Newton). In particular, the simulator will be able to conduct transient analysis in anticipation or at the time of a transient. Tr. 32,931-32 (Newton).
- 56. Until the replica simulator goes on line, si-mulator training at TMI-l will depend on the BPTS and the PSI
'(B&W) simulator. The Board, UCS, and the NRC Staff, according-i.
ly, inquired in some detail into the potential problem of nega-tive transfer or habit regression. Tr. 32,124-27 (Judge Lin-
- enberger); Tr. 31,875-77 (UCS); Tr. 32,072-74 (MRC Staff).
- Negative transfer essentially is the transfer of incorrect sknowledge, based on use of a simulator, to the actual operation of the plant. See Tr. 32,125-27 (Christensen). According to Dr. Christensen, the differences.between'the Lynchburg si-mulator and TMI-l are sufficiently noticeable and appreciated to keep the problem to a minimum. Tr. 32,126-27'(Christensen).
f" Moreover, as Dr. Christensen points cut, negative 1 transfer is unlikely because of Licensee's programLto' assure consistency between the TMI-l plant response-and the Lynchburg simulator.
- - Iji . Moreover, formal- and 'inicema? debriefings occur during1 PSI - _
-(B&W) training to' eliminate any limited:neaativeLtransfer-prob 1
~
' lems ' that' may occur; Tr. 31,875-77 L(Kelly). UCS' L expert .-wit -
_ ~ ness,;Dr. Regan, stated,that. people ~ tend to become: preoccupied
-with' ~ creating a simulator physically 1 identical to an c gg-V.
4 I
* . > .1,
_s
{J operational setting at the expense of budget and training effectiveness. Tr. 32,770 (Regan). Dr. Regan believes that a simulator, by virtue of its design as a teaching tool, is peda-gogically preferable to operational equipment as a training de-vice, and he maintains that a simulator need not have phy'sical fidelity if it elicits behavior comparable to what an operator
. would experience in a real situation. Tr. 32,768-69, 32,80d-03 (Regan). Exactly why a replica uimulator is less effective as a training device than a non-replica one is unclear from Dr.
Regan's testimony, see'Tr. 32,770 (Regan), b t what is clear from the record is that the value to be gai..< from Licensee's present and planned future uses of simulators far outweighs any burdens of negative transfer.
- 3. Impact of Cheating
- a. Management Responsibility for Cheating
- 57. ALAB-772_(footnote 48) refers;to.the Licensing Board's concern about whether the Vice President of Nuclear-As-surance, Dr. Long, understood his responsibility for the cheating that occurred at TMI. At the time of'the cheating, Dr. Long was the Director of Training and Education. ALAB-772, sup ra ,- 19 N.R.C. at 1233.n.48. Licensee's post-accident :
1 upgrading of training should=have included measures to prevent
. . cheating on examinations, such as formal proctoring a'nd review
- ~46-l'h ,
.al F
2
l l l of examinations for evidence of cheating. Dr. Long testified (^}: v that between the time of the TMI-2 accident and the discovery l of cheating, he overlooked the need to critically review the processes in use to prevent cheating during the examination and testing. activities of the T&E Department. Long & Coe, ff. Tr. 32,202, at 2; see also LBP-82-56, supra, 16 N.R.C. at 296-97, 355-63, (11 2063-66, 2321-41).
- 58. The investigations and reviews of training which followed the TMI-2 accident generated a large number of recom-mendations. These recommendations focused on numerous ways in which various review groups felt nuclear plant training pro-grams, particularly for licensed operators, should be changed.
None of these recommendations addressed the need for control of the. examination process. Thus, Licensee's failure, for which Ihr. Long takes responsibility, must be evaluated in-the context
. of the attention that was being focused on responding to the post-TMI-2 accident recommendations. Long & Coe, ff. Tr.
'32,202, at 2.
- 59. A primary cause of cheating was-the failureEto
-provide full-time proctoring for written examinations. Id. at
- 3. .Dr. Long testified that he does not believe that this-fail-ure stemmed from any disrespect by.the TMI instructors for-the examination process; rather, he feels there was a belief'among r~T N-u
l the training personnel based on their experience in educational
.{ }
and training programs and their knowledge of the operators, i that everyone recognized that one is expected to do one's own work on an examination and that cheating not only is unacceptable, but results in penalties i'f a'pprehended. Id. A corollary of this belief was the perception at the time that the primary reason to have a proctor present during an examina-tion was to provide clarification for students for questions they might have during the examination, not to serve as a da-terrent to cheating. Id. Dr. Long admits that in retrospect, these beliefs, which he shared, were naive and should have been challenged, particularly in light of the unprecedented require-ment GPU Nuclear and the NRC imposed that all licensed opera-
' tors would have to undergo an additional complete NRC license examination ~to continue in their positions as licensed opera-tors at TMI-1. Operations and Training management personnel should have been monitoring closely the attitudes and concerns of each individual license holder to ensure that management un-derstood and addressed any fears, uncertainty,' or gaps in the operators' acceptance of the importance of the NRC' exam'and their preparations for~it. fd.
L
- 60. Given the personal 1 pressures.on-individuals which might lead to attempts to cheat, Dr. Long acknowledges,.
management should~have clearly. articulated the guidelines for.
.rs- .g
(_ taking examinations and should have been looking for any evi-dence (e.g., attempts to cheat- feelings of discouragement) which would have indicated that individual license candidates were experiencing difficulties. Also, Dr. Long states, the GPU Nuclear training program should have been structured to rein-force the view that tests are one's own work product. It was not. For this, Dr. Long takes responsibility. Id. at 4.
- 61. The Board notes that Dr. Long is not the only member of current management who accepts responsibility for the cheating incident. Mr. Newton, who was Operator Training Man-ager'at the time the cheating-incidents occurred, acknowledges that he had not focused his attention on procedures to prevent or detect cheating. His contributing l responsibility for..
failings of the training program which led to'the cheating in-cidents was reviewed with him by Dr..Long, Dr. Knief, and
. Mr. Hukill in a number of discussions over the-past several years. In the company's. judgment, Mr. Newton fully-appreciates the. ways in which the operator training program and personnel bear some.of the responsibility for-the cheating that has oc-curred. Id..at 33;-see also LBP-82-56,Esupra,.16 N.R.C. at-358-59.
- 62. Finally, the Board shares Dr. .Long's observation
'that the individuals who chose to cheat also have to accept t6e c
7.
=wi '
[E .A
l I l l
. responsibility and consequences of that choice. They could have, and should have, requested additional help from their Operations or Training supervisors or indicated in some manner that they were not ready to take the exam in question. Had they done so, Dr. Long believes Operations or Training would have been responsive and, for example, would have provided the
-extra training needed to prepare for quinzes and examinations.
Long & Coe, ff. Tr. 32,202, at 4.
- 63. The Board concludes that Dr. Long was candid in his testimony and that he-accepts his responsibility for the cheating that occurred. The Committee also observed and noted management's keen sense of responsibility for the cheating that occurred. Committee, ff. Tr. 31,749, at 6. These traits re-flect well on both Dr. Long's character, and on his qualifica-tions to serve as.the senior manager in the company, below the Office of the President,. responsible for the training of=the
'TMI-1 licensed operators. In short, the concerns about Dr'. Long raised by the Licensing Board in its, partial initial-decision and reflected in footnote 48 of ALAB-772 have been satisfied.21/.
21/. s TMIA challenged the effectiveness of-Dr. Long's response-to the TMI-2-generated ~ recommendations. See,-e.g., Tr.
~32,219-52.(Bradford cross-examination of Dr. Long). As we pre-
_viously_ observed,1TMIA verged on default of its participation (Continued Next_Page) 1p v ,
,)- b
=
.; rQ:
- 4s.
~
l (Continued)
- 'in the training issue. See 1 9, supra. Id. We noted that in -
the particular instance of TMIA's cross-examination of Dr. Long, TMIA had unabashedly pursued issues other than the one
~ issue -- management. integrity -- which TMIA,had agreed.would be Lits only area of " lead" interest. See, e.g., Tr. 32,234-36,
. '32,311-13 (Chairman Smith).
Irrespective of the problam of default, TMIA has failed to establish a foundation for the conclusion it would have us
-reach that management provided a mere paper response to serious attitudinal problems among employees, evidencing a lack of in-tegrity. 'See Tr. 32,246, 32,265 (Bradford). These problems allegedly were reflected in TMIA Exhibits 3A-M, which were 13
-attendance forms filled out by training instructors in the 1980 time-frame on which a. space was provided to. comment on a. par-
- ticular-session of training. TMIA points us to comments some of'which' reflect dissatisfaction of the trainees with specific
^
; sessions of. training. _The comments are attributed to:several
, recognizable' factors,_all of which have been addressed by Licensee. Five of the seven forms on heat transfer fluid flow-
'and thermodynamics, .and two of the remaining forms were from.
the same crew forcthe same week in October 1980. Tr. 32,950-
-(Newton). The Training Department was having some problems with this crew,.and with one of the individuals.in particular.
~
s Tr. 32,951'(Newton)- . The' Training Department also.was having.
^
< problems'with that particularfinstructor. Id. Over half-of' the forms-relate:to heat transfer,- thermodynamics,=and fluid; flow:-- new subjectEareasirequired after the TMI-24 accident.
LThe operators were having difficulties understanding 1how;these
" subjects related-to their. jobs in;thefcontrolcroom . Tr.~32,952 '
- (Newton). ;In addition', three contractors were responsible for fallibut one of the evaluations, andtTraining:haschad: difficulty Lin_thelpastiintegrating. contracted-instructors into-the' pro-tgram/Jespecially for; licensed-operators..- Tr. 32,9541(Newton) .
eFinally, all:but.three'of--the; forms reflectcsessions that in-
- fcluded both TMI-11and-TMI-2 licensed-and auxiliary operators- .
;("AO's"). (Tr. /32,956E(Newton). Mr.~ . Newton suggests : that: a.
p :certain percent'ageLof'the negativ'e commentaries:may be:by the' AO's,Jwho did:not see anyfsignificantzapplication-ofsheat' e _ ztransfer and reactor theory to ~their : Job Gd. . ;(The-Trainingf Departmentihas since responded tocthis. problem.by[ creating!a- '
- tseparate.requalification program for.the-AO'.s,; focusing morelon:
(plant specifics. Id.); _: . :During the hearing,0Mr; Leonard addressed whether.the TMIA
- ( (Continied NextLPage)- '
^
Mi ,
~~: .
I h#' b. Management Response to Cheating
\--
- 64. The two principal areas on which Licensee has focused.in its overall response to cheating have been management-personnel communication and exam security. In gen-eral, the' Board agrees with the OARP Review Committee that 1
Licensee. presently has in place working and demonstrably effec-tive communication practices between management and the persons involved in the licensed operator training program, including both the training staff and operators. See Committee, ff., Tr. (Continued)
" exhibits reflected.a generic attitudinal problem with the shifts. He reviewed one hundred thirty other training atten-dance forms from' August to-December 1980. Tr. 32,957 (Leonard). Mr. Leonard found that only five other forms in-. .
cluded a comment on poor operator attitudes, and they were not-. periodic but pertained to a certain topic (heat transfer). LTr.
~
-32,958-(Leonard). TMIA Exhibits 3A-M therefore reflect iso-lated' instances in an isolated time. period; .they do not support the. existence of a generic problem with operator attitude to-wards training. Id.
Finally, Dr. Long explained that while he had not seen the
- particular documents .shown to him 'by TMIA, lum did know, and it was important for.him to know, that the instructors and man--
agement under him were aware'of the problem with the heat transfer classes,Lin particular,'and were,taking steps to'cor-rect-the problem. Tr. 32,269 (Long). -TMIA thus is attacking Dr. Long for failing to review documents describing;a problem of which he already was aware. TMIA also;is attempting to take l advanta'ge of a period,of corporate self-analysis and self-L~ ^ criticism to argue that the paper generated was_no more than' paper.~ Tr. 32,312-(Chairman Smith.-). TMIA's argument,'however,- collapses 'cnt itself: the very fact that. paper was generated
-establishes that. Licensee-had an effective procedure in place
~to identify problems.
See Tr. 32,271 ~ (Ch21rman Smith) .
'f s - 'O^ '
o I (') - 31,749, at 22-24, 29; see also id., Special Report at 75-81. L/ ^ The Board also concurs with the conclusion of the OARP Review
~ Committee that GPU Nuclear has taken a necessary precaution to prevent future cheating incidents by instituting an elaborate exam security system. See Committee, ff. Tr. 31,749, at 6; see also id., Special Report, at 25-27, 55-57. The OARP Review Committee, for one, has "never seen such stringent examination procedures." Committee, supra, at 6.
- i. Communications
- 65. The initial Licensee management response to the cheating on the NRC exams was focused on the " mechanics" of the T&E Department examination and testing processes. Long & C'oe, ff'. Tr. 32,202, at 5. Immediately after the announcement of the cheating incident and.during_the several months of subse-F quent' investigations, Dr. Long was directly involved with the T&E Department managers and supervisors-in analyzing:and developing appropriate responses to these events. Id. On sev-eral occasions Dr. Long met personally with the entire staffs.
of the. Training Departments at both TMI and Oyster Creek.: These' meetings were basically question-and-answer discussion sessions to clarify issues and gain' acceptance for and commit-
-ment to enforcement of the stringent examination control proce-
; dures Licensee was implementing. Id. Initially, some rt
(")t
\
u 4
f~') . instructors and trainees felt that the contents of the examina-
%J tion procedures were an over-reaction to the cheating incidents and that T&E was now unfairly assuming that everyone was a potential cheater. Through the open discussion of such con-cerns, management was able to persuade both instructors and trainees that the company had a special obligation to adopt practices which would prevent any recurrence or unjust accusa-tions of cheating. Id.
- 66. Contemporaneous with the issuance of the Special Master's Report and the Licensing Board's 1982 decision, Licensee followed up on its initial response with additional
-activities, including the use of cutside reviewers, to further respond to the " lessons learned" from the whole sequence of events brought out'by the cheating hearings. The Office _of.the-President was actively involved in these activities and met
. quarterly with the Director-of T&E and the T&E Managers to en-
-sure active follow-up of. identified problem areas. Through analysis and discussion, management, including Dr. Long, the
-Office of the President',~and the' Training and Operations de-1partments identified a-number of root cause concerns which had to be addressed. See Tr. 32,206'(Long). _These_ included the need to restore and maintain credibility in'the training pro-
, grams. The' integrity of'the entire trdining process was re-viewed and more formal procedures developed for test
' n
):
h r {L preparation,' instructor evaluation, program planning, and training interfaces with all the training " user groups." Although Dr. Long recognized from the beginning of his assign-ment as' Director of T&E that instructors can and do influence employee attitudes, additional steps were taken to stress this impact-to instructors and, particularly, to identify clearly the value of-the training process to all employees. Long & Coe, ff. Tr. 32,202, at 6.
- 67. A significant' step in restoring and maintaining credibility in the management of training and operations has been the activity of the Vice President of'TMI-1, Mr. Henry Hukill. Atua minimum, each licensed operator i:s interviewed annually.by Mr. Eukill, who specifically interviews all. _
licensed operator-candidates prior to certifying.them for their initial = licensing or relicensing. .The following subjects are
' discussed and.. instructions'and' guidance given to the operators
!during these. interviews: importancefof their. duties to the?
~
_ . safety and health- of :the public and their fellow employees;
; requirement L for procedural; compliance;. importance of the - NRC ' '
examination process in licensing operators;Iduties and' respon -
- sibilitie's'of-Licensee'and its employees'as.a regulated indus -
try;;the needsfor honest'y andiintegrity;in' all! aspects of.plantL s . .
' ~
. operation and maintenance including training'and;the'examina-
, Etions associated therewith; the cheating;that occurredyin-1981~,.
p ?" , . ( . ->
>, n 4 -
-55 .
m > - <y . S .
; h. 4 I i a
;. , o
^
m A 1 .. (} including possible causes therefor and the corrective measures taken; the requirement to address openly all nuclear safety-related questions or problems with management, and if they are not satisfied with the answers thereto from management, their personal ~ responsibility to bring them to the attention of the x- :NRC; current events, schedules, problems and~ incidents; and the difference between honest mistakes and intentional / willful vio-lation of procedures and rules. Included is a discussion of 4 the bases for procedures, rules, and regulations. Each opera-tor la given the opportunity during the interview to ask ques--
'tions or raise issues and/or problems with the Vice President.
.Mr..Hukill attempts to resolve, through his Staff and Training,-
1 any; issues.or. questions raised by the operators. Id. at 6-8. 468. Another step in restoring and maintaining credi-bility in the training: programs and. management commitment to quality training has 'been .the - active program' of both w>
~
7: o unannouncedLand ann'unced visits to' observe-classroom-delivery. of: training. TMI operator training is " audited".by both
~
Training and-Operations' management and the Vice Presidents'of: LNu'learfAssurance c and TMI-1. These audits / visits provide man-agement-visibility and first-hand observation and evaluation:of.
' training.
The;results and' conclusions of audits are,.for~the-most.part', fed back toLTraining;except/forfthose' audits offspe-:
, icialDinterest where1 managers feel thattthey have=seen'what they j
~
. 2: > 4 , JrSc . O
\
;_d ' " y r
---M
_ m ftf came for, are satisfied with the results and believe there is Thus, GPU Nuclear man-no further need for communication. agement makes frequent visits to the TMI Training Center and the visits are visible to the students in the classes. The
. fact that management is there and that students, including op-erators, can have first-hand discussions with management about their training provides the students with concrete evidence of management's ongoing concern that the training activities are carried out effectively. Id. at 8; see also Committee, ff. Tr.
31,749, Special Report at 45.
- 69. Another method of keeping management informed regarding the implementation and effectiveness of the training programs is the submittal by the T&E Department of bi-weekly "significant events" reports which highlight to the Division-Director and Office of the President such things as training attendance, program initiations and completior.s, licensing and requalification exam performance, and simulator training activ-
=ities. Long & Coe, supra, at 9.
- 70. In August of 1982 Licensee _ initiated, during_
each week of requalification training, a'one-hour " Management Interface"_ meeting for operations, maintenance,- and technician personnel attending training. This meeting is designed-to in-
- form employees of programs and policies being 1 plemented.that-
.n
'm.]
-x - m ..- ,
/
7 M
+
jaffect their daily work. patterns, and to assure them that man :
.agement is aware and appreciates the end result of changing policies-on the worker. One of the following three people at-
.tendsLeach of these meetings: the.Vice President TMI-1; the Operations and Maintenance Director; or the Plant Engineering Director. A second manager, typically from a support organiza-tion ~(e.g., Training, 9A, Rad Con, etc.)., also' attends. These-manageis address the status of situations in their respective
.sreas and-respond to questions from the trainees in give-and-i itake discussions. Id. at 9; see also Tt. 33,079-80 (Newton).
T Mr. Hukill als'o sits down with the operators when a significant
' event occurs. Mr. Hukill explains-the reasoning and the conse-
'quencesLof the Licensee's actions, and allows theLoperators to h ; commen't. Tr.L32,938-39 (Ross).
~
p '71. .-TMIA challenged the c efficacy of Ethe. Management P ' Interface meetings, based on a document:suggestingtone incident
- where'Mr.:Hukill may have, failed.to respond. encouragingly to a.
E ~
; maintenance worker who. stood up-in a Management Interface seet-
* 'ingjand made a serious safety allegation. See TMIA Tr. Exh.
1.'22/!iMr.LHukill'did.not testify.nor was Licensee given,any;
~
~ s c22/.?TMIA Tr. Ex. 1; which was-not admitted.into. evidence,-lTr.
, e r ~31,995-96 (Chairman Smith), appears.to'be.a package-of m'ateriali
'N' 'related1to an; incident in which:a TMI-l maintenance worker, "i - j during:a: Management. Interface meetings alleged that:he was 4 '
- being required:to.. perform. maintenance work-for which express procedures were'not provided. The-exhibit-includes = memoranda:
~
~ *about. management's handling of the man's! allegations.
. n-. - W' y+ o n .s
';f.: g _ <
~=
7.. 7 advance notice of-this subissue by TMIA; therefore, Mr. , , Hukill's perceptions and experiences about this incident are
- not known. Although it is unclear to the Board whether man-agement was inappropriately intimidating and thereby
'discouragingohthefreeflowofinformation, it is very clear that!L'icensee must maintain a difficult balance of encouraging employe'es to'use the " chain of command" to communic ~ ate to their management while providing for management access outside of JE this chain. As Dr. Kimel suggested, the very fact that TMIA Tr..Exh. 1 exists evidences the availability of another forum
'between management and employees for information flow. Tr.
. 31,992-93 (Kimel). The Board believes the. Management Interface
~
meetings _are important,fwe' recognize-that they were established at Mr. Hukill's-initiative, Tr. 33,079-80 (Newton), and.we' urge Licensee to continue to utilize them.to improve existing work
. practices,_ training _ programs and morale.
72.- Beginning in-the Spring of 1983, Dr. Long initi-ated NAD Employee Meetings _for the. purposes of (1)-encouraging-
~
and fostering better understanding of NAD employees regarding;
~; activities of'the.various Division Departments,.and (2)1enco'r- u aging and-improving NAD~relttionships'with other Licensee divi '
~ sions. :The meetings have'been well-received'by: employees and havaibeen continued at approximately-six-month intervals. A
~
memorrndum announces each,grou'rof p meetings and_an: agenda
,c :
- D o c 4
prepared for the meetings at each location identifies the speakers.23/ In the first three rounds of meetings, there were five speakers, one from each NAD Department and a division Di-rector from another division. Employees also had an opportuni-ty.to interact'with Dr. Long through questions and answers and discussion. Long & Coe, ff. Tr. 32,202, at 9-10.
- 73. Yet another activity to keep management informed and in touch with Operations personnel is the attendance by se-nior managers from Nuclear Assurance, Operations, and Training
'ati the simulator training sessions at Lynchburg to evaluate training being conducted by PSI (B&W). This allows management t'o evaluate the quality of PSI's training at the simulator as well as to evaluate licensed operators' and licensed operator candidates' performance on the simulator. Ici. at.10. The first week of a requalification training cycle'at the PSI (B&W) simulator is attended by instructors and management representa-tives in order to identify and correct any problems with the training before the operating shifts begin their training. Tr.
32,349-51.(Long); Newton et al., ff. Tr. 32,409, at 21; see also Tr. 32,481 (Leonard). 1 23/. For example, in the Fall 1984.round~of' meetings, NAD man-agement gave employees training ~in brainstorming techniques and had them develop lists of brainstorming ideas for improving the
' effectiveness of the-NAD work activities. . Employee committees are now evaluating these brainstorming idaas to recommend those which should be further developed and implemented. Long & Coe,
-ff. Tr. 32,202, at 10.
r~m .Q.
f~'). '7 4 . Several activities which began in 1980 have been u/ refined and formalized and continue to significantly aid commu-nications between the Training and Operations Departments. To ensure that the training content is relevant to the needs of the. operators, Operations management approves training pro-grams, schedules, and program content -- including learning ob-jectives,-- prior to the conduct of requalification training. Operations (along with Technical Functions and Training) also reviews the behavioral learning objectives contained in the Operations Plant Manual ("OPM") discussed infra, at 11 113, 176, which are used as a basis for developing classroom objec-
.tives. Newton et al., ff. Tr. 32,409, at 36. Management has learned that the more mutual involvement occurs in operator training, the more focused that training becomes. Operators-then are more receptive to their training. T.lso, at.the end of each requalification training week, the shift foreman or super-1 visor from the crew that is.just completing training meets with the Supervisor, Licensed Operator Training, the Supervisor, Non-licensed Operator Training,-the Operator Training-Manager, and either the shift foreman or the supervisor _from the crew
.. entering training the next week. These individuals review-the week'of training and determine what needs to be improved or-em--
, phasizedifor th,e following week. These meetings have helped
; training. focus on more specific needs of different. crews I >
..g~
- \,,/
a f . regarding the same subject areas. Management personnel respon-
f'/$. s_
sible for training also have found that they sometimes develop a common thread over six weeks useful to them in working to im-
~
prove the training the next time it is scheduled. Long & Coe, ff. Tr. 32,202,.at 11; see Tr. 32,350-51 (Long). The Operator Training Review Team, discussed at 1 198, infra, provides an additional line of communi6ations between the Training and -
.Oper'ations Departments.
4
- 75. The Board finds that all of the activities cited
^
'above reflect an ongoing GPU Nuclear management commitment to find ways to stay' abreast of the real.and perceived concerns of.
Lits employees. We are. satisfied that management has taken se-
-- riously the " lessons learned" from the cheating hearings and will continue to seek ways to maintain the credibility.and in-
'tegrity of the training-process.and the effectiveness:of'its contribution to overall'TMI-l plant operations activities.-
ii. .ExamESecurity
- 76. . Another principal'part of Licensee's response tol t ch' eating has been its. effort to insure ~~that-individuals-would I'
'never agAin'be infa position to be tempted-to cheat.
.The_GPU.
~
~
Nuclear Control of Examinations p'rocedurelis a detailed process. that clearly communicates:to all parties Licensee'sEcommitment _ Ltolthe security 1of exe.ninations r and the : responsibility of;
.pg N
ff E
- d
'f .
c everyone involved in insuring the proper conduct of such exams.
~(O~y.
Long & Coe, ff. Tr. 32,202, at 19.
- 77. Examinations are classified in four basic secu-rity categories: Category 1 - written examinations where grades
. serve'as a basis for certifying satisfactory completion of training; Category 2 - written examinations used as rapid feed-back to assist the examiner in assessing the effectiveness of training; Category 3 - oral examinations conducted.by an indi--
7 vidual examiner or a board; Category 4 - practical factors ex-aminations where' evaluation of skill levels is based on perfor-mance of actual or simulated tasks. Id. This division into
' categories allows for different levels of security and adminis-trative controls. Security of Category 1 examinations applies from the time the questions are assembled until final-adminis--
tration and grading. Security also applies to question and an-swer banks-in this category. Category 1 examinations are re--
- used without written approval-by the Manager of Training.
- ' Access to Category 1. examination-materials is restricted on.a'
. need-to-know basis and the policy also inclu' des provisions.for e ' locked storage, assuring security passwords for' data processing systems, limited access to exam materials, numerical = accounting
. of exam copies,~and an established question bank. In addition,
., there must be a 40% content difference-for Category 1-consecu-'-
~ tive weeks'utraining=(cyclic)' exams. Non-cyclic training-
- l ~ ~
y, 4
7-. . . - I 4
' requires multiple. exam versions differing at least 50% in con-tent. The procedure also identifies the methods of trans-porting examinations between sites and the shredding of surplus.
examination material. The security for Category 2 exams applies from initial assembly through final gra' ding. These exams-may be reissued to subsequent classes. Category 3 and 4
. examinations are less restrictive in their security. .Id. at 19-20. Administration requirements and specific instructions for proctoring are clearly identified by category as well.24/
- Detailed instructions for proctoring responsibilities are given.25/ Id.
- 78. Detailed instructions are given to the students
- regarding'their conduct in the~ exam. Students must also sign a,
.24/1 Each. category 1 examination.has a coversheet that
~
identifies the following information: examination title.and' location where administered; whether the examination is open-
- book or closed-book; authorized reference 1 material;_any special instructions; title of each section.of_ examination; point value of each'section; total point value ofLexamination; time limits -
.for completing exam; minimumLacceptable passing grade. lid. at -
20-21;1see, e.g.,-UCS Tr. Exhs. 21-27. 25/ 1The proctor must insure that. student work surfaces are
,, clear of unauthorized materials;.. seating--assures maximum:
; workspace for each' individual-by: separating students as'much"as'
- possible; no unauthorized information is available, e.g., from-blackboards or'wallJcharts; authorized reference materials are ifree of~any unauthorized. markings; a seating chart'is made fors u selected. examinations; examination. cover sheets are reviewed lwith the students. - Atcleast one proctor.must be'present at~all times and student-movement is minimized. -Long'&-Coe,-ff. Tr.
- 32,202,.at'21.
wp N f T
.f 'E statement that indicates their understanding of the examination d.
instructions, including an oath that the work on the examina-
~
tion is their own. Specific instructions are provided to those grading-the exams and Category 1 examinations are graded-in
-accordance with approved answer keys. A plus or minus two per-
-centage points variation from the passing score is reviewed by supervision and the Operator Training Manager. Examinations are:also_ graded in a manner that provides specific attention to detecting suspicious parallelisms among various examinations.
All.instancesJof suspicious parallelism are investigated thor-Joughly within one week by persons designated by the Manager of
. Plant Training, who receives a written report of the investiga-
~
. tion. _The Manager of Plant Training then reviews the matter
- with.the Director of Training and Education. Id. at 21-22; see J- .
Newton et al., ff. Tr. 32,-409, at 42-44.
~
- p 79. After exams have been graded, an additional' mea-sure is-taken to ensure that the examination has not been com-
~
promised. Comprehensive. examinations, as' described previously, P are reviewed by either the. Supervisor, License'd Operator 1 Training, or the operator Training Manager, or his_ written'de-Ib signee. This-collueion review consists of the reviewer se-- lecting 'one-half of the questions . from one-half of Lthe ~ students- j
.and. reviewing a matrix listing tho-students who took the exam and the gra'ded value - of their answers for sue:picious )
~parallelisms. -Id.Jat-44.
a r~) .(_ ; ,
; ,.p5
p
,.- I fN 80. Since the control of examination procedure has v.
been implemented there have been no known incidents of cheating or the'need-to pursue further initial investigations for suspi-cious parallelism.in licensed' operator training at TMI. The
~
entire control of examinati~ons' procedure ic an area of major. i emphasis in.the GPU Nuclear instructor qualification and devel-
- opment programs. Long & Coe,'ff. Tr. 32,202, at 22. We con-clude that GPU Nuclear is deeply committed to the control of examination-process.
. iii. Affected Individuals
- 81. The Appeal' Board has raised questions in ALAB-772 regarding' management' s judgment in-its. assignments and pro- ,
motions of E. R ~. Frederick and C. ~ E. Husted.' ALAB-772',' - supra, .
' 19 N.R.C. at.1224, 1235 n. 56. Although both. individuals have.
. : been reassigned.and are no longer involved with eitheralicensed orfnon-licensed' operator training, the. treatment of these indi--
- vidual employees is relevant 1to the question:of'whetheruman -
I . agement-thought'throughJand responded appropriately.toIthe.im 1
- plications of' cheating.
, 18,2. Mr. Frederick. Mr.' Frederick began"his employ-
- ment:with Met.Ed/GPU Nuclear-in Nove'mber,1973. At that' time,:.
. he.had approximately five years;of.. experience in the Navy Nu-
. clear.PowerLProgram. 'Since joining Licensee,6he has' gained L' ' ., .
b.
. p -s JA
) nearly five years of experience as an auxiliary operator and licensed reactor operator on TMI-2, and approximately five years of experience in the TMI Training Department as an in-structor and supervisor. His Navy experience included training as an electrician and nuclear power plant operator. He re-ceived an NRC RO license on TMI-2 in October, 1977, and an SRO n
license on TMI-2 in Ja'uary, 1982. Because Mr. Frederick was one of two licensed reactor operators on shift at the time of the initiation of the TMI-2 accident, over the past five years he also has been involved in numerous inquiries, studies, legal proceedings, and investigations relating to the TMI-2 accident. Long & Coe, ff. Tr. 32,202, at 12-13.
- 83. In July _of 1979, Mr. Frederick began his assign-ment as an operator training instructor in the TMI Training De-partment .- From the beginning of this assignment, Mr. Frederick was conscientious in his preparation',' and enthusiastic and effective in his classroom presentacion. Id. at 13. -In
~
-February, 1982, Mr. Frederick _was promoted to Supervisor Non-Licensed Operator Training when the incumbent in that position left the company. His promotion was based on a demonstrated ability as an' instructor and effective interactions with other instructors and his T&E Department supervisors and-managers.
'He also had capably served as an interim supervisor of licensed ~
~
operator training in .the _ period priorc to Mr. Newton's f) w L -
employment. In addition Mr. Frederick had shown a particular sense of responsibility in assisting trainees in recognizing and learning.how to respond to events identified in the lessons learned from the TMI-2 accident. As Director of T&E at that time, Dr.'Long concurred with and approved the Training Depart-ment recommendation. This concurrence was based on a review of Mr. Frederick's performance and on personal observations ~of his behavior and capabilities in Training Department activities, e.g.,-in the instructor development training program. Id. at
- 13. .
- 84. Mr. Frederick's performance as Supervisor Non-Licensed Operator Training was excellent and he was considered a primary candidate for Supervisor, Licensed Operator Training.
1TMI-1 when~that position became available in March, 1983. See UCS Tr. Exhs.-2-5. He had maintained his TMI-2 SRO license'and was enthusiastic about working towards acquiring an NRC SRO In-structor' Certification on TMI-1. After reviewing Mr. Frederick's promotion, the.TMI-1. Operations Department ex-pressed.some lingering concern about-ensuring that what some
, perceived as an old "know-it-all" attitude problem had been corrected. However, they agreed that he ha'd performed _well in his recent assignments ~and-that.similar performance.could be
- expected in the newLposition. Long & Coe, ff. Tr.'32,-202, at 14.
p I 4
. Q ,!
a m
h = y fx 85. As indicated by his performance reviews,
.V Mr. Frederick was effective as the Supervisor, Licensed Opera-tor Training and on occasion in early 1984 as Acting Operator Training Manager.in Mr. Leonard's absence. Thus, in all of his assignments in the TMI Training Department he demonstrated his ability both-to teach and to supervise the activities of other instructors. Id.
- 86. In March of 1984, while serving as the Supervi-
'sor, Licensed Operator Training, Mr. Frederick took the NRC
. TMI-1 SRO Certification examination. In early April 1984, the s results!were received from NRC that he had failed the exam.
l'After careful review by the T&E Department management and a. ,
'" personal' interview by Dr. Long with Mr. Frederick, Dr. Long was satisfied'that his failure related primarily to a lack'of suf-ficient time in the plant to be intimately familiar with TMI-1
. Administrative Procedures, a section of the exam with which most' March 1984 candidates had:also experienced difficulty.
Dr. Long. confirmed that,';in his judgment, Mr. Frederick did not have any. attitude > problem, such'as'over-assuredness or lack'of recognition of-the importance of the exam proces's. Id. at-
'14-15.
e
' 87. In: June 1984, Dr. Long concurred with the recom-mendation of the TMI Training Department to assign.an-Acting 1
' ?,f~y : '
- 4. _/ =
?
e e
Supervisor of Licensed Operator Training to free up [{u~} z Mr. Frederick full-time to prepare for his reexamination by the NRC. While Mr. Frederick was in this temporary assignment of full-time study, the NRC issued NUREG-0680 Supp. 5 (July 1984),
-which' reflected NRC Staff concerns about Mr. Frederick and an
. intention to withhold Mr. Frederick's TMI-l SRO Certification 4
so that ". . . the licensee can assign Frederick no duties as- . sociated with TMI-l' licensed operator training until these issues are resolved." ' Faced with uncertainty regarding Mr. Frederick's readiness to sit for the reexam, and given.the NRC's position, the decision was made to withdraw his applica-tion for the TMI-1 SRO Instructor Certification and to reassign Mr. Frederick until these questions and concerns are resolved. 4 .at 15.
- 88. UCS argues that Mr.' Frederick's training perfor-mance, particularly his failure on the TMI-1 SRO exam, indi-
. cates.a management failure to assign a qualified individual.to
.the job of: Supervisor, Licensed Operator Training. UCS also aindicts the efficacy of the program while it was under Mr. 4 Frederick's - supervision. -The chronology of UCS' case against Mr.. Frederick may be summarized as follows.' Mr. Frederick
. failed his NRC SRO exams in March 1984. Tr. 32,635-36 (Ross);
'UCS Tr. Exh.'1. After preparation'for reexamination,- Mr. Ross gave Mr. Frederick a marginal pass..on his mock NRC SRO oral
;,3 Qf b_
l l This marginal pass was not in line with Mr.
-(a) exam in July 1984.
- Ross' usual clear pass or fail for operators. Tr. 32,633-35 (Ross); UCS Tr. Exh. 1. Mr. Hukill then took the unusual ac-tion'of reversing the recommendation of Mr. Ross that Mr.
Frederick be certified as having met the requirements of an SRO instructor certification. From this, UCS infers that Mr. Frederick suffers from serious inadequacies in knowledge and ability. See Tr. 32,623-24 (Ross); UCS Tr. Exh. 1. UCS then suggests, again by inference, that, despite Mr. Frederick's inadequacies, he continued.in the Training Department and re-
^ceived promotions because of his personality - "a lawyer's fa-vorite" -- not his ability. Tr. 32,415-22 (Newton); UCS Tr.
.Exhs. 2-5.26/
- 89. By_ focusing on the negatives in Mr. . Freder'ick's trcaihing history, UCS; essentially ignores the overwhelming pos- S Ditive performance. outlined above. Obviously, Mr.. Frederick was not fully prepared for his TMI-l SRO exam, as he failed it.
However, Mr.' Frederick.has a current SRO license on TMI-2,-
. having_ met'theurequirements to obtain-and maintain that'
_26/; UCS may base. its -critique of -Licensee's _ performance evalu-
'ations of Mr.' Frederick.on,a passage in_the rebuttal testimony-of Dr. Regan' which; reflects Dr. Regan's view that ratings or
. personal evaluations of an' individual by_a superior:or7 peer-are ,
?probably-the least:-r'eliable way to"obtain the individual's ac-5tualiperformance level. . Regan,'ff. Tr. 33',532,=at 12. .See
- 11-192-194,-infra. '
..'- p.
f, ,,?- m J s
- t. y < g y .
", ., q w- --wsw y y ,,-14w 4 y---
? I , +- h s rc r , fp W .; 7;J-i ' license. Long & Coe, ff..Tr. 32,202, at 14. It is not reason-l 4
-able to. conclude that Mr. Frederick fundamentally lacked the
<1 requisite technical know-how for the job of Supervisor-Licensed E .
Operator Training, based on an initial SRO exam failure. More- ,
- over, we agree with Messrs. Hukill and Ross that an instructor
. should.be more knowledgeable in the specific area (s) he is I h ; teaching,.but not in all subjects. See-Tr. 32,947-49 (Ro.ss) ;- L.*. 4
- UCS Tr. Exh. 1. Indee'd,'.as Mr. Ross observed, it would'be im-I p'ossible for an individual assigned full-time to the Training ,
- Department to have a superior knowledge level in all areas re-
.i quired for an SRO license. Tr. 32,949 (Ross). One area with which people-in the plant would tend to be:more familiar than .
I. - people in the training-facility would be! administrative proce-? w idures as'they pertain-to operations'-- the'one section . 14 Mr. ~ Frederick failed on his March'1984 NRC SRO written ~ exam. Tr.-32,949 (Ross). Finally, contrary to the inference of.;UCS. %9 ~ ' that-Mr. Frederick rose on personality,~not performance, Mr.
~
v . , M : Newton'has testified that'Mr. Frederick is " extremely.conscien-itious"fand "technicallyEsuperb,'" characterizations..whichJthe i ,-R "l= 7 testimony- presented Labove-~ and UCS'. :owni exhibits iconfirm. : Seef. b . Leig.,MTr. 33,060, 32,4201(Newton); UCS Tr. Exh'. 5..
~
.~ ,
' .9 0 .' In' summary,7the. Board-believes-thatathe handling?
l
.g v-
, (' y ' 1 LSf Mr. Frederick during)the f time : since the TMI-2:. accident =has:
^ '
JdemonstratedIGPU'.Nb$ lear's commitm$nt to evaluate itsf ! r 4 .. 4
, [,- y G .
l --72 '
~ '
g _
, 5:(, ,-
n
'l .h*
+ . DI .- ' _
~
! - AA' ~
-r , e LJ m ,4. '- , - .M 4 - ,,<-,-.k- .~~-# .r , ,.-r -r-., , , .wy = i.- +
l l (") employee's performance fairly and to advance employees appro-v priately based on their performance. We are satisfied that de-cisions regarding Mr. Frederick's advancement were carefully reviewed and, in each case, his subsequent performance verified that he could satisfactorily perform the assigned responsibil-11 ties.
- 31. Mr. Husted. Mr. Husted began his employment with Licences in February, 1974. He has approximately five and one-half years of experience in the Navy Nuclear. He has about three years of experience as an auxiliary and licensed reactor operator on TMI-1 and about five' years experience i'n the TMI Training organization. His Navy experience included trainin; as a machinist mate and a nuclear plant watchstander. He re-ceived his NRC RO license on TMI-1 in June, 1978, and his SRO-license on TMI-1 in July, 1980. In July, 1978 Mr. Husted
-joined Training as a TMI-l licensed operator instructor. His performance as an instructor was consistent and improved with experience and additional instructor.and supervisory training.
Long & Coe, ff. Tr. 32,202, at 16.
- 92. During the 1981 investigation and remanded hear .
ings on cheating, Mr. Husted displayed a serious ~ attitude-prob-
'lem which led.to the-Licensing Board expressing " doubts . . .
about his competence.to instill a sense of-seriousness about e
~
T T
. . - ~ . . - . . - . -
l l
. I
- l the important need for integrity, discipline and public confi- ' - V[ h ~ dence in the TMI Training program." LBP-82-56, supra, 16 RN.R.C. at 320 (1 2168). The Board recommended ". . . that the qualifications and delivery performance of Mr. Husted receive ptrticular attention during the forthcoming review of the TMI l
' Training program." Id.
- 93. Prior to the Licensing Board's decision, in June
- 1982, Dr. Long met with then Manager Plant Training-TMI, Dr.
-Knief, and the Operator Training Manager, Mr. Newton, to 1i
! develop a plan of action for an ongoing assessment of Mr.
-Husted's attitude and performance as a licensed operator in-structor. This plan included anLinterv,iew of Mr. Husted by Dr.
Long and Mr. Hukill,.after which they-were satisfied that Mr. Husted understood the seriousness with which the Company: viewed-
~
his behavior _in his. interactions with the NRC I&E investiga-Etions, the intervenors during his deposition,.and the~Special Master and others during his' appearance:In the-reopened hear-ings. As'a result of these. incidents,~.which Dr.LLong and Mr. ~ '
~Hukill informed.him were3 inappropriate, Mr. HustedfiJas advised 1that' his job performance and attitude .would be .. closely: moni-
;tored:for an extended period. Id. at 17.
- 94. The monitoring program and special counseling g _
'with TMI-Training-Section management,had actually begun prior I&
O
~
k to the June meeting and continued on a regular documented basis (~)N 4 through December, 1983. In addition to observations and evalu-ations by Training personnel, the TMI-1 Operations Department
- performed special observations and submitted written reports to Mr. Hukill on Mr. Husted's performance and attitudes. All of these reports indicated that Mr. Husted was performing very satisfactorily and that there was.no evidence of undesirable attitudes or lack of, respect for the training and licensing processes. Id.
- 95. In March, 1983, when the supervisory position for non-licensed operator training became open, Mr. Husted was considered as a candidate. Based on the thorough and extensive ,
recent observations of his performance and attitudes, the TMI. Training Department recommended and the-Director of Training & Education,-Dr. Coe,'and Dr. Long concurred in his appointment as Supervisor, Non-Licensed Operator Training. In June 1983, the Commonwealth filed exceptions to the Licensing Board's de-ir cision. These exceptions challenged the appropriateness of Mr. l. Husted's retaining a license or instructing _ licensed operators. i Licensee made a commitment-to the Commonwealth to remove Mr. Husted's SROflicense and:not to use him as a-TMI-1 licensed op-ierator or instructor of licensed operators. Id.-at 18.
. Mr. Husted. performed effectively as Supervisor, Non-Licensed -
, Operator Training until June 1984-when ALAB-772 directed that
( e 5
+
- 25. _ $ -
Lhe be removed from this position. He was then assigned to the
-.(~)
v -
-Nuclear Safety Assessment Department to work on the TMI =probabilistic ~ risk assessment project, where his excellent knowledge of TMI-1 plant systems could be used advantageously.
Id.
- 96. It is impossible for the Board to determine
-whether Mr. Husted's career was given appropriate consideration in the complex controversy over his role at TMI-1. We ex-pressed our concern about this question during the hearings.
J Tr. 32,320-23 (Chairman Smith).27/ However, the Board recog-nizes that this-matter involved all sorts of judgments by GPU Nuclear management and others which were not and need not'have been aired in this remanded proceeding. See Tr. 33,096 < (Chairman Smith). ~ Suffice.it to say that' decisions.regarding Mr. Husted's assignments and promotion.were carefully reviewed
;by GPU Nuclear management. Mr. Husted's subsequent performance.
- was verified so as to ensure that he had corrected.the' problem E27/z Several. times 1during the' hearing the Board also expressed concern about.the licensing process-leading.to results.which:
were unfair to individuals involved. .We cited Mr. Husted.as.a possible victim of past process and Mr. Frederick as a possible. victim of present process.~ 'Tr. 32,016-18, 32,212-13,f32,320 - L23, 32,681-83, 33,095-97 (Chairman Smith). Notwithstanding our
. philosophical frustration over this question, we. find'that as.
swith Mr. Frederick, Licensee's handling'of Mr.-:Husted since the-cheating-hearings demonstrates.a. corporate commitment to address-. employee: performance / attitude problems and to. resolve - them if possible. 'See"Tr.132,320-21-(Long). _ ,eq LN)
- s. . __ _ __ _.
l j p - the Licensing Board.had identified to him and that he could V handle effectively the responsibilities assigned to him. Long
& Coe, ff. Tr. 32,202, at 18. In short, management's response to Mr. Husted's conduct was appropriately thorough and circum-spect.
- 4. The Licensed Operator Training Program
- a. Methodoloay
- 97. The operator accelerated retraining program
_("OARP"), developed in the aftermath of the TMI-2 accident, was designed and conducted in a manner then typical of the nuclear industry and academia -- it was a traditional, knowledge-based program that emphasized subject-matter topics and prior.knowl-edge of the instructors. As a traditional program, it was di-verse.and thorough. However, it was not correlated with spe-cific job performance requirements. Knief & Leonard, ff. Tr.
.33,364, at 4; see generally LBP-81-32, supra, 14 N'.R.C. at 451'
'(11 196-207).
- 98. In mid-1980, the Training and Education Depart-ment of GPU Nuclear was-formed, with Dr..Long as Director and Dr. Knief as Manager of Plant Training at TMI. Dr. Long and Dr. Knief were. familiar with concepts of validation and took
.immediatelsteps-to shift the-focus of operator training to a p
^;)
._m___. _.___ _ _ _ . _-
performance basis. Program validity was sought in terms of (g'Y-both subject-matter content and job performance. Information in both areas developed in-house was compared to that available from external sources such as INPO and the NRC. Systematic training _ development using feedback from a variety of cognizant personnel increased content and performance validity. Knief & 4 ,
. Leonard, ff. Tr. 33,364, at 4. Detailed consideration of Licensee's performance-based methodology is important and nec-essary, in view of the position taken by Dr. James Regan, UCS' expert witness. Dr. Regan in effect challenges Licensee for not making a serious and explicit attempt to relate training T- content to job characteristics and training performance to job performance. See Tr. 32,765-66 (Regan).
- 99. Although Dr. Regan (mistakenly). directs his criticism of-lack 1of validation to the OARP Review. Committee's work, see-11 278-285, infra, the real question is whether ,
i' ~ Licensee-has sound basis for considering its programs to be valid. We believe it does, as evidenced by'our discussion'of.
. Licensee's performance-based training'. approach. We also' agree with Licensee's witnesses that'Dr. Regan's: incorrect perception is based on his lack of awareness of the considerablea efforts' .
- by;GPU Nuclear _over_the past four and one-half years-to estab-
'lish :the -validity of the TMI-1 licensed operator . training pro -
- gram. Knieff& Leonard, ff. Tr. 33,364,~at-1. Dr. Regan
,m v<
I - M'
j/) himself has. stated that UCS assured him that his participation in the case did not hinge on his having any knowledge of spe-cifics about the TMI training program. Tr. 32,738 (Regan); see e.g., Tr. 32,732-51, 80-81 (Regan). Dr. Regan has further stated that he was not offering any testimony about the sub-stantive quality of the program.28/ Id. 100. Instructor training, which started in 1980, placed special emphasis on the development and use of behav-ioral learning objectives. In addition, instructors were in-troduced to the principles of training needs analysis, job and task analysis, and testing and evaluation -- topics which were later formalized as key elements in GPU Nuclear's and INPO's training system development ("TSD") models and the NRC's 28/ .Dr. Regan did not know enough about the specific-tasks as-sociated with the job of control room operator to apply his-personnel performance system to TMI. Knief & Leonard, ff. Tr. F 33,364, at 2, citing Regen deposition (November 13, 1984) at
~157, 159, 168. Dr. Knief and Mr.. Leonard noted that Dr.
~Regan's familiarity with the training program apparently is limited to facts gleaned during a'seven and ene-half day effort ,
y to review related documents ,and prepare his 22 pages.of testi-mony. Knief & Leonard, ff. Tr. 33,364, at 2,. citing Regan, supra, at 1. He therefore did not answer'the question, "Is the instruction adequate to prepare the operators to operat,e the plant safely?" Id., citing Regan deposition at 168, referring
'to ALAB-772. Instead, Dr. Regan's testimony describes the sys-tem he would use to validate the program. Id. Apparently aware of its expert witness' limited _ exposure to the training program,- counsel for UCS--stated that they would have liked to hive provided Dr. Regan with more information on a number'of
. subjects. Tr. 32,834 (Jordan).
r
=-
systematic approach to training (" SAT"). These models were ("/i C developed at approximately the same time. Tr. 32,898-99 (Leonard, Newton). Subsequent revisions to the replacement and requalification operator training programs incorporated these principles. Knief & Leonard, ff. Tr. 33,364,,at 4-5. 101. Moreover, Licensee implemented the TSD model as-a method to develop a performance-based training program. Id. at 5; see generally Newton et al., ff. Tr. 32,409, at 29-31; Tr. 32,898-904 (Newton, Leonard). The model includes five
~
basic elements -- analysis, design, development, imple-mentation, and evaluation. In summary, the TSD model recom-mends'that'a new training activity be constructed using the ,
.following steps: .(1) Front-end analyses first identify the na-ture and extent of the training needs and then identify the el-ements.of the job and tasks of which the job is. composed. (2)
The design phase focuses'on developing behavioral learning ob-jectives and job performance measures which correspond to the 1 tasks required to perform the job. (3) The development compo-
-nent is primarily involved with developing curricu.'.a, training strategies, and lesson plans and other materials. (4)'Imple-mentation includes the actual. scheduling and delive~ry of the
-training to the subject audience. (5) Although evaluation is-
~1isted as the final step of the TSD process, and indeed in its summative form can be a final wrap-up exercise, formative
,7 L-)-
k_
(in-line) evaluations should be conducted during and between
}.
each of the other steps to assess consistency and provide for
-in-line feedback to modify and improve the resulting training program. Knief & Leonard, ff. Tr. 33,364, at 5-6.
102. When a TSD approach As applied to an existing training program, in contrast to a new program under develop-
' ment, the initial, focus is logically on the evaluation step.
Strengths and weaknesses sho21d be identified with the latter becoming the primary focus of attention and resources. Begin-ning in 1980, application.of these principles to the licensed. operator training programs at TMI-1 showed that the development and implementation phases were already conducted effectively. Licensee decided, however, that analysis, design, and evalua-tion could benefit from additional attention to assure proper focus on job performance.29/ Use of the TSD model was for-malized in 1983. Id. at 6. 29/ In his'surrebuttal testimony, Dr. Regan-asserted that Licensee must not understand the TSD model because.it is not possible for phases (3) and (4) to be effective if phases (1), (2) and (5) require additional attention. Regan Surrebuttal, ff. Tr. 32,693, at 5. However, as Dr..Knief explained, Dr. Regan's approach is theoretically clear, but not really correct in application. -For when.there is an' existing, on-going program,-the question is where to initially put one's; resources. There is.not the luxury, to which Dr.'Regan may be accustomed in-the research environment, of creating a new model. Tr. 33,380-82 (Knief). 7 \_, '
1, J? , ~ 103. The transition to performance-based training at q TMI' began through. emphasis on behavioral learning objectives. These objectives identify not only subject areas required, but Jakills or cognitive behaviors to be mastered. Id. The behav-- ioralilearning objectives for the licensed operator were developed or . revised by job incumbents or other subject-matter experts. LThis: approach; included an inherent element of infor-mal, or." table-top" job / task analysis. Id.; see also Tr.
.33,377-74, 32,457-59_(discussion of " table-top" analysis).
'2 104. Evaluation in a performance-based setting is
-based on matching test items directly to the behavioral learn-ing. objectives. Focus on objectives paid the-immediat,el divi-
.dend.of allowing-progress'to be made simultaneously;on,three;of-
+
;the-phases of the TSD'model'(analysis, design, and evaluation).
' Knief 5& Leonard, ff. Tr. 33,364,: at ~7.
+
105. To ensure that instructors. unfamiliar with the s _use'of behavioral learning objectives utilized them properly in - ithe classes 1they' taught, instructors.andLaupervisors.were
. trained on'the writingEand usenof behavioral learning lobjec ~
- -tives - as a means of ' focusing -instru'ctionali and stiu' dent i atten- -
.-tion; on tr aining performance . requirements and of communicating :
program content to Operati~ons management personnelLfor their.
~
(t added' input.and ultimate concurrence. ; Instructor-training 3
~
t 4
?
4 A )) L _ um . -
, ' l Y. ,
+
. . . . .n .
['N - courses, given routinely, continue the process of educating in-
;\ )-
structors in the performance-based methods utilized at TMI. In addition, the Manager of Plant Training has worked with Training staff on improving the quality of the behavioral learning objectives through instructor classroom evaluations
~
and review of selected lesson plans. Id.
~
106. The validation process used at TMI evolved fur-ther between 1980 and 1982. With the issuance of NUREG/ CR-1750, " Analysis, Conclusions, and Recommendations Concerning LOperator Licensing" (January 1981), generic job analysis infor-mation:for the licensed-operator job was available for the
.first time. GPU Nuclear reviewed this document to assess both the content of the then recently-issued TMI-1 licensed operator training program and new qualification cards developed to sup-port on-the-job training activities. Id. at 7-8. The training program closely correlated with the NUREG/CR-1750 generic in-
'dustry job / task analysis. Newton et al., ff. Tr. 32 409,'at 30.
107. INPO Guidelines (initially christened
" benchmarks of excellence") for licensed operator training also were issued in this time-frame. Knief & Leonard, supra, at 8; see also Newton et al., ff. Tr. 32,409, at 30; Tr. 32,461-62,
-33,376-78 (Leonard, Knief). Comparison-'of their subject matter ~
,.m k )>
5-
= .:
s a p (} -
;tocthat of the'TMI-l program showed substantial agreement and
.contentLvalidity. Knief & Leonard, supra, at 8. The two pro-grams'also matched in terms of administrative requirements,
- such as the types of evaluations and review and approval mecha-
, -nisms,'which enhance performance validity. ' Ijg . In response to cross-examination by the NRC Staff as to how the GPU Nuclear
' training program will continue to be consistent with the INPO guidelines, Dr. Knief stated that Licensee is committed to con-
.tinuing~to evaluate its training program against the INPO guidelines and either to maintain consistency or have a defi-
'- nite reason for taking exception to them. Tr. 33,377 (Knief).
108. In 1980 GPU Nuclear instituted a program of man-agement. evaluation of. simulator training. 'Due to their inher-
., entLintegration of the . entire range of job-performance' skills,-
er simulatorLdrills and evolutions have~been especially important I<
~
< evaluation methods providing feedback to both the training and operational arenas. They are also important mechanisms in!per- ,
.formance validation. Knief & Leonard,.ff. Tr. 33,364, at 8.
,. Il09.:In addition,-in 1982>the: formal process for op ' ceratorLcertification as ready ~to operate.the plant.was estab-
'lished toiconsist of an integration of several-training-related
- ' , ~ performances;- ' classroom quizzes and examinations, on-the-job L. qualification,Lsimulator and plant drills, and final written
, o c5(bL '
%.I z.
m-
E-~q m ,
!{,. ~ and' oral'. examinations. Based initially on consultation by Dr. Eric Gardner with the TMI Training Department, a workshop on testing and evaluation provided some specific guidance on construction and use of a variety of examination methods. Dur-
.ing-the workshop, the instructors developed a TMI-specific taxonomy of cognitive skills against which. existing quizzes and examinations were compared to assess relative balance between
~ memorization and higher order mental processes, such as problem
. solving :and decision making. This training provided background for developing test specifications for annual requalification examinations. Id. at 8-9;;see also Tr. 31,879-82, 32,082-83 (Gardner).
110. In'1981, INPO began its industry-wide job / task-analysis z project. TMI-1 supported the effort by having
. . licensed operators complete surveys and. participate in valida-tion exercises. conducted at INPO headquarters in Atlanta. Edu-cational technologists from both the TMI-and Oyster Creek'
< Training Departments participated in workshop' sessions-at:INPO~
to become1 trained in the-process in. support of. plant-specific Evalidation of the. job / task lists. T&E Department ~ management and educational technology personnel: reviewed INPO's 1982 draft
,~ ,
guidelines for. accreditation.of nuclear power plant training
. programs for consistency _with-the TMI-1' licensed operator
, training program.
.; /m.' .
w a
[*
i
f')) v 111. GPU Nuclear contracted with Data Design La-boratories ("DDL") to perform an extensive evaluation of these programs using the draft INPO criteria as a basis. Their as-sessment of program strengths provided assurance of overall va-lidity, while identification of specific weaknesses provided guidance for program improvement. Knief & Leonard, ff. Tr. 33,364, at 9-10. 112. The 1983 INPO generic job / task analycis was used in the continued development of the TMI licensed operator training program. This 1983 publication by INPO allowed com-parison of the analyses to_TMI-1 licensed' operator on-the-job training ("OJT") task sheets. Through this process, TMI-Training revised the OJT training program using the performance requirements established by INPO. Perhaps.even more impor-tantly, the INPO analysis provided a useful benchmark for developing training materials for the BPTS.. The design of the BPTS itself owes much of both its. hardware configuration and instructor-console software to upfront table-topitask analysis and resulting behavioral learning objectives develope'd-by Oper-ations, Training, and Technical Functions person ~nel. 'BPTS training development used the much more detailed INPOLresults to identify those tasks for which the device is best suited. At the same time, tasks suited for training 'n o a full scope si-mulator_were also identified. This proces~s supported on-going jy. i_)
r training at what was then the B&W simulator and also was used
'(~}
v . in development of specifications for the TMI-1 replica si-mulator ultimately ordered from Singer-Link. Id. at 10-11. 113. The Operations Plant Manual ("OPM"), discussed
-supra, at 1 74 and infra, at 176, provides a single reference for the basic subject-matter that licensed operators need for their jobs. Developed primarily by Operations personnel, it has been supplemented through reviews by Training and Technical Functions. The presence of behavioral learning objectives for each1section of the OPM provides focus not only on the key sub-
~ ject matter but also on the important cognitive. levels associ-ated with each element. It is extremely useful to training personnel, operators, and operator candidates as a reference tool that corresponds to both the training subject-matter and
-the job performance requirements. Id. at 11-12;.see also Tr.
31,825,-33,325-26 (Kimel).
.114. The Training Department also has taken the INPO generic job / task-analysis results and prepared a job-analysis-
-task list for the licensed operator, by using the plant .
specific information provided previously to INPO by the TMI-1 licensed operators and a supplemental job analysis conducted by GPU Nuclear. Using this list, tasks are being identified which are appropriate for inclusion in-the licensed operator training
. i (~
,y)
[ ..
F
' Y~h . .
) program. A matrix will identify whether each task is taught in
.the classroom and/or on.the job. The matrix also will be used to upgrade the task descriptions and performanct standards contained on the OJT qualification cards. Knief & Leonard, ff.
Tr. 33,364, at 11. 115. The following activities thus far have been com-pleted in support of TSD implementation: (1) System operating procedures and surveillances have been reviewed to determine if
-the surveys missed any tasks; (2) The task lists have been re-vised to reword the tasks in such manner that they can be in-
'corporated into- OJT and simulator training programs; (3) The completed task list has been reviewed to eliminate repetition and to' standardize, as much as possible, the scope of tasks on the list;'(4)-Operations and Training have reviewed these task list to determine which are appropriate for inclusion in the training programs and the appropriate method of training,_i.e.,
classroom, OJT,'or simulator. The efforts along these lines discussed in the preceding paragraph have been incorporated.
~
Newton _et al., ff. Tr. 32,409, at'30-31, as modified at Tr.
~
32,407 (Newton). 116. Using the finalized' task lists, determinations of what constitutes satisfactory performance will be made. .Re-views will also be conducted to ensure that the knowledge ("T . . Ll
i necessary to support task performance, i.e., the knowledge nec-essary to perform sub-tasks, Tr. 32,456 (Newton), is included in classroom training and is supported by the Operations Plant Manual and its learning objectivos. The comparisons already conducted indicate fairly close uniformity between the class-room training and the task lists. Newton et al., ff. Tr. 32,409, at'31. Results of this job / task analysis will be in-corporated into revisions for the respective programs prior to their next scheduled convening dates. Id. 117. The performance-based training methods used by GPU Nuclear are not identical to the method recommended by UCS' witness, Dr. Regan; however, the Board finds that the methods are consistent with Dr. Regans's recommendations and certainly have involved many of the same elements that he recommends. Knief & Leonard, ff. Tr. 33,364, at 12; see 11 278-290' infra. Moreover, it is important to recognize that there are practical and legitimate constraints on the ability of Licensee to imple-ment a performance system such as Dr. Regan recommends. Knief & Leonard, ff. Tr. 33,364, at 12. The licensed operator training programs in place at TMI-l are ongoing programs, im-plemented on a continuous basis to a fairly small group of individuals. In this framework, test reliability, for example, i's not readily established on a statistical basis. Standard-ization also may be impractical, as training needs change D 4
D
~T. : rather _ quickl'y. Id. When Licensee decided to introduce
,l[Q performance-based training at TMI, it was not possible to shut down the operator training programs in order thoroughly to ana-lyze,-design,-and develop them. Instead, it was necessary to continue to train, qualify and requalify operators. Over the past;four andLa half years, particularly with the development of the INPO job / task analyses', Licensee has expended consider-able resources and effort to correlate its program with, and revise'it on the basis of, performance criteria. The Boa'rd
. shares the opinion of Dr. Knief and Mr. Leonard that accom-plishing this effort.has been both necessary and advantageous.
Iji.-at 12-13.
~ 118. The TMI-l' licensed operator training program is
-performance-based. See Tr. 33,325-26 (Kimel). Notwithstanding
.the shutdown of TMI-1,-the_ program's validity has been and con-tinues to be tested by various means, such_as the capabilities
~
of the trainees on-the-job, at the simulators, in plant drills,- 4
.and-on examinations _(oral and written). Independent evalua-tions have been made, as well, e.g.,'by the'NRC Staff, OARP Re-view Committee, DDL, Admiral ' Rickover, 'and -INPO. . Numerous
' feedback. mechanisms from~ trainees and Operations management-to Training exist'to factor in the~ users' views of the prog' ram.
In conclusion, the Board _ notes that Dr.1Regan himself has de-scribed his-testimony as presenting ~a suitable scheme, but not'
, .;)--
i-
l (' ; the only scheme. Tr. 32,808 (Regan). Licensee has presented such a suitable validation scheme.
- b. Substance 119. Turning to the details of the TMI-1 operator training prcgram, the operation and maintenance of a nuclear facility such as TMI-1 must be supported by an extensive and diversified training program, including formal classroom in-struction as well as on-the-job training activities. Licensee has successfully demonstrated that it has such a program.
120. The purpose of the training programs for licensed operators is twofold. The replacement programs for new operators provide a sound theoretical and practical back-ground to ensure that personnel understand how and why they perform specific tasks, understand ho'w their job impacts plant and public safety, and can correctly respond to situations that they might encounter during normal and abnormal situations. The continuous requalification training program for. licensed
. operators enhance nuclear plant safety and reliability by main-taining a high level of skill and knowledge. -
121. There are three approved training programs which develop and maintain the performance standards necessary to serve as a reactor operator ("RO") or senior reactor operator M ' g =- e e 4
m
~
/ 'T ("SRO") at TMI-1: the replacement RO program, the replacement
%)
SRO program, and the requalification program for licensed ROs and SROs. Newton, et al., ff. Tr. 32,409, at 3.
- i. Replacement RO Training 122. Each candidate for the RO po'sition participates in the replacement program, which is nine months long and con-sists of two phases. Phase one is primarily on-the-job training ("OJT") and classroom training *in reactor plant funda-mentals. Phase two consists of OJT, simulator and classroom training in systems and integrated plant response. Id. at 3,
, 6.30/
123. Replacement operator candidates are designated
'by the Manager, Plant Operations. Each candidate for the pro-gram must meet the job prerequisites.31/ The RO program is 30/ 'The length of time 6r each phase is dependent upon the neads of the specific group of trainees, whose backgrounds are evaluated prior to the commencement of the program. Two phases are utilized to provide the students with an interraixed class-room and OJT program. Prior to commencement of the training
. program, the schedule is reviewed with Operations management to-provide concurrence that the training.needs of each specific group of trainees are met. Newton et al., ff. Tr. 32,409, at 6.
31/ The prerequisites ares. (1) a high school diploma or equivalency; (2) at the time of licensing,-three years of power plant experience of which one year is at TMI-1. This one year of experience must include three months of performing the du-(Continued Next Page)
,a
~..
E
r- -
- a[) designed to accommodate new operators from the job market as wellasthekoranks. Newly-hired candidates from an outside source, with no AO experience, are required to complete sec-tions of the A0 OJT program 32/ as well as complete or validate the plant systems and fundamentals training received by the AO's during their training program. Id. at 4.
124. Classroom training conducted for replacement op-erators includes coverage in the following topic areas: sys-tems; heat transfer, fluid flow, and thermodynamics; mechanical fundamentals; radiation control and safety; reactor (Continued) ties of a licensed operator while under instruction as an extra person in the control room; (3) satisfactory completion of the plant fundamentals training program unless written examination has verified that the knowledge and skill of the individual is comparable to that of individuals who have completed the training; (4) satisfactory completion of the plant systems training programs; and (5) satisfaction of the minimum medical requirements for licensed personnel as specified in 10 C.F.R. Part 55. Id. at 3-4. UCS has suggested that because the re-quired three years of power plant experience may include expe-rience either at non-nuclear power plants or as an auxiliary operator ("A0") at TMI-1, the RO candidates are insufficiently experienced with nuclear power plant operations. Tr. 32,472-73 (Jordan cross-examination of Newton, Leonard, and Ross.) UCS offers no evidentiary support for this. position, however, and the Board has no reason to question the sufficiency of the thre e-year requirement, which is followed by the intensive training and. retraining described above. l 32/ The completion of A0 OJT tasks serves to familiarize the candidates with key operating equipment and procedures while they complete the replacement operator training program. Newton et al., ff. Tr. 32,409, at 4. 6 _ _ _ _ . _ _ . _ _ _ _ _ _ _- .a
() instrumentation and control; reactor theory; primary and sec-ondary chemistry and chemistry control; emergency plan; securi-ty; technical specifications; normal, abnormal, and emergency operating procedures; recognition and mitigation of consequenc-es of_ accidents resulting in severe core damage; and safety analysis.33/ Id. at 4-5. During classroom training, a licensed SRO from the Operations Department is normally as-signed to assist the Training Department in candidate training. This SRO provides an additional source of technical plant knowledge for the trainees and assists in counseling when re-quired. Id. at 5. During classroom training, the status of the operator is continuously evaluated through weekly written topical tests, on which a passing grade of 80% is required. Reexams are given within two weeks for all failures. Failure of a second written test requires the Manager, Plant Opera-tions, and the Operator Training Manager to evaluate the 33/ To illustrate the scope of the program, when systems are taught, training includes: (a) purposes of the system and emergency functions; (b) simplified diagram showing the flow pa'ths including instrumentation, interconnections, interlocks, all major components and control room operated equipment; (c) automatic actuation signal setpointc, interlock setpoints, and the purpose and function of these signals; (d) alarms associ-ated with the system including the purpose, setpoint, and re-quired operator actions; (e) limits, precautions, Technical Specifications, and, where applicable, the basis (Technical Specifications or the FSAR); (f) brief description of system operation in a.'.1 modes, including normal system parameters; (g) power supplies to major components; and (h) interrelations and interfaces with other systems. Id. at 5.
! l L_
(- . student's performance and decide on the corrective action to be ['.I) N taken. Id. at 8. These tests are given subject to the strict security procedures discussed in 11 76-80, supra. 125. One significant illustration of the degree of involvement of Operations in the training program is the fact that the Operations Department is responsible for the conduct of the OJT programs for candidates.34/ The OJT training pro-gram encompasses'the areas of (i) administrative procedures; (ii)~ periodic surveillances; (iii) normal, abnormal, and emer-gency operating procedures; (iv) technical specifications; and (v) specific job-related tasks. Id. at 6. Each candidate must complete all assigned tasks and receive oral checkouts by two levels of Operations personnel. The first checkout received is. on each task identified on the OJT task sheets. The second checkout, or Final Verification, is conducted by an SKO and en-compasses _several related OJT tasks.. If a candidate fails to' complete the second level checkout, or Final Verification, the candidate's supervisor will review his performance and recom-mend' corrective action for reexam. If an individual. fails'the reexam, the' Manager, Plant Operations and the-Operator Training 34/ Routinely, training instructors conduct audits of candi-
, date progress and knowledge level. Concerns resulting from these audits are'-forwarded to both Operations and Training.
Newton et al., ff. Tr. 32,409, at 6.
/3 y) 4 A
i'\
~
3 ;.w , _.
-Manager review the candidate's overall progress and performance (v')
' and' determine the corrective action to be taken. Id. at 8-9.
126. UCS criticizes the fact that shift supervisors and foremen, who are not required to go through the instructor development program, normally conduct the OJT evaluations. See
. Tr. 32,473-75 (Leonard, Ross). As Mr. Ross states, however,
- these supervisors and foremen have three major qualifications:
- 1) they have gone through the licensed operator training pro-gram themselves; 2) they are licensed; and 3) they have many years both of exposure to the oral exam process and of hands-on operating experience in the plant. Tr. 32,474, 32,477 (Ross,
- Leonard)., .UCS has failed to identify precisely what essential r skills an OJT evaluator may lack because he has not partici-
. pated in the instructor development program. TMIA also has at-
' tempted to challenge tho'OJT check-out procedure. See Tr.
32,639-54-(TMIA cross-examination of Leonard and Newton). TMIA
=apparently believes more' instructors should be conducting f ' check-out evaluations and therefore Licensee's staffing of the
-program is inadequate. See'Tr. 32,639-49 (Bradford. cross-examination of Newton and Leonard).35/ However, there is no 4
35/ s With,the concurrence of Operations, Training plans to be-
'come more involved with OJT, with instructors assigned on shift to assist the supervisors and foremen in giving checkouts.
~Tr.m 32,642 (Newton).
I-
-96. a
-x
.m 1
f
)
-self-evident reason why shift personnel cannot give OJT check- >
}
outs, nor have the intervenors provided one. To the contrary,
.these individuals appear to us to be in the best position --
~i.e., most technically knowledgeable -- to perform this func-tion. 1
. 127. In phase two of the replacement RO program, three weeks of simulator training are provided for each candi-
~date at the PSI (B&W) plant simulator in Lynchburg, Virginia.
-This training is designed to reinforce classroom and OJT con-
~
cepts and to develop the operator's knowledge in integrated
. plant response.36/ Training conducted at PSI utilizes TMI-1 plant proc'edures. When-candidates are sent to the simulator-
- for training, an SRO is normallyLassigned_to accompany them.
The.SRO provides.TMI-specific input and evalu'ates the operators and' instructors on their performance. See Tr. 32,078-79 (Dr. Christensen's description.of the interaction between the SRO and'the: operators as " lively" and " dynamic"). Any deficiencies 36/ I Simulator program content'is determined. prior to the initiati'n o of the training. PSI:has developed a standard: three-week control room' operator program which:it-issues to its L. customers. -Using this classroom'and simulator-schedule as a base,xthe OperatorJTraining and Simulator. Training sections of; the TMI Training Department: develop aLmoressite-specific pro-gram. . ThelSupervisor,1 Simulator Instruction,. and' Supervisor, Licensed Operator. Training,.' provide' input to PSI regarding - topic selection,-planned evolutions ~andl drills, and instruc-tors; ENewton'et al., ff. Tr. 52,409, at 6-7.
+
n jf} - , - g .
- w. -
k@: s
-, s, ,
') -_
~- 'u . -
v 1.4;)s% .
. w
r
/ ~^. in operator or instructor performance are discussed with PSI
.U and TMI Operations and Training management.37/ In addition, an operational exam is' administered by the Manager, Plant Opera-tions, or his designee at the completion of the three-week si-mulator program. Drill scenarios are developed by the Manager, Plant Operations, and provided to PSI at the time of each exam.
The objective of the operational evaluation is to test the can-didate's ability to safely operate the plant through an assees-ment'of the candidate's knowledge of procedural requirements, systems, system response, plant operations fundamentals, and integrated plant response. If a candidate fails the operation-al exam, the Manager, Plant Operations, and Operator Training Manager review the candidate's training performance record and determine required corrective action. Newton et al., ff. Tr. 32,409, at 6-7. 37/ UCS has made two inferences concerning the appropriateness of sending these SRO's to Lynchburg: .1) the SRO's are unquali-fied; and 2) they are biased in their evaluations. Tr. 32,477-79 (Jordan cross-examination of Leonard 'and Ross)'.' The Board
' finds no support _in the record for these inferences. Mr. Ross
- and Mr. Leonard select the SRO's on the basis of their techni-cal: background and their' ability to communicate. Tr. 32,478 (Leonard). The Board cannot infer that-these bases indicate lack of' qualification; to-the contrary, Licensee appears-to be s conscious of the need to pick.an individual who is both know-j' ledgeable and.able to verbalize that knowledge. Nor is the
. system biased. While.a trainee may assigned to the SRO's
- shift,. trainees at. PSI usually represent four.or five different
. shifts. Tr. 32,479-(Ross).
1 s
,~
\..)
iJ; [: ~
128. Successful completion of the replacement RO pro-gram requires that the candidate satisfactorily complete writ-
> ten er ainations with a grade of 80% or better; satisfactorily complete OJT checkouts, including " Final Verification" check-outs; pass a simulator startup certification and an operational
~
evaluation conducted by the Manager, Plant Operations, or his designee; and pass (80% overall, 70% per section)' a final com-
' prehensive written and oral examination. I_d . at 8. The oral I exam consists of an oral board on plant fundamentals and a plant walk-through. Personnel from Operations and Training are
~ assigned to the ortal board. A licensed or certified SRO is as-signed to~ conduct the plant walk-through. I_d . at 9. After the-
' candidate completes the assigned training program,:the Direc-tor,-TMI-1, must certify that he is ready to'take the NRC:RO
' license exam. Id.; see LBP-82-56, supra, 16 N.R.C. at 365-66 (11 2348-51);-LBP-81-32, supra, 14 N.R.C. at 448 (1-187).
ii. Replacement SRO Training 129.' The- TMI-1; Manager, Plant' Operations, TMI- l . shif t 4
. supervisors--and shift foremen, and specified TMI-11 instructors-
- participate in"the:SRO' replacement program. The replacement
' program accommodates.can'didates' promoted fromlthe RO position, ' -
as well'as individuals seeking-an-SRO license directly w'thout i
1havinglb'een previously' license'd.as TMI-llRO's. LALmajority of'. - s . 7 ;fy. -.
~
MJ ' O _ s
- 1 r
W ) V
- - - - . . .-.. - . - - . - - - . . . . . - . .~ ----~....-- -.- -- -
, N' _ r
?
.the candidates for the' direct SRO program are Shift Technical
}~
-Advisors (" STA" ) and degreed Training staff. This program also p accommodates engineers involved in plant support. The SRO re-placement programs.are normally six months in length. Id. at t
9-10. - 130. Each candidate for the SRO program must satisfy . i
'specified minimum qualification requirements.38/ Newton et al., ff. Tr. 32,409, at 10-11. The Manager, Plant Operations, designates candidates for the SRO program, using the specified
- prerequisites. Id. at 11.
131..The program content for both the replacement and ; the direct SRO' programs.is' designed to provide classroom, si- , L ~mulator, andlon-the-job training in the following areas
. supervisory course in decision analysis'/ supervisory develop-li (ment;ssupervisory.. control1 room and plant operating' experience,
, directed by specific, task assignments and licensed senior oper- ,
ators'; reactor. theory;' plant design and operational' character-e
,istics; plant: control. systems;/ radiation control and safety;.
~
R;- . - b i38/ ; The. concern we. inferred from UCS' questioning (on'the power-L-
; plant experience;necessaryLto qualify.forithe replacement:RO
.e. : program, see supra, n.31,s apparently also applies to<the..re-.
^^
. placement SRO program. 'Tr. 32,472-73!(Jordon cross-examinationD _
- of; Leonard 'and-Newton). Furthermoreh UCS;has' failed to~ move beyond inference and.show that~the1 requisite 1four' years of . *
.poweriplant; experiences 'two f of' which must be nuclear, amounts . .
1, 'to'insufficientuexperience. g4
,M-- '
~
f-100 - . 1 8 _T N
* ~ x r..+ i. , , e .r v , , - 0S,- ,-,.-myn c. -,,-e d s . , - . -
(~) x_/ plant transients; and recognizing and mitigating core damage. Id. 132. Classroom training is conducted to emphasize the SRO's role in-plant control. Specific schedules are developed for each replacement class based on candidate experience. The Operations and Training Departments confer on training sched-ules prior to issuance to ensure that training needs for each class are met. Id. at 11-12. 133. UCS' expert, Dr. Regan, suggested that the key training that operators need is in how to deal with situations
.for which there are no clear-cut procedures. Tr. 32,799 (Recan). Dr. Regan was unfamiliar with the nature of the three-day' training session on decision analysis that is given to all SROs. Tf._32,840-41 (Regan). Decision analysis trains individuals (a) to handle complex situations for which written 7- precedurec de not c::ict; (h) te develop a technique to cope with uncertainty, stress, and conflicting information and to make~ decisions in the face of such circumstances; and,'(c) to make " good" decisions, i.e., to consider fully and understand the significance of alternatives and to factor in the most im-portant considerations. Decision analysis training develops in control room supervisory personnel the tools-and sensitivity to
.make the right. decisions under, highly adverse circumstances,
-101-
+((
a L? _. _
~
. .__ .- _ _ . _ . - - -- __ . __ . m __
l l l Land to do so in a systematic and thoughtful manner. Newton et
}
al., ff. Tr. 32,409, at 12; see LBP-81-32, supra, 14 N.R.C. at 453 (1 200).39/. Moreover, operators receive training at the PSI simulator on scenarios for which there are no clear-cut
. procedures. Tr. 32,920-21 (Ross).
134. The OJT program for SRO candidates consists of
.- day-to-day tasks which involve participation by the SRO candi-
- date in shift foreman-related activities designed to reinforce
,- . classroom study and maximize new learning experiences. The OJT !: - program-consists of tasks related to 1) secondary systems; 2) I primary systems; 3) administrative procedures; 4) normal, ab-normal and emergency operating procedures; 5) technical speci-fications; and 6) shift. foreman duties'. The selection of OJT-tasks for_the direct SRO program'is completed using. input from the Operations and Training staffs. The program coEbines.the; OJT.'from'the replacement RO and SRO-programs, as wellfas se-s lected ~ tasks from and checkouts cn1 systems listed in the AO program. Each-candidate is examined:on these tasks. Final. _
^ verification checkouts are conducted by shift supervisors cut-groups.of related tasks' . .This-verification serves as a-second:
j !/ j3 In addition, .each candidate attends six~ sessions of the-
.Zenger-Miller supervisoryfcourse. These' sessions' include <in-c Jstruction on giving recognition to employees,' communicating _
- j - effectively,~ listening,; improving employee' performance,.and
- delegating. Newton et:al., supra, at'12.
m
~ '
-102-y- l
.[
s b.:. k- A bI
, . ~. . . . _ . _ . _ _ _ _ _ _ . _ . _ .. . .- -
a ,h.
- i: . .
>J -
check. Id.' at 12-13.40/ . 135. Simulator training for each SRO candidate is
-conducted by PSI at Lynchburg, Virginia. The program content for the simulator training is determined prior to' training bein'g conducted by PSI. PSI has developed a standard'two-week
- SRO. program.41/ As with the replacement RO program, the Opera-
~
Ltions and Training staffr; use this program as a foundation for i the development.of a TMI-l specific program. The Supervisor, Simulator Instruction, and Supervisor, Licensed Operator l-Training, provide input to PSI regarding topic selection, Olanned evolutions and drills, and instructors. Id.Lat 13.42/ b 4 . jg2/ UCS makes the:same criticism of.the individuals ~:responsi : )J ible1.for OJT evaluations in.the replacement SRO program.as itJ
'made'concerning the_RO program. -Tr. 32,475-77 (Jordon cross-
- -examination of' Leonard); see supra, 1 126. Our analysis off that criticism < applies here. -Eurthermore,'because.only. ..
- licensed SRO's may give checkouts;in othe-_SRO program; UCS coun-e "sel himself" acknowledged that :the1 size on the group. that was' cqualified'for:this' role was smaller:and more-restricted. eTr.
- 32,476-(Jordan).
;4_1/ Trainees in_the direct SRO Replacement' Program'rece'ivefad - ~
- Editional simulator training beyond the two weeks normally-con - '
iducte'd for' replacement'SRO candidates. LThe goal"offthisuaddi :
-tional-training isEto provide trainingr onicontrol panelE ..
~
operation, and : expose- the- c.andidate . to: an increased- number of ? normaljand abnormal-plant ~ operations. : Newton et al.,.ff.JTr. 9,32,409,.at 13. , L d
;42/) As'in:the 'O' R program, a111censedISR'Ofis normally= assigned,
~
7e -
.to accompany:theiSRO candidates?to Lynchburg,'with the same .
,zm
~
tasksLasJ.the.SRO who accompanies the RO candidates. UCSiagain. questions the qualifications:andrimpartialityc of the SRO'who 1(Continued Next Page) : m_ -
-> -103- e z- - .
._ 7$-_ s
', 1%~ '~ .
- c. - -
e ~ T m l < < g - ,-
s k^ 136. To complete the SRO training program, a candi-
~date must satisfy the same requirements as in the RO program.
A direct SRO also must pass a Startup Certification Exam. As outlined in the RO program discussion, weekly quizzes, OJT l checkouts, and' comprehensive examinations are conducted, and results of examinations and quizaes are used to evaluate the competency of the candidate. The Director, TMI-1, again must certify all candidates before they take their NRC exams. Id. at 14. iii. Requalification Training 137. Upon licensing by the NRC, each operator is as-signed to participate in an ongoing requalification program.
. The goal of the licensed operator requalification program is to
~
enhance nuclear plant reliability and safety by maintaining a-high' level of skill and knowledge in licensed RO's and SRO's. The requalification program is implemented utilizing the fol-lowing interrelated segments: pre-planned' lecture series; (Continued)- . helps evaluate'the shifts at the simulator. Tr. 32,480-483 (Jordan ~ cross-examination of Newton, Leonard, and Ross); see, n.37, supra. .-Our. discussion in n.37.again applies, with'the
. addition.that.the qualifications are generally-higherifor the SRO-sent down for the SRO,'as' opposed to the RO, program. Tr.
c 32,4825(Leonard).
-104--
I s'
'^{ ).
3_f i 2
,'q,,) skills training and evaluation; operational review program; and annual examination and evaluation. The operator requalifica- !
[ tion prog' ram is conducted on a cyclic basis so that all program requirements are completed in a period not to exceed two years. Id. at 15. To ensure that requalification training fulfills its purpose,'all TMI-1 Operators shift personnel are scheduled on a six shift work cycle with one of the six shifts dedicated to training. In cases where identified training cannot be com-pleted within the one shift week devoted to training, addition-al time is scheduled during the operating crews' relief week, , or'on overtime as necessary to complete required training. . Id. at 3. 138. Lectures. The Pre-Planned Lecture Series con-sists of'two types of lecture programs, the Fundamentals Review Lectures and the Operational Proficiency Lectures.. The Funda-mentals Review training sessions cover areas in which the knowledge required of a licensed individual is relatively con-' ,
~
istant. The topics presented in the Fundamentals Review series .
-reflect 1the results of.the annual: examinations and the perfor- -
mance of the licensed personnel as evaluated by the: Manager,. Plant Operations, and'the Operations and Maintenance Director, TMI-1.43/ The depth of coverage in each topic addresses 43/, The. lecture topics are selected-on an as-needed basis'from the-following list: .Theoti and Principles of Reactor Opera-(Continued.Next~Page)
^
f ^., . , s ' - (_j - -105-
. - ~ - , .:- r ,
q t
- i -dAficiencies identified by the annual examinations, as well as
- those identified by the Operations Training Coordinator, who is the-direct liaison for training in the Operations Department.
The Operational Proficiency lecture topics are selected to en-surefcoverage of'essenti A plant operational guidelines and to ensure that operational changes and experiences are integrated into licensed individuals' training.44/ The depth of coverage in each. topic reflects the knowledge required of the licensed SRO) as does the material for the fundamental review training. Id. at.15-17. . 139. The' Pre-Planned Lecture Series is scheduled'on
~
an annual basis. The lecture series is held on a continuing. basis with a weekly schedule of lectures designed to be a I _ L(Continued) tion; Theory and Fundamentals of. Heat 1 Transfer,: Fluid FlowLand
' Thermodynamics;, Features oftFacility Design-including Plant ~
Systems;tNuclear. Plant. Operating Characteristics Including Op-erating' Experience; Plant' Instrumentation.and; Control: Systems;
- Plant; Protection _ Systems;LEngineered SafetyLSystems;mRadiation'
- Controlland. Safety and. Plant Chemistry;. Applicable Portions;of:
Title.:10,1 Chapter 1I,-Code of. Federal-Regulations;fand~ Fuel:Han - dling. Newton et al.,Jff.iTr.'32,409, at 16. F . .. . . 44/ The-lecture topics are-selected from'the following;11st': g Normal,1 normaliand. Emergency. Operating Procedures.and changes
~ .
.thereto;-Administrative 1 Procedures,4 Conditions: and Limitations .
Land 1 Technical'Specificacions and changes.thereto; Major Opera-itional Evolutions;! Facility: Design'and-License: Changes;-Op-- . 4erating History and' Problems; Related; Nuclear? Industry Op - ., Lerating Experience; .and' Mitigation of Accidents ? Involving la. 4
! Degraded Core. Id. at-16 1 a , -
M
/W- '-106-u - -
A s b_ _ _. .s
repeated for each shift during its training week. It typically fus') ~ . Linvolves up to 240 contact hours of instruction divided among the program topics which are appropriately scheduled throughout the. year. Id. at 17.45/ For each training session of the lec-ture series, a lesson plan is prepared, reviewed, and approved in accordance with Training Department procedures. Id. at 17. 140. Skills Training. The Skills Training and Evalu-ation segment of requalification is conducted so that each
' licensed operator participates in frequent and varied plant evclutions in order to maintain an acceptable level of skill and familiarity with the nuclear plant systems, controls, and operational procedures. Each licensed individual must demon-strate operational proficiency by participating in reactivity manipulations and plant evolutions,4s/ nuclear plant simulator 15/. All licensed operators are required to attend the Pre-
-planned Lecture Series. Absences are approved in advance by the'. Manage r, Plant Operations, or the Operations and Mainte-nance Director, Unit _l, and are normally limited to one ..
training week per year. Additional absences; unless approved by the Manager, Plant Operations, result in the individual's removal from-licensed duties-and placement in an accelerated requalification program-until'such. time as the missed material is made-up. Id. at 17. 4p/- To provide ~ proficiency training-for normal plant evolu-Ltions,;each individual participates in plant evolutions on an annual-basis. . Newton et al., ff. Tr. 32,409, Attachment 4-(list of evolutions). Individual performance _during these
-plant evolutions is monitored and deficiences corrected so that-1 satisfactory proficiency is demonstrated. To providt profi-(Continued Next:Page) 1
-107-yl '
.i g ~.
+
r; --- I exercises, BPTS exercises, and the plant dril147/ program. To (V}:;(' _ maintain these skills, licensed RO's must actually manipulate plant or simulator controls, while licensed SRO's may either manipulate or actively supervise manipulation of controls. Re-
' activity manip'21ations, plant evolutions, and exercises which are considered in the simulator training program include normal plant' evolutions, abnormal / emergency plant evolutions, verifi-cation.of plant operating procedure adequacy, and demonstration of plant response to conditions identified from nuclear (Continued)
.ciency training in abnormal / emergency plant evolutions, each individual, 'cn1 an annual basis, participates in training exer-cises covering plant abnormal / emergency conditions. - See id.,
Attachment 5 (list of annual conditions). These-evolutions are-conducted either_.at the simulator or during"the plant drill program. On a two-year' cyclic basis, cach licensed individual participates in training exercises covering additional plant abnormal / emergency. conditions. . Id. at 19; see id., Attachment 6 (list of biennial conditions).
-4Z/ Plant drills are conducted in order that each licensed individual actively participates in drills. covering abnormal /
emergency plant evolutions which are not adequately covered in , thel. nuclear plant simulator training program. Plant drills are structured to review or carry out actions required-to respond to abnormal / emergency plant conditions. Plant drills are con-ducted with the approval of the Manager, Plant Operations ~, on an individual-or team basis and usually involve: reviewing plant procedure steps; identifying actions required to estab-
'lish stable _ plant conditions; identifying-equipment control lo-cations and functions; identifying' expected plant instrumen- ,
tation and' alarm response; reviewing communications necessary to gather information or coordinate team' actions; and-identi-fying' supplementary actions aimed at mitigating results or
.causes of plant abnormal / emergency conditions. Id.~at 21.
-108-
.( y v.
w u -- .rwee % w- -ey- y -.p .,M- p4yg y t+-e- r-em-y. w twr-w
I l 1 1 ( }; industry operating experiences. Id. at 18. Exercises involve multiple failures and/or operator error, and utilization of ap-plicable plant procedures and technical specifications. Indi-vidual and operation &l team performance during the abnormal /
' emergency training exercises is monitored. Id. at 19.
o
- 141. Each licensed individual completes nuclear plant
-simulator training sessions involving a minimum of twenty hours of direct interaction with the simulator nuclear plant control panel on an annual basis. Since 1982, lectures at PSI have contained TMI-specific information, e.g., TMI heatup and i
cooldown curves, fuel mechanical performance, fuel in-compres-sion curves, core power peaking, integrated control system
-failures / operation, emergency feedwater effectiveness, RCP
~
operations guidelines, ATOG, and.OTSG tube rupture. The con- ~ tent of-these lectures is directly under the control of-the Op-erator-Training section, which is a significant improv'ement-
-from the pre-1982 lectures which were-provided by PSI as gener-tic topics. Id. at.19-20. In developing theLsimulator; training
, : program,-the Operations Department works with the Training De ~
~
,partmentlto establish a' list of topics-for classroom:traininge as well as an outline for simulator' drills.48/r.The Operator-L4 y 1-Av'previously discussed,'at the start of ea'ch training;
- cycle,-la' group ofETMI-1 operatoriinstructors-and non' shift-jlicensed' operators;from. Operations participate in a prototype r simulator training. program. See 1 73,' supra.
2
., i['n .
-109 z
- A_/ . ,
' A P
$~ f ,*
, f, , r
~-g'.
F ' r @r c# m
~
- : Training section develops lesson plans and objectives for the
[
/cl'assroom program, and the Simulator Development section
~
; develops. drill sequences and drill guides. The two Training xsections work:together to ensure that the classroom and si-mulator sessions provide continuity within the training pro-gram.. The simulator training program is approved by Operations and. Training and sent to PSI for review prior to its commence-
._ ment.49/ ' During th'e 1983 training cycle, simulator training
-for licensed operators was expanded to include an additional tweek of ATOG training and three days of steam. generator tube rupture training. During the 1984 cycle there have been three
- additional days of operator proficiency training. Id. at
~
20-21.50/ - o
.49/ LUCSihas attempted to apply its critique'of th'e'SRO:who accompanies'ROfand SRO simulator. crews during replacement training, see nn. 37,.42,csupra, to thelrequalification pro-gram. Tr. 32,480.(Jordan cross-examination"of N_ewton;and Leonard). As-Mr. Leonard explained,- howeveri the purpose'of
~
y ithe requalification program.is~differentifrom'the. purpose'of the: replacement program.- Tr. 32i480_;(Leonard). Because the shift supervisors 1and foremen ~whoinormally would serveLasithe- ?? - caccompanying-SRO's~are themselves' receiving training.atiPSI,
;the41ndividualsTresponsible'for evaluating. crews are.those
< qualified :as ~emergencyadire'ctors, suchfas: Messrs.ERoss,.Toole,-
}Colitz,Jand-Hukill.':UCS' analogy:between the replacementfand (requalificationsiprogramsithus breaks downzbefore:UCSleventgets-ito the point:of challenging'the1 qualifications of-the:
evaluating personnel. f50/JLIn-' addition;to meeting thet requirements,forJskills p ' C; l training; participation:notedLabove,.off-shift licensed person-inel? assigned?to the'OperationsjDepartment actively participate.
-.^
. (Continued Next Page):
a n-110- - 9. b'M T
"4 a
c .. l'
'(-)
'~/ 142. Mr. Ross has an active role in the evaluation of
, operator. performance on the PSI (B&W) simulator. He gives the majority of the simulator examinations for requalifying crews and replacement operators. Tr. 32,619-620 (Ross). .Mr. Ross selects the scenarios (which he keeps confidential until the moment of the exam). Tr. 32,620 (Ross). He then makes the
~ judgment on the overall grade, with input from the B&W instruc-
-tors. Id.
143. Operational Review. The Operational Review Pro-gram provides a system for on-shift review of selected opera-tional experiences and changes to existing operating guidance or equipment. .The program. enables continuous updating for on-
'shif t personnel by establishing a means of ' disseminating new cur changing information. rapidly. Newton et al., ff. Tr. 32,459,
;at'22. A" continuing system exists to ensure that licensed individuals review documented plant designJchanges, equipment ~
(Continued) in control' room operation a minimum of one shift per_ month.
-Licensed. instructors from the Training Department staff;and nother on-site. licensed personnel; actively participate _in con-
. trol, room operation la minimum-of two shifts per month. . During'
-;this-period,'theseLlicensed. personnel:must assume (actual'or' under: instruction) and perform the duties of-the on-shift.
licensed" operator. Failure to meet this requiremention.a quar-terly ; basis results .in placement in!an upgrade program. Newton
.et al., ff. Tr.'32,409,; at 22.
'-111-s
_'( '
>~- :
"I..
W u m i.
~
P f (~5. modifications, procedure changes, and technical specification
- M changes. -Selected changes and modifications are analyzed and
.information pertinent to the basis for the changes and their operational implications is collected and formally transmitted to all licensed individuals with acknowledgement of review re-quired. Changes to emergency procedures and technical specifi-cations require review by licensed operators. Id. at 22-23.51/
144. Training is conducted to incorporate operating
. experience review from TMI-1 and the industry. Selected opera-tional events and reportable occurrences at the facility-are.
analyzed and information pertinent'to the event collected. Se-lected operational information from the nuclear industry is an-alyzed using Licensee Event Reports, audit, evaluation, and inspection reports, publications and periodicals covering.nu-" clear industry information, and NSAC/INPO Significant Event Re-
- -ports. Technical Functions personnel assigned to assess plant operating experience and the Training Department sp'ecify,op--
3: .. sf gerating experience:to be analyzed for training purposes.52/ 1 5_1/ -To ensure operators are kept' informed on plant procedure; changes,~~eachton-coming shift of licensed = operators is.. required to review a revision book. This process ensures significant procedure changes..are' pointed out promptly to the: operating Lcrews. . I_d . at 64.
. - 52/';When:the Plant. Analysis S'ection.~of Technical ~ Functions.
~
sends a1 recommendation,~.the. Training' Department:must;acknow- !. (Continued Next'Page)- L.
- -112-l: }];
v
< s
+ E p
._' _'j[ , [-
r~ s
. Selected nuclear plant' accidents / transients from industry op-
{(' erating experience are analyzed and, where applicable, inte-grated into the~ simulator exercises, the plant drill program, or classroom training. The Training Department sets aside be-ztween'one and two hours during every six-week requalification
~ training cycle to cover relevant industry events that have oc-curred since the previous cycle. Tr. 32,936 (Newton). Addi-
-tion' ally, information can also be formally transmitted to all licensed individuals-with required acknowledgement of review.
-10 at 23.
, - Operators are kept abreast of plant modifications first by. training handouts. generated by Operations management, and l'ater by formal classroom training on these plant changes.
- This approach:immediately informs operators in the field when a system change takes; place so they can be aware of its proper (Continued)
.s dedge andLrespond.to-thel recommendation by returning a response sheet. L Tr. 32,934-35 L(Newton) . _ Mr.' Newton lfurther: explained 1 that.the_significant event.reportsidistributedaby INPO.are ,
Ltabbedired : (_" urgent") , yellow, Land' green.(" routine"). The ,
, Training Department receives an additional-; copy'of thesejre-- 1
.portsLfrom Technical Functions. ._The. Training DepartmentLmust-
~ respond'to'theicopy from'INPO, which= evaluates-Training's-re-sponse. ~ INPO also . sends ^ "go'od ' operating- practice's" ~ recommenda-
- iN 'tions to Mr.LRoss as Manager, Plant. Operations. .Tr.7 32,937 1, ,
;(Newton) l. ,
The_ required;TrainingLresponsesLto'TechnicallF' unctions-and-
- 1" --INPO :and e the : overlapping ; copies' of1INPO 'significant event y re- ,
JH ' ports provide assurance that'the1TrainingfDepartment is not. .
~only receiving? industry. recommendations,1but istalso responding.
'_' s .toithem.
' ' ~'
i S 3'. _
--113 .
+p: _ , _
' ' :L/i
~
Ny t , A -
% )
" Y
?
>? 6
&:7 r
'(). operation. Later in their normal requalification training this material may be presented in a formal classroom atmosphere.
Newton et al., ff. Tr. 32,409, at 63. The Board finds that
- Licensee has in place an adequate mechanism for monitoring in-ternal and external events. requiring consideration and possible change.
145. Annual Examinations. To determine each licenced individual's knowledge of topics covered in the requalification program and provide a basis for determining areas in which retra'ining is needed, an annual examination is given to all licensed individuals prior to the completion of each annual requalification program cycle. It consists of an oral examina-tion and a written examination. Id. 146. The written examination contains questions covering the topics. addressed in'the Fundamentals Review Lec-
=
ture Series and the Operational Proficiency Lecture Series. The examination is structured.so that the level of questioning. is consistent- with the individual's license level . (RO or SROi. Each' licensed individual receiving a grade of'less-thanJ70% in
- any; examination category or an overall gra'de of less than 80%-
is: relieved of his-license duties and placed in an accelerated requalification program.53/ . Ijd. at 24. .1 53/ . Under - special circumstances where a - grade of less tduus 70% has been scored ir. a_ single section-with the overall average-(Continued Next Page) t' 't
-- 114 W $ M g g* , ce -- % e y - -- - .-r p;" -=T**-- ' - ' "^ + *'
I (3
'~l' 147. An oral examination is also administered to
~
^ licensed individuals. The oral examination contains questions covering many of the following areas: licensed duties and responsibilities of the operating position corresponding to the individual's license level; actions in the event of abnormal conditions; actions in the event of emergency conditions; in-terpretation of instrumentation responses; plant transient and
' accident response; plant modifications; procedure changes; technical specifications; emergency plan; plant operating his-
. tory and problems; 'and related nuclear industry operating - expe-riences. Oral examinations are conducted by a licensed SRO or an individual who has successfully completed education and training programs required for an SRO license. Each oral exam-ination is structured so that the oral examination is at least two' hours long; normally,.it is considerably longer. Id. at 24-25.
4 (Continued)
.-greater than'80%,Lthe Vice President,-TMI-1 may document.the-
-special circumstances and authorize an oral and written reexam-iination of:the failed:section within one week. If the' oral exam.is-completed satisfactorily;and a grade of 70% or' greater is scored on the single written section, the individual may re- '
turn i to shift in aclicensed' status with the approval of the
'Vice-President, TMI-1. 'Id. at 24.
-115-f~3
,I -
1 l
"/~'% 148. The. oral examination involves sessions conducted
\m) in the plant control room and in plant areas normally entered by individuals whose actions are directed by the licensed oper-ator. A failing overall oral examination grade requires the licensed individual to be removed from his licensed duties and be placed in an accelerated requalification program. The con-tent of an accelerated requalification or special retraining program is specifically structured to upgrade knowledge and
< skills identified as deficient. Id. at 25.
149. UCS has focused a significant part of its cross-examination on the training histories of two currently licensed
'RO's, Jay-E. Moore-and John J. Walsh, and an SRO, H. Keith Olive. See, e.g., Tr. 32,422-53, 32,624-32, 33,434-44 (Jordan
' cross-examination ~of Newton,' Leonard, and Ross). Eighteen of-UCS'. thirty-four exhibits involve Messrs. Moore, Walsh, or
; Olive. See UCS Tr. Exhs. 8-16, 21-28, 30. .UCS apparently-seeks to show from-these individuals' training. histories'the inadequacy of Training and Operations Departments.which allow these: operators to continue in the program.
150. The three exhibits introduced by UCS on
-Mr. Walsh are coversheets documenting one mock NRC RO written.
~
1 r exam failure in 1983, one mock NRC RO written examEpass in May
'1983, and ono annual requalification. exam failure in March of
-116-
- /~s c -
a( , c . .
o . T~'I 1984. UCS Tr. Exhs. 21-23, respectively; Tr. 32,624-27 (Jordan
\)
cross-examination of Leonard and Ross). Based on the results of these-three exams, UCS would have this Board find that the Licensee erred in its decision not to remove Mr. Walsh from the program,' and thus hold that the current organization, with its flawed judgment, is inadequate to train competent operators. The evidence introduced on Mr. Walsh is grossly inadequate to justify UCS' proposed finding. We find that, rather than undermining the Licensee's judgment, the evidence supports its
. Judgment, reaffirms the decisions to keep Mr. Walsh in training, and justifies the policies and procedures of the Licensee with regard to exam failures.
151. Mr. Walsh failed the company-administered mock-NRC exam required by Licensee'(but not by,the NRC) prior to certification. Tr. 32,624-27 (Ross, Leonard). However, he subsequently passed that exam in May, and passed his NRC RO.
.. license exam on the first try. Tr. 32,627, 32,6591(Leonard).
Mr.-Walsh also failed one-of four sections of his March:1984 requalification exam. Tr. 32,625-27 (Ross). . Licensee proce-dure' required that Mr. Walsh.be immediately removed from
^
licensed duties and placed into an accelerated. upgrade program. Tr.-32,627;(Leonard). Mr. Walsh then had.to'and did take and pas.s a reexamination. Id. ~
-117-e m
k " L - a
(( '1'2. 5 The Board is satisfied that these procedures struck a balance between Licensee standards and individual fairness. One way to judge past decisions by the Training and _ Operations Departments is to look at subsequent performance by the~ operator. Since being licensed, Mr. Walsh has satisfacto-rily completed the requalification program. Tr. 32,959 (Leonard). His average score on the 1983 requalification cycle weekly examinations was approximately 90. Tr. 32,959-60
'(Leonard). His average score on the current.requalification
-cycle -- Cycle'84 -- weekly written examinations has been ap-proximately 92,-above average for the class as a whole.
~
Tr. 32,959 (Leonard). Mr. Leonard stated that the current suc-cess of Mr. Walsh in the requalification program.is consistent with his~performanceLsince' passing the NRC licensing exam. Id.
.Neither1the Training nor Operations Departments.have'any reason 1to believe that: Mr. Walsh should not-have been allowed to con-
-tinue in the program. based on his-earlier! failures. Tr.'32,960-(Leonard);.Tr.. 32,9621(Ross). The : Board: would: simply Ladd that
' consistent performance by.a superb 1 student probably-says more about the student than~the program,1but' improved performance.by.
- a-student'who began.with'difficultiesireflects highly on.the efforts ofrthe Training and Operations Departments.
-153.'The case of Mr.' Moore: echoes that of Mr. Walsh. -
~
~;UCS'. training exhibits document'a mock:NRC written exam failure
,,. -118-
- y -
g-
.: a 1:
c
,k
h O > 3 "\ f
;(,-}l in Januaryc1983, a mock NRC written reexamination failure in early February 1983, and a mock NRC written reexam pass in mid-
; February 1983. UCS Tr. Exhs. 24-26. Mr. Leonard agreed with UCS' sulmmary that;UCS Training Exhibits 24, 25 and 26 reflect >
~
the decision "to allow Mr. Moore to go ahead after he failed the: exam reflected in Exhibit 24 with additional training in order'to take the exam as reflected in Exhibit 25, and then after having. failed the exam reflected in 25 the Company al-lowed-him to go ahead and continue and take the exam reflected in' Exhibit 26." -Tr. 32,630 (Leonard). As in the case of Mr..Wilsh, UCS again questions the judgment of the Training'and
, Operations' Departments in their decision allowing Mr. Moore to
' continue in the program. See Tr. 32,630 (Jordan cross-A..
~
- examination of Ross).
(154. We once agdin concidde-that the evidence pre-
~
~
svents:the Board from finding what UCS proposes' . -Af te r. I
; completing 1the replacement RO program,in February 1983; ,
~
.Mr. Moore'the same. month passed _the NRC RO' licensing. exam on~
r ~
~ ,
'- ihisffirst attempt.3 Since'tNen Mr. Moore has participated-in;
~
~
', athe(Cycle 101:(1983) and Cycle 84 requalification programs. ' ..Tr .-
;32,961:(Leonar'd). He-has; averaged aroundi90l percent.on0his.
~
~
. j
~
l Cycle 1.84? weekly quizzes,(consistentLwith'his performance.during-
~ 1Cyc1h? 10. DI d.- JAs with Mr. ;Wailsh,iMr. Leonard does 'not believe
+5
~
-thAt Mr.? Moore'should_have;been removed:from the program while' 4
17 , . 1
- v. , , , .
-119-4
' ~
y .
~
~
..}- .
e
. 7
^
f Dr E
} ,
T3/ he was having diffi ulty passing his mock examinations. Id.
;\
We agree with Mr. Leonard that Mr. Moore's performance on the NRC licensing exam and in the recent requalification programs indicates that the judgment of the Licensee was not incorrect. Tr. 32,961-62 (Leonard). 155. UCS also questioned Mr. Ross about the competen-cy of Mr. Moore. The reasons for Mr. Moore's difficulty with-examinations, apparently, is that Mr. Moore tended to misread exam questions, i.e., he read'" black instead of white" on exams. Tr. 32,631,f32,962 (Ross). However, Mr. Ross has abso-
~
lutely no question about Mr. Moore's ability to follow direc-tions while serving in the control room as an RO, he has abso-lutely no question about Mr. Moore's attitude or willingness to
' follow directions, and he considers Mr. Moore to be a competent operator. Tr. 32,962 (Ross). In short, Mr. Ross considers the problem'to have been one of careless exam taking, not one of-
. performance. See Tr. 32,963 (Mr. Moore reads'into questions more than is there and goes off on tangents). Mr. Moore, he observes, is a'"very intelligent individual" wita knowledge that enables him to pursue tangents. Mr. Moore, he contends, actually "follows instructions quite w' ell." Id.
156. In the case-of Mr. Olive,.UCS once again is
' challenging the judgment of Training'and Operations in allowing n -120-
[v
^
- u. .= , ~
L Mr.. Olive to continue in the program. See Tr. 32,422-53,
-]
~
32,963-68, 33,439-44 (Jordan cross-examination of Newton, Leonard, and Ross); UCS Tr. Exhs. 8-16, 27-28. UCS has argued generally that Mr. Olive's continued presence in the training program means.that the Licensee has no criteria for removing an
^
' operator. -We disagree. A chronological review of Mr. Olive's recent training history reveals an elaborate and progressive
. system established to deal with learning difficulties, including personally tailored programs and distinct
-possibilities of' removal.
157. In. March 1984; Mr. Olive passed his Cycle 10
- requalification written exam; however, he~ failed his cycle 10
' oral exam. Tr. 32,963- (Leonard); UCS Tr. Exh. 16. In accor-I' ' dance with the requalification procedure, lir. Olive was immedi -
, ately' removed from licensed operator duties. Tr. 32,964 (Leonard).
- pk'
- * '
4 ~
.158. The operations supervisor-who had conducted'the oral exam ~ documented weaknesses which-Mr. Olive.had shown-dur--
' ~
Ling his oral, and - those weaknesses "were Lresearched toldetermine what Mr.' Olive had ta review to improve his" performance. 131e (
. comments-in1the, oral exam summaryJsheet provided tne Training.
f + Department with a basis on which it could develop an upgrade- - program. An' instructor.in the_ training department developed.a'n~-
~
-121-yy)-
A. -- 5 A
p. 6 V i a. ( , upgrade 1self-study program detailing those specific topics in 4' '
. 'which Mr. Olive had shown weakness and materials to which he
-could refer. Id.
n 159. Mr. Leonard explained that in most cases (and in 1the. case.of.Mr. Olive) with initial failures on oral or written exams, Licensee's approach is to design a self-study program
,which?provides the operator with guidance on where to look for appropriate reference material to upgrade his knowledge level.
Tr. 32,964-65 (Leonard). 160. Mr. Olive followed the self-stddy program. A reexamination was scheduled at a later date, and a board was
. reconvened for his reexamination. In April 1984, Mr.LOlive failed ~his oral reexamination before the board'. After re .
viewing the oral'reexamiresults, the Training Department'de--
-signed for.Mr. Olive a more detailed and structured: program
-than.the original self-study. This individualized program con-
) _siIt'ed of requalification training lectures,. checkouts on shift 1 .
t. from'SRO's, practice. oral examinations, attendance at emergency
- director; training, and a.f.inal oral board, which'he had tof pass. Tr. 32,965 (Leonard).
~ ~
-161'. TheJfinal oral' board was scheduledsfor July.
.Mr.'Ross placed Mr. Olive under. strict orders-to complets the: '
p: -
, program,fand. assigned?a supervisor to personally oversee
-122--
.: .y v s- -
[ d n s 4 4. w
1 , I(I _ Mr. - Olive. Personnel from Training also monitored the program. Mr. Leonard recollects that Mr. Olive completed his program in June, at which point he went up for reexamination. Mr. Olive
, passed his second reexam and was returned to licensed duties.
Tr. 32,965-66 (Leonard). 162. Mr. Ross and Mr. Leonard discussed the results of the examination and believed that Mr. Olive's overall know-
. ledge was satisfactory. Although they believed.Er. Olive had the knowledge required to perform licensed duties, they felt specific areas addressed on the board and revealed during requalification required further upgrading. The Training De-partment therefore developed an additional six-month upgrade h
-program, including ~ checkouts on systems and procedures. Tr.
. 32,966 (Leonard).'
)
163. While working on his upgrade program, Mr. Olive . has been accomplishing his shift-foreman duties and completing his Cycle 84 requalification requirements. Tr. 32,967
-(Leonard). Mr Olive's recent grades on his' Cycle 84 weekly -
tests -- 96.7, 86.7, 95.49, 97.5; _89.9, and 91.8 -- 1ndicate ,
'that.Mr.' Olive-has attacked his requalification and. upgrade c-prog' ram with-vigor. T$.- 32,967-68;(Leonard). Dismissihg a UCS question J about a,possibly-defeatist attitude,LMr. Ross empha-
- sized that Mr. Olive has " continuously expressed a desire to
-123--
-N/[ A
+
i.
n 9 complete his duties and upgrade his knowledge." Tr. 33,444 [v') . (Ross). Mr. Ross has no hesitation about keeping Mr. Olive on L an a member of his Operations Department. Tr. 32,968 (Ross).54/ 164. Mr. Ross, who served on the two feexam boards, suggests that one reason for Mr. Olive's difficulties on his oral exams was that he was off-shift and therefore away from the control room and daily shift duties. Id. Also, Mr. Olive apparently had serious family-related concerns at the time of his oral exam difficulties. Ijd . We consider appropriate Mr. Ross' explanation as to why Licensee allowed Mr. Olive to
~
take'an oral reexam after his first failure: "I think anytime
-you have an employee, besides having- the responsibility. t.o pro-vide' qualified operators and safe operators, we also have a re-hponsibility-to the employee. This particular employee had an 54/: UCS counsel may have had Mr.-Olive in mind when he asked.
Mr. Ross whether he had ever recommended that a' candidate or a i
. licensed operator be removed from the training program _on the basis of poor on-the-job performance notwithstanding good exam performance. See Tr. 32,592-93. (Jordan' cross-examination of Ross). While the evidence introduced in-this hearing indicates less than optimum performance, see UCS Tr. Exh. 9,'it does not indi.cate inadequate on-the-job performance by Mr. Olive. The
, Board does not believe Mr. Olive's removal was necessary or even the best alternative available to_ respond to Mr. Olive's performance weaknesses. Turthermore, Licensee has removed the second most senior-operator from licensed duties,because of' job performance (attendance) problems, even though the' individual's'
' training ~ record was excellent. Tr. 33,063 (Ross).
v _ -124-yy Nj i
._A
;z: ' '*-
. l g
[() extent,ive background in proven operation, and proven supervi-c,yp _ c sion. We felt he had some personal problems that perhaps in-itervened atethis time and we felt he rated another chan[c]e.' Tr. 32,449 (Ross).55/
~
165. The Board would like to make clear that, con-trary-to UCS' inference, the decision whether or not to remove : so'meone'from a training program is not lightly made. Mr. Ross has stated that he'himself takes into account past performance iin training,. participation in shift activitie ,' involvement in shiftLincidents (e.g., pump break due to operator error), gen -
' [~ erall attitude of cooperation, and general knowledge level. Tr.
-:gy y . , . , 32;5931(Ross). Mr. Newton has testified that when he is py. 4p -
, ,Y l deciding.whether training should make a special effort for an.
? individual, he considers 5the capability,. aptitude, and effort -
. demonstrated by the individual. Tr. 32,429-30 (Newton). The
~
zg Board believes,thatithe record on. Messrs.'Walsh,' Moore,uand
^
Olive demonstrates the1 capability,; aptitude,nand. effort not . y
.- Lonly;of the1 trainees.butiof theLTraining and Operations Depart -
-UCS' exhib'its themselvesireflectithe-fact that'not only,
~
~~
, ments.
y J5_5/J--Mr..Ross 5 pointed out Lthat~Mrs' Olive had eight? years of'
, - Navy; nuclear l power fexperience _ before joining GPU^ Nuclear :as ah?
- AO. - Tr. 32,'450-51' . (Ros s )'. In;the; Navy,"heL' served a full.
,, ' . -x Lthree-year < term'as7a prototype' instructor:.where, according to
~ ~Mr.'Ross, if any' technical,' personality,for" supervisory l prob-- ~
-lems had surfaced,the wouldihave:beenndischarged from that par-'
fticular; duty. tid. . 4 >
~
gjf5 ,
-125- -
a :f'E ; ,
&5 T
^
4 -
- *'._ 7 4 'O q ' "_ A-- -
_, - 'a + . Ei , 3s <
.is'there management, but there is senior management involvement I. ) ~
~
_in Licensee's responses to training weaknesses experienced by
- operators. We conclude that the replacement and requalifi-
-cation progracs have the mechanisms in place to discover per-Eformance weaknesses and to correct them.
- c. -Training Processes 166. The replacement and requalification training
, ; programs for.. licensed operators incorporate a number of comple-
~
mentary-processes which have significantly changed since 1981 and which provide'for the sys,tematic development, administra-
~
4 tion,'and assessment of the programs -- elements that ensure Jthat :the program is a valid means of teaching operators how to
< .operateithe' plant safely. See, e.g., Regan,'ff.,Tr. 333,532.
- i. Program Development E 167. As;previously: described,iLicensee' utilizes the .
- TSD model_to. construct, implement, and: maintain GPU Nuclear's.
training programs ~ . The experienced instructo'sfin r the Depart ~
., _' ment have bee'niintroduced to.the'TSD system-through1a~. dedicated S
g
! training session. .
The new instructors 1are.indoctr'inated as:
~
2 jl 2part of the initial! instructor. development course. -Newton et lalfj ff.1Tr.' 32,.409, fat 29. 'This. systematic'.approachito 1 training,iwhichiLicensee-has used albeit-informallyn since- -;
~~
>s ,
. 4 -126 -
4 ( s
,h _ ..s s - -
9 s
$ 4 g
. f-)s
( . mid-to-late 1980, emphasizes the use of behavioral learning ob-jectives to match job needs and feedback from trainees and user
. group supervisory / management personnel. Id.
168. There is constant involvement by Operations man-agement in the development and implementation of licensed oper-ator training. Each of the program descriptions must be ap-proved by the Manager, Plant Training, and Manager, Plant Operations, thereby further ensuring that training needs are met. Weekly quizzes for replacement and requalification pro-grams are.normally reviewed by the Supervisor, Licensed Opera-tor Training, and are required to be approved by the Operator Training Manager. This provides for consistency between exami-nations, technical. corrections, and concurrence with the estab-lished training program. Id. at 32. In addition, comprehen-
' ~
sive examinations are submitted for approval to the Operator Training Manager and Manager,. Plant Operations. This review and approval by subject-matter experts provides for technical
. validation of,the. examination. Id.
169. Each time the. program is implemented, it re-
'fle' cts individual needs that have been identified through the operators and training and~other management' personnel. See, e.g., 1 198, infra. These: table-top validation processes,-
-although informal,' help ensure that the content of the programs
-127-M 3 C.
4 () . reflects the training required to develop the knowledge and skills.of.each operator. Newton et al., ff. Tr. 32,409, at 32. 170. In addition to the regular training program con-tent,Jcertain? circumstances call for implementation of special training programs. For example, major changes in plant proce-
, :dures encompassing Once Through Steam Generator ("OTSG") Tube Rupture were implemented in conjunction with the repairs done to the OTSG's at TMI. These procedures reflected conclusions and recommendations contained in technical documents which.were issued in conjunction with the repairs and which had an impact on1the condOct of operations.in the event of OTSG1 Tube Rupture
. conditions. The significance of these changes and the necessi-ty.that each operator be able to operate the plant safely under
. these conditions dictated that specific training'be conducted.~
A joint effort between Operations, Training, and Technical Functions produced a training program.which was conducted at'
=the PSI simulator over a three-day period during the summerLof I ,
V 1983. - The lesson plans, training- objectives; and : simulator -
" drill guides were developed by Licensee p'ersonnel
. Jach
~
licensed operator received three days of. training, . including , both' simulator and' classroom. A' written and' operational; test? was-: administered at the-end of each training program. Iji. at
. 33; Tr. 32,855-56:-(Ross),
i x
-128 -
M-ik / .
+
g 4
, r 5 9
) 171. The decision by Licensee to develop procedures based on B&W's Abnormal Transient Operating Guidelines ("ATOG")
resulted in an additional and substantial effort by the company to incorporate tJue guidelines into the present procedural structure. Extensive man-hourc were expended to revise plant
' procedures, and a training program was developed to enhance
-licensed' operator knowledge and skills in-support of the proce-dure change. Since.ATOG emphasizes " symptom-oriented" rather than " event-oriented" response, the program was designed to in-clude instruction in this area. The procedural revisions were submitted by.accommittee consisting of representives'from Oper-
^ ~ ations, Technical Functions, and Training. As changes were
.made, the committee identified topics-that1would' require training. .The Trr.ining Department used these topics and the~
revised procedures:to develop a training program. .A:one-week training program.for each crew was conducted at PS$ in the
- . first quarter of 1984, which
- consistsd of classroom and si-mulator~ training. 'The. lesson plans and drill: guides for the
. training. program were developed by Licensee personnel and for-warded to PSI for their use. -At the completion of each week'of.
- training, each, licensed operator-tookfalwritten test.and-the crews had'an operational exam. Most of.the currently. licensed .g operators havel satisfactorily completed.this special'ATOG pro-
. gram; four new licensed' operators and one recently SRO-licensed
-129-
.{ -v ,
J t
u m (f : Shift Technical Adviser have completed similar training (although not this specific program). Id. at 33-34, as j modified at Tr. 32,407-08 (Newton). P 172. The licensed operator training program effec-
'tively provides timely training requested by the Operations De-partment design.ed to resolve industry problems that are appli-cable to TMI. An' example of this would be a fulfilled Training
~
request for lectures on recovery from mispositioned control rods,Ewhich was a.recent published industry problem. This re-
- > :sponsiveness to current issues'is of importance to the opera-tors. Id. at.65;.see 11 143-144, supra.
173. In : addition to development of training programs requiring:new1 knowledge'and' skills, Licensee has made provi-p, sions to address'the genebal area of skill deteriorationithat. at .can: result from~a prolonged shutdown. To support training, . m . .
. .needs in'this area; two separate programs were initiated.
-Newton et al., ff.' Tr._32,409, at 34.
t 174.lAirestart qualification card;.. developed,in 1983,- ; t has-been~ designed to-be'. utilized.during hot functional testing, .
- 'zerofpoweratesting, andithe_powor: escalation test program.' The-
~
squalifi6ation card contains both individual and crew tasks s--.-..
'*^-
+' Jwhich arelto~be completed,-and-is: designed to provide each op--
-erator(withfexposureLto' specific _ operational situations.
.w, a s - o .'. -130 - Dq_. 4-t
,A w
~ > -
. s7 ,;.
, a ;2 ._. . . ,..- - - . a,_,. -- .. ._-.._._,.;-..,.,.;,u...-,.
2.u . .
L b[ 1'- '[ ._ Furthermore, the power escalation test program was designed
. with' hold-time periods at 40% and'75% power levels to allow all crews the opportunity to participate in hands-on performance of items identified on the restart qualification card. Id. at 34-35.
175. Additionally, based on management's observation oficrews during the 1984 ATOG simulator training, Licensee con-sidered it beneficial for the crews to receive additional training on routine. evolutions associated with operation at
. power. A special program was. designed to incorporate lessons on startup, power operations, and licensee event reports. The lesson plans and. drill guides developed by Licensee for these programs were used during a-three-day simulator _ program,in May
-and' June'of.1984. Each licensed operator was required to at-i:
t'end . At the end of the training period-a-written..and opera-etional test.was. administered. Id. atL35.-
^
'176. The method for control 1of the quality of'the- /#
technical information availablefto Operations.end Training.per--- -
- sonnell has undergone. changes.~ .All lesson. plans used by;the op- z erator Training'section must be reviewed by TechnicalLFunctions to ensure.that-the information and scope ofimaterial being- .
Jpresented to the operators is technically correct. _Id. at 35-36. A. standard reference source document has been created-.
. -131-- ,
-rN
-,,,gg. -- ' + e- , ->
% 4 i
l
>~.: .
( - for use by Operationszand Training personnel as a teaching and A --
- study aid. Id. at 36; Committee, ff. Tr. 31,749, at 18; Tr.
. 32,911-12 (Newton). The Operations Plant Manual ("OPM"), dis-cussed supra, at 11 74'and 113, incorporates technical informa-
.' tion from sources such as previous lesson plans, technical ~ man-uals, system design descriptions and operating characteristics,
-into one standard controlled document, The OPM was drafted by GPU Nuclear personnel and reviewed by designated members of Operat$ons,-Training, and Technical Functions. The nine-volume manual contains one hundred twenty-one sections, only a few of
~
which were still in the review process at the time of the hear-ings, and: addresses ~ areas such as primary and secondary sys-tems,; support systems, and plant fundamentals. Learning objec-tives, included in each section, have'been written for:RO's and SRO's. Periodicfreviews are~ scheduled'for each section and an
, - ownerLIs assigned to'each.section to ensure that it is updated
'to'reflectiplant conditions. See-generally Tr.- 33,080-82, -
33;422-26.(Leonard, Ross)~. LEvery time'an1 operating procedure is cha,nged, consideration is given to_ changing the OPM as well
- and, as applicable, vice versa. Tr.?32,923-26 (Ross, Leonard).
.Because the OPM=is controlled, sit' serves as alcurrent'. source of-
~
, ftechnical information for licensedLoperators, . licensed' operator
. ' candidates, and-training-staff. .See generally Tr. 32,908-11 (Leonard,' Newton).
-132-
- X.
'I ,[. -
t 3..
e-
/ 'N
-u[ 177. In summary, there are numerous mechanisms in place at TMI'to. ensure that the licensed operator training pro-gram is and will continue to be responsive to the needs of the operators, reflects current plant design, and constitutes a performance-based program, ii. Training Delivery 178. Training delivery at TMI encompasses several
- different areas, including (1) an instructor development pro--
- gram, -(2) an instructor qualification procedure, and (3) an in-structor evaluation procedure. Newton et al., ff. Tr. 32,409, at 36-37.
179. Licensed operator instructors are required to: attend the one-week instructor development program, which is under the~ direction of T&E's Educational Development Sec-
-tion.56/ The program includes an introduction to the'TSD ap-
. proach,. curriculum development, development of behavioral
- 56/ 'UCS makes the point that not all current' instructors h' ave
~
completed the instructor development program. 'Tr. 32,483 (Leonard). The only one who has not attended this program, however,.is'Mr. Maag, who' presently has~an interim cer-
- - tification,.provided for by the procedure, to teach' operators.
; Id;fsee also,-Tr.:32,216 (Long). UCS has' presented no~ evidence
. that puts into doubt Mr. Maag's-teaching abilities, and.the
- reason Mr. Maag-has not taken this program as yet is'because~of F >
his fairly recent assignment to' training.' Tr. 32,216 (Long); Tr.-31,891-92 (Gardner, Uhrig).
-133--
n. b - s -
. . , g-
-learning objectives, preparation of lesson outlines and lesson
)[
plan formats,- utilization of audio-visual aids, instructing ' -U itechniques, preparation of exams, evaluation techniques and counseling techniques. Id. at 37; see 11 100-116, supra. In addition to initial. instructor development and, of course, training necessary to maintain any current license, each in- _structor attends continuing instructor development training. The advanced instructor development program provides the in- , 'SC structor sith' additional skills not presented in the initial
-course. Advanced training has been provided to instructors in examination development, criterion-referenced instruction, i
audio-visual aids,.and implementation of the TSD model. ; Newton
- et . al~. , supra, at 37.
180. Each instructor also must be qualified in accor-dance with. Training' Department' procedures. Licensed, operator- - Einstructors are required-to complete a qualification card re- . 4
' lated toitheir. area of instruction. The qualification card' ,
specifies the proper level of._ technical. knowledge necessary.57/ TIncludre d in the -instructor qualification card is a list of i . d 157/ Instructors.for plantifundamentals'are required to be ,. Tlicensed-operators.or have specific educational' background and-
~
experience. -An NRC.SRO license or' instructor certification-is
, required'to instruct in plant: systems'an'd. transients,-integrat-ediplantiresponse and to function as a simulator' instructor.
4
' Newton =et al., ff.Tr. 32,409,Lat'38.
, -134 ' 1
[b 6h
~
.. ,2: <
f
,i.
Y". u.. ,
L ' reading material.which each instructor is required to read and [( discuss with his supervisor. The material includes the control of examination procedures, training program descriptions, 10
, C.F.R. Part 55, and several documents describing the TMI cheating incidents. Prior to certifying instructors, the Man-
- ager, Plant Training discusses the cheating incidents with them, emphasicing lessons learned, including the responsibil-ities'that each instructor has in ensuring the exam security process is maintained and taken seriously., Id. at 38.
181. A. revision to the instructor career development
' path has: resulted 'in precise specifications for each instructor position.in the Training Department. The modo of progression y for instructors now incorporates five separate promotional lev-els, whereas before there were only two available for licensed operator instructors. The' instructor levele are based.oh expe-rience ', education, and accountability. This provides a more structured career pathefor. instructors and a viable ~ career path forEOperations personnel. The revision is. intended _to.encour-x ,
age. movement back and forth_between-Operations and Training. Id.uat 38-39.
._ 182. The classroom performance of each instructor'is-1
- evaluated ~on an ongoing basis. An instructor evaluation proce--
dure provides for evaluations of each instructor by upper- _ J N
- -135-
~
p_ t: _u p e
~m
'$ n. "*- 3ss J management and peers. Each instructor is scheduled to be regu-larly. evaluated ~-- up to eight times per year -- wheh involved full-time in classroom instruction activities. Id. ct 39; see
;Tr. 32,483-85 (Leonard, Newton) . A detailed rating sheet has
~been developed that permits the evaluation of an instructor on a number of the important factors related to teaching, such as familiarity with technical information, adequate preparation andl presentation of materials, establishment of sound learning objectives, selection of appropriate instructional methods, proper use of instructional aids, proper response to questions, classroom management, and-instructor characteristics such as 4 voice, diction, enthusiasm, .and appearance. The evaluations
._are. reviewed by the instructor, his supervisor, and Training.
2 management and entered into the instructor's qualification folder. These evaluatio'ns are used to upgrade the individual instructor's skills and identify and correct generic defi-ciencies. Newton et al., ff. Tr. 32,409,. at 39; see also, Long:
& Coe,.ff. Tr. 32,202, at 39-43, "The Criteria for and Develop-ment-of TMI-l Licensed Operator Instructors"; Committee, ff.
Tr. 31,749, at 10-12; id., Special Report at'20-22. iii. Exam Administration 183. Written' examinations are part of Licensee's overall-appraisal of a-potential operator's. competence to i
-136-u' f[ )
_ 7 A
s
!m,)- function safely in the TMI-l control room. Detailed guidelines are now used in constructing examinations.58/ The guidelines for exam construction apply to comprehensive examinations con-ducted at the completion of replacement and annual requalification training. The format and content of the exami-nations are designed.to test specific skills and knowledges.
The examinations are based upon behavioral learning objectives.
- Both informal job and task analyses done by the GPU Nuclear staff and a set of generic B&W task analyses constructed by INPO have been used, with a TMI-1 specific format analysis in progress as described earlier. Newton et al., ff. Tr. 32,409, at 40. The behavioral learning objectives for each specific lesson are developed by subject-matter experts when determining the material to be taught during each lesson. The subject-matter expert, in this case the' instructor, conducts an infor-mal job analysis to determine which knowledge-and/or skills are-required of the operator in the subject area being taught. Id'.
at 44.59/ In this manner, there is a direct link from the job 58/ For a discussion of the exam security procedures imple-mented by Licensee, see 11 76-80,-supra. 59/ Additionally, the objectives for requalification' training
- are approved by the Manager, Plant Operations, while those-for-initial programs are derived from those.in the Operations Plant Manual which'has been reviewed by Operations,' Training, and Technical Functions. From this the instructor formulates training' objectives upon which the lesson plan and examination (Continued Next Page)
-137-
. A) .
t 3./ _,L-.
,, ,, _ . . _ .. . ~ . _ . - . . - , _ , . - .- m . .
"' 3:u; . . .
M
-+ U ?
ju + _ , r - E h-
%?
4 Jto(the material taught to the examinations administered to the w)? :
^5- ! operators. ,
4
;+ 184. The guidelines for examination construction out-411ne-responsibilities in exam assembly, exam-question coding,
- ML r Jexam"reviewLand approval, and exam grading. Individuals are
-designated to fulfill responsibilities as exam writers, exam 3
-coordinators,'and technical' reviewers.
Each has specific responsibilities to ensure that the examination reflects the
~
.behaviora'lDiearning objectives for the material being examined,
.contains. technically correct information, and meets-the speci-
, -fication required for the exam. Id. at'40-41.
Il85. A test specification is issued =for-each-compre-hensive examinAt' ion prior to its' construction. The specifica-
't'on i det' ails the breakdown of points among topic areas to be LaddressedJin.the examination, and the breakdown of point values zto~be' addressed in each of the five skill / ability areas for
. ;each> topic area. 'The five' skill / ability areas which are used'
;(Continued). 4 EI questions.can:.be developed, if-not already done. [Approvalhof ftheLexaminationJincludes-a-review:to' ensure that the questions
- -4 ; reflect.. objectives presented.forithe lesson. . Review by.the= 1
,~ ; Manager,fPlant. Operations,,of1the: annual'requalification exami -
.3 ination and comprehensive examinationsiprovidesianLadditional~ 1" . validation process for'these examinations. Newton, et al.,1ff.-
-Tr.i32,'409,, at?44-45. a
~
, 4 1, f . ~
6
-138-a- ,
/ ff!
- A./ ^a >
> a b o
+ l3 '
c 4 i T (E ~ 1 2 .- _ _ .
-1
F F
,~ .
a..
. w1 f',b to code each question are 1) recall, 2) comprehension, 3) ap-plication of rules and principle, 4) analysis, and 5) synthe-
' sis. The test specification is determined by the Operator Training Manager, with input from the Supervisor, Licensed Op-erator Training. In determining the specification, the objec-tives used during the training program are utilized, thereby ensuring that the examinations contain the correct coverage in
-topic area (e.g., system or fundamental area) and the appropri-
- ate skills / abilities.
~
Id. at_41. 186. UCS has tried unsuccessfully to find substantial
-h' oles in the exam. writing, coordinating, reviewing, and approv-
- ing. process. See Tr. 32,491-504 (Jordan cross-examination of (Leonard). UCS makes the point that under the termslof the guidelines, aflicensed operator is qualified to. write exams.
Tr. 32,497 (Leonard). *Mr. - Leonard has-stated,-however, that he controls the. exam' construction and designates.the writers, and he never appoints operators outside the Training organization-to write; exams. Tr. 32,497 (Leonard). UCS'apparently is con-lcerned that a licensed. operator will be the one responsible for determining the mix of skill and ability areas. Tr. 32,494-97
'(Jordan cross-examination.of Leonard)'. UCS concern is
, -unwarranted for two-reasons. .First, as Mr. Leonard has stated,
'i UCS' -strictJreadinglof the guidelines is literally correct:but-practically of no consequence. 'Present practice prevents
-139-
~w.
'( v- ).
.=
^ operators from having the responsibilities UCS fears. Second,
/~T (i the comprehensive exam guidelines provide guidance on the sub-jects that should be covered, the kinds of questions that should be asked, and what key words indicate a certain skill or ability. See Tr. 32,494 (Leonard). Moreover, the exam writers do not make the final judgment about the skill and ability areas into which a certain percentage of questions should f411.
Tr. 32,494 (Leonard). The exam writer makes an initial judg-ment about the design and mix of questions using the guidelines,60/ but the exam reviewer and Mr. Leonard, as the 60/ An additional source for exam questions-at TMI is the exam bank, which preserves questions from previous exams for possi-
;ble use in later ones. Tr. 32,504 (Leonard). UCS has chal-lenged the validity of the questions in the exam bank because Licensee does not periodically conduct a formal evaluation of each question in the exam bank. Tr. 32,504-06 (Leonard). We are satisfied, however, that a sufficient validation process does exist. First, the exam writer technically reviews the question when he decides to use it. Tr. 32,504-05 (Leonard).
Second, ^ the exam reviewer technically reviews the question _to-make sure it reflects plant conditions at the time of examina-tion. Tr. 32,505 (Leonard). Third, by using the collusion re-view matrix, which, as discussed supra, at V 79, lists the grade by each operator on each question, the Training Depart-ment sometimes can determine whether a questica is valid. Tr. 32,505 (Leonard). Furthermore the Training Department has a number of means'of ensuring that the instructor or reviewer has up-to-date information about the system in order competently to critique extractions from the exam bank: 1) the instructor or reviewer has the responsibility of referring to the OPM, which, as discussed supra, at 1 176, is continuously updated, for cur-rent information; 2) the licensed instructors stand two. shifts a month in_the plant to maintain proficiency; 3) the Operations. 3 engineering staff circulate summaries of new modifications to all' crews, who then receive a briefing ~from their shift super-(Continued Next Page)'
-140-v Al
exam approver, make the final judgment. Tr. 32,495 (Leonard) . Ss In short, there is enough " quality assurance" built into the process to overcome the shortcomings of a hypothetical exam
. writer-who is a licensed operator without training in examina-l tion construction.
187. Licensee does not code exam questions for diffi-culty. .Tr. 32,506 (Leonard). UCS points to one recent requa-
'lification exam and finds in it a poorly-worded question which, UCS asserts, even counsel could answer. Tr. 32,525-26 (Jordan cross-examination of Leonard); see UCS Tr. Exh. 31, #6. Per-
. haps this illustration would not have existed if Licensee did code.for difficulty or if the exam construction QA process had functioned perfectly. However, the illustration represents one question among innumerable exam questions, and there is no evi-dence suggesting thatLa lack of coding for difficulty has re-sulted in easy exams at TMI. Moreover, the question cited may be useful in at least reinforcing the definitions at issue.
188. UCS also has-proposed that an excellent way_of testing.an operator's underlying understanding of the reactor (Continued) visor;-and 4) the Training. Department places a. copy of these summaries into a required reading file for instructors and into ia lesson plan folder:used for' revising future curriculum. Tr.
-32,908-09 (Leonard, Newton).
-141-
..r' ,
' A )N u _
i i. Lis to ask a question for which an operator would need three
- G ensr days to write a competent answer. See Tr. 32,511 (Jordan).
i-UCS appears to disfavor the shorter essay questions utilized by Licensee. Notwithstanding UCS' preferences, its proposal is impractical. More fundamentally, UCS has failed-to show any infirmity in the paragraph essay format preferred by Licensee. Moreover, during UCS' cross-examination of Licensee's witness-es, Messrs. Lecnard and Newton displayed a comfortable grasp of the kinds of questions that test specific knowledge of what is happening in the reactor. See, e.g., Tr. 32,506-13 (Leonard, E
-Newton).
189. Operators are also evaluated through various oral examinations. The replacement training programs require that an oral exam be given at the completion of the programs and in addition, that final verification oral examinations be conducted at the completion of sections of the OJT' program.
-These examinations encompass the' tasks addressed in the section-and are conducted by a shift foreman or shift supervisor. The OJT programs outline the knowledge level' required for each of the tasks. Each examiner, a licensed SRO, uses the OJT task
~
outlines to establish the content of the examination. Newton
.et al., ff. Tr. 32,409, at 45. In addition to:the-one-on-one
- comprehensive oralladministered at'the end of the replacement r
p ' program, Mr. Ross normally conducts a separate oral on the
-142-
> r' i - a s
c- .;- candidates. Tr. 32,535 (Ross). The Board is impressed by this
\_/1 further effort by Mr. Ross, which is beyond what the training
' department guidelines require. See id.
190. The oral examinations given as part of the
= licensed operator requalification program are comprehensive.
See Tr. 32,532 (Leonard). The Operations and Training Depart-ments jointly establish a list of topics to be addressed during the examination and issue it to assigned examiners. Licensed or certified SRO's conduct the oral examinations. The results are forwarded to the Supervisor, Licensed Operator Training, for review. The performance of operators on topics (pass / fail /
. marginal), as noted on the exam topic list, is reviewed for ge-neric deficiencies in order to identify areas which may require
. training during the following requalification cycle. Newton et
- al., ff. Tr. 32,409, at 45-46.
191. UCS is correct that a review of the topic list-summary sheet documenting an oral can only be administrative not substantive. Tr. 32,535-46 (Leonard). However, the Board finds nothing improper about relying on the oral examinor to judge an operator's performance on the oral exam. At some point,1someone has to: rely on the judgment of someone else. t
- There.is no other alternative,-except having no orals, which we do not see as a preferable solution. The question,'then, is
-143-
~
g3
+
u- .
l l whether-the pecple giving oral exams are the right people for
. (3
?NJ the job. In this regard, UCS has directed all its' critical at-tention to Mr. Ross, who may be the most proven of oral examin-
- ers.
See 31, supra. UCS cites the fact that Mr. Ross has no formal training in the grading and administering of oral exams as reason for_us to conclude that he is unqualified. UCS ig-nores the fact that Mr. Ross has been SRO-licensed on TMI-l for about_ eleven years and has over twenty years of actual experi-ence in giving oral exams. Tr. 32,601 (Ross); Newton et al., ff. Tr. 32,409, attached Ross. statement of qualification. The Board-simply _does not accept that until Mr. Ross completes a formal course on oral exams, he is unqualified to take part in
;the process. Nor do we have any reason to challenge the tiered' system used by Licensee by which orals are administered from-more senior to the more junior licensed operators. See Tr.
132,539 (Ross). 192. Finally, UCS' witness, Dr. Regan, suggests that a-small training program, such as the licensed operator training program, should rely only on standardized objective-procedures and documents in place to prevent subjective influ-ences from interfering with the evaluation of trainees. See
.Regan Surrebuttal, ff. Tr. 32,693, at 8. Dr. Regan apparently-believes that subjective-judgments are inherently flawed and should therefore be expunged from all evaluations of a
-144-j v
- me-er-> e t y r*e -y- * - = ' w- F* -- P w,
trainee's performance. See, e.g., Regan, ff. Tr. 33,532, at A l 12, 15-16. Hence, to Dr. Regan, oral examinations and walk-through exams.are of very little value so long as effec-tive simulator training is in place. Id. at 15-16; Tr. 32,828-31, 32,839 (Regan). Moreover, Dr. Regan testified that personal evaluations of operators' job and training performance by their superiors or peers is the least reliable mode or eval-uation available. Regan, ff. Tr. 33,532, at 12. 193. The OARP Review Committee agrees with Dr. Regan that the documer. cation and standardization of evaluation proce-dures'can be useful. However, the Committee disagreed with Dr. Regan's low opinion of.the value of the personal evaluations of
-operators performed by training managers and on-the-job man-agers. Committee Rebuttal, ff. Tr. 33,320, at 15. The Commit-tee testified-that it would be unnecessary and counter-
-productive to require these managers to spend a considerable
-amount of time engaged in the administrative task of docu-menting all-of their activitiesEand interactions with the oper-ators or trainees in light of their extensive first-hand appre-ciation of the strengths and weaknesses of-the operators which
-frequently transcends information obtained from predetermined
. formal, questionnaires and checklists. Ihece first-hand impres-sions are especially valuable in a relatively small, stable
. program such as the TMI-1 licensed operator training program
-145-
}/ v
where the Training and Operations managers are very familiar (N A s/ with the trainees' backgrounds and performance. Id. at 15-16. Training and Operations managers are privy to and continuously review operators' on-the-job, classroom, simulator'(BPT and-B&W) and test (written and oral) performance. Id. at 16. The
-composite of tla information, which constitutes a picture of each individual's strengths and. weaknesses, is continuously re-viewed by Training and Operations. Group or team performance is also evaluated. From this composite, the Committee con-cludes the managers have a' sound, although not necessarily standardized, basis.on which to judge performance. Id.
194. The Board agrees with the OARP Review Commit-tee's positive assessment of the value of subjective evalua - tions. Such evaluations may be inherently subject to an evaluator's idiosyncracies. However, we believe that they also are extremely;useful in providing insightful information about individuals' capabilities and weaknesses. p iv. Program Evaluation and Feedback-195. In the licensed operator. training programs, there are a number of mechanisms _ established to provide Training and Operations management with an evaluation of the-effectiveness'of the training programs.- These mechanisms in-clude. examinations,' periodic' internal evaluations, external
-146-i
, ,3
'x, _ $, -
s m
n.-m . ,.
- . - . . . - . - . .- . . . - .- .-. . - ~ . . ~ .. .- -- . . . . ~ .
4,- E
'4 ,
, - > /
; evaluations, and feedback from operations personnel. Newton et 4- .
.. . lal.,[ff. Tr. 32,409, at.46.
196. Examinations. As is already evident, through
-its various. exam. processes, Licensee not only evaluates its op-
'_erators,- but :it : assesses the adequacy of its licensed operator programs. Simulator operationa? examinations are utilized to assess the performance of individuals and groups receiving
" training. .When the NRC announced that-it would no longer con-
'ductisimulator exams for utilities that did'not have replica
- - s'imulators , GPU. Nuclear considered the practice beneficial as a' means of evaluating the effectiveness of the program and candi-datesi' qualifications and, accordingly, continued the practice.
^ '
' on' its i own. The NRC,.in' fact, ultimately decided to. continue l
administering-simulator exama for TMI-1. Id. at 46-47.
- 197. The examinations conducted.by both Licensee and 4- -
.theiNRC are.eva,luated to identify'both. individual and' generic
" weaknesses. These are usedias' input into1 future. changes of.-
program content 1and/or description., The:results of oral and 1 written examinations are:also evaluated to identify weaknesses:-
~ ~
Jthat may exist in the training program:or in individuals. Oral : exam 7 summary: sheets and written. comprehensive' exam result matric'es are reviewed'by the Supervisor,' Licensed Operator
, ; Training,Jinforder to-determine if additional training'is-a' . . . ,
8 l-
~
p
, -147 1 :
e
' s
'l 1
- (
i: , (' ~ * ' ' y} , hk- _,__..___._.i
required or changes are needed in program content. Commonly missed: questions'can be easily identified and corrective action can be initiated where required. Determining if the programs' training objectives have been mastered through application to plant operations is valuable in assessing whether training is meeting its objectives. Id. at 47. 198. Internal' Evaluation. Periodic internal evalua-tions provide an additional means by which programs can be val-idated. Each of the licensed operator programs requires that an annual audit be conducted. The team conducting the audit is made up of Operations and Training personnel. The team as-sesses the adequacy of the program for meeting new require - ments, adequacy of records, quality of material and presenta-
'tions, and program effectiveness. In conducting the review, the team may incorporate input from NRC inspectors,-Quality As-surance= audits, regulatory changes,-industry experience,
-license candidate critiques and other audits conducted during the year. The team reports its results to the Manager, Plant
. Training, and Manager, Plant Operations. During 1983 a review of. operator training programs was conducted by the Operating Training Review Committee. .The membership of this team includ-ed_the Manager,. Plant Operations,-Operator Training Manager,
~
pp . Training Coordinator, Supervisor,-Licensed Operator Training,'a shift foreman, one inctructor, and one' licensed control' room , l.
-148- ._p ~(
a
p operator. The review team conducted an in-depth review of the f~') we RRO and SRO replacement programs and the licensed operator requalification programs. Individual team members solicited input from both the Operations and Training Departments in the following areas: informal job analysis of each licensed posi-tion to ensure that training program content adequately pre-pares candidates through OJT, classroom, and simulator training; method of training delivery; operations / training com-munications; technical content of the program; and administra-tion of training programs. Id. at'48-49.61/ 61/ The following changes in licensed operator training pro-grams that were effected as a result of the Operator Training Review Team Final Report: (1) . Licensed operator replacement programs are scheduled based on a five-year plan developed by TMI-l Operations. Class start dates are published for a five-year period. Variations-are communicated to training several months in advance; ~ . (2) The number of qualified licensed operator in-structors has increased; (3) A revision of the CRO OJT program has been made to include guidance on performance lev-els for tasks; (4) The RO replacement program was revised toLin-clude additional tasks for direct hires; (5) The RO and SRO replacement OJT programs were reviewed to reflect recent procedural changes; (Continued Next Page)
-149-p).-
~.
L_
h
- ,' -199. In May 1984 the Training Department conducted a
^
( self-evaluati'on of its licensed operator programs. This evalu-ation was completed in accordance with criteria established by INPO. Information gained from this self-evaluation will pro-. L( _ vide input into decisiens on changes in program content, pro-k- l .- c e s s , ~ and records. Id. at 50. o 200. External Evaluation. The TMI-1 licensed opera-
~, . tor program has been evaluated repeatedly by persons or organi-zations outside its structure. These evaluetions were complet-e'd bothiin response to requests by Licensee and as a result of'
,GPU Nuclear's. membership in INPO.
^
These evaluations include lthase conducted by Data Design' Laboratories (DDL), INPO, Admi-
~
'ral Hyman G. Rickover,-and the Reconstituted OARP Review'Com -
- mittee. Id.
'201. In September, 1982, DDL issued a. report titled ,
;m. . - " Assessment of SelectedtTMI-1 Training. Programs." Licensee ,
., , f(Continued)'.
i (6) Additional: tasks were added to the senior.re-- actor operator OJTLprogram; and
;(7) The control' room mockupfwas. delivered and is!
'being usedEfor classroom instruction and-study.
' Newton et-al., ff..Tr. 32,409, at 49.
E -
-k. -
-150-
~
( l i
,)._'-
I l contracted with DDL in June 1982 to conduct an independent as-7 , x_) sessment of selected TMI-1 training programs, including opera-tor training programs. The se se of the evaluation included (1) a review of the technical content of the licensed operator training programs and a comparison with INPO guidelines, (2) the administration and delivery of the training programs, and (3) an assessment of the results of the training program. The ; intent of the DDL report was "to provide informed, broadly ex-perienced recommendations and guidance for the further enhance-ment of efforts which have been well started by GPU Nuclear." In response to the DDL recommendations, GPU Nuclear established an action item tracking system with tracking responsibility at
' corporate offices. An individual was assigned to respond to each finding and take appropriate corrective action. The sta-tus of the action items is updated on a regular basis. Id. at 50-51.
202. In 1982 and 1983 INPO conducted evaluations of TMI-1 site activities to make an overall determination of plant safety, to evaluate management systems and controls, and to identify areas needing improvement. As a pr.rt of these evalua-tions INPO examined licensed operator training. Recommenda-tions for improvement were entered into an action item tracking. system and individuals were assigned to respond to each and in-itiate required corrective action. The items are updated on a
-151-
t periodic basis. Although recommendations were made regarding l k improvements in the programs, the 1983 evaluation reported the following: (1) TMI-l "is being effectively maintained by qualified personnel;"
-(2) "There is a well defined program focused on operational planning and preparation.for startup, including the startup qualification 1 program;" and ,
(3) " Station personnel are well qualified. Their morale, . positive attitude, and motivation re-flect commitment to improved performance."
. Id. at 51. " Station Personnel" includes licensed operators.
Tr. 32,676-77 (Leonard). 203. In anticipation of operation of TMI-1 in 1983, an' assessment of the management at TMI-l and its qualifications
'to! operate nuclear power plants was conducted by a team led by LAdmiral Hyman G. Rickover. Admiral-Rickover's final report, titled "An' Assessment of the GPU Nuclear Corporation, Organiza-tion, and Senior Management and Its Competence to operate -
LTMI-1" was issued on November 19, 1983. The report encompassed the area of licensed operator training. As with previous ex-ternal reports, findings were tracked at the corporate level. The'following findings relating to operator training ~were docu-mented'in the report:
"present.tra'ining exceeds regulatory require-
~
(1) ments in breadth, depth ~and diversity-of personnel training;" and
-152-
/
. ~gh It - i-m
7.g E/ - / a (2) _ management involvement in training is "re-j'} - freshing."
~s
(, Id. at 51-52. In the section of the report entitled "The Im-F portance of Training," Admiral Rickover rcadorsed training man-agement. Committee, ff. Tr. 31,749, Special Report at 11-12. I ~Q,2 O <, 204. On April 19, 1984, a follow-up report was issued by Admiral Rickover which centered on actions which had been ii . .
.taken by Licensee management in implementing recommendations from the previous assessment. The conclusion, as stated in the
~~
report, was that the " actions of GPU Nuclear Corporation man-U cagement give further evidence of the competence to safely
/ . restart and operate the plant." Id. at 52.
, 205. Aside from the independent' assessments con-tracted by Licensee,. assessments have been conducted by the
., l .
Two.of the evaluations-conducted recently by the NRC are
/
NRC. its Systematic Assessment of Licensee Performance ("SALP") y~ dated April 24, 1984, and an Operational Readiness Evaluation
,(" ORE") (Inspection No. 50-289/84-05) dated April 13,.1984.-
b Id- - 206. The. purpose of the^SALP with regard to. licensed
+
4 e operator training wasrto provide valid indications of the ade-
;quacy and; effectiveness of-training of persennel. Id. at-
/53'.62/
g ,
'^ '
, M .
[62/.I The(foll'owing' observations were made in the' report:
. y ' -i: l- -(Continued Next Fage).
y , e
-153- !
a s s -[ s 1
+
m .
r? t
=
ne f'.; . l: F
- b. -.
~
207. The ORE was specifically oriented toward ob-b ta'ining an' improved understanding of the state of knowledge and L' readiness of,NRC licensed personnel at TMI-1. Based on the re-sults of the evaluation, licensed personnel at TMI-1 were found L .. by the NRC to be " knowledgeable and well trained." The results also L indicated "an effective requalification program" and "a Id. at 53-54.63/ sound and effective training approach." y v (Co'tinued) n
-(l); "A large number.of dedicated training person- !
nel, detailed procedures specialized manu-als, technical. courses, and well maintained and retrievable records reflect a high degree
~
of management. attention to implementation of , the.. training program." , yc (2) < ,' Control procedures estaL Aished last year in
' response to ASLBJPartial Initial Decision on the Reopened Proceeding on-cheating were well thought out and properly implemented."
," l(3) " Interfacing between'the plant staff and the ;
' training staff isl evident'withifrequent feed- .
iback'of practical information into the
'U training program."'
' ' ~
l(4)- " Personnel-training on' numerous restart modi-- . Eficationslwas;found.to'be generally well
'f developed, timely'and supplemented by
~
' training: briefs prepared and presented by the
. Operations Department. These briefs were in-
< jitiated-by'the Licensee.andLdemonstrated a-
' ~
.~ desire to' ensure the plant' staff's knowledge-of the numerous-restart modifications."
' Newton. et" al'. ,1 f f.:. Tr.132,.409, - at - 53.
ss , d' f !3/JMeasures to' compensate for any" decline ~in. operational'
-skills have been integrated intojthe requalification program,
- e
- ,
A "
; f(Continued.Next Page)
.. n A n , c, { , - v' xg . - c
~
\
4 4
? t\ ~
N' _ {_ ~f , ,_ 7 ,
's 208. Feedback. As previously described, by allowing f^J -w operators to have a voice in their training, the program is im-proved and operators are less likely to become disgruntled or frustrated by the training in which they must participate.
Meetings at the completion of each requalification training week have been instituted at which operating personnel from that week's training class, the Training Supervisors, the Training Coordinator, and, when possible, the upcoming week's Shift Supervisor who is scheduled for training discuss the pre-vious week's training, focusing en corrections that should be made for the next week. Id. at 64. Also, off-shift tours and management evaluations of instructor performance are fed back
. -into the system to improve.the program.
- d. INPO Accreditation 209. Licensee presently is seeking accreditation by INPO of:its licensed operator training programs.64/ The pur-
- pose of the~INPO accreditation process is to assist member
'(Continued) and have been addressed in classroom and simulator training.
.Id. at 53-54; see 11 140-142, supra.
;64/ Licensee also has sought INPO accreditation for its TMI-1 non-licensed'(auxiliary). operator, shift technical advisor and.
radiological controls' technician training programs. Newton et al.,-ff. Tr. 32,409,.at 67-68.
-155-
sc
]
N fl __, y
r-utilities in developing training programs that will provide p(_/ well-qualified, competent personnel who will operate their nu-clear power plants with quality and excellence. To obtain ac-creditation, a utility must demonstrate that its training meets the INPO accreditation criteria. Newton et al., supra, ff. Tr. 32,409, at 65-66 95/ The INPO accreditation procese itself consists of three major parts: (1) Accreditation self-evaluation conducted by the utility and resulting in a self-evaluation report submitted to INPO in a prescribed format;@6/ 2 (.) Accreditation team evaluation conducted by peer evaluators from INPO and other utilities and resulting in an accreditation team report;s2/ and (3) Accreditation decision by the INPO g5/ Dr. Kimel, who is an alternate member of the INPO accredi-tation board,-testified that seven utilities have received INPO accreditation of specified training programs. Tr. 32,048-49 (Kimel).
@s/ The self-evaluation is conducted based on the INPO accred-itation criteria and a comparison of the utility's training programs to training and qualification guidelines issued by INPO for these specific programs. Newten et al., ff. Tr.
.32,409, at 66.
@2/ The accreditation team is composed of a group of peers with collective expertise in nuclear power plant operations, nuclear utility training, instructional processes, and training evaluation. During the visit, the team interviews training and other personnel; observes training activities, examines facili-tie s , . - equipment, and training materials; reviews instructor.
qualification procedures; and examines training program content and. training records. It reviews the conclusions of the Self-Evaluation Report and provides an independent check on its thorouganess, and evaluates how well the training programs meet (Continued Next Page)
-156-g gj
Accrediting Board.68/ Id. at 66-67.
,,-~.
N-] 210. The Training Department has completed its self-evaluation report in support of INPO accreditation. An INFO accreditation team visited the site in early October, 1984 and has prepared its report. Knief & Leonard, ff. Tr. 33,364, at 11; see letter from counsel for Licensee to Appeal Board, December 19, 1984. The accreditation, if received, will be for a' period of four years, requiring an interim two-year review and update. It is the goal of Training and Education to main-tain the accreditation of its programs. Long & Coe, ff. Tr. 32,202,-at 43. (Continued) the related INPO accreditation criteria and compare against the state of the art. The team prepares its conclusions and.recom-mendations and writes a report that is provided to the utility. c ;TheHutility dubsits a written response"to the. report providing clarification or describing any corrective actions taken, if
-required. The accreditation team' report and the utility' sire--
sponse are' submitted >in a-joint-report to the INPO Accrediting Board. L Id. at 67. 68/ The Accrediting Board consists of-five members: two per-sons from INPO member utilities,'one person.from a non-nuclear industrial. training organization, one person from the post-secondary education community, and one person recommended by the NRC-. Alternate members are selected to facilitate the scheduling of meetings. No two individuals 're affiliated with
- the.same organization. The Chairman, who normally remains in office for.two years, and the other members and alternates are
. approved by the President;of INPO. Id. at 66-67.
-157-
' .fy_,Y
211. INPO has established criteria for assessing fs js) training which address the program (content and trainee evalua-tion and qualification methods), the process (organization and administration, resources and facilities, and program develop-ment and implementation), and the training staff (size and L workload,-qualification, and development and evaluation). 1 Newton et al., ff. Tr. 32,409, at 66. INPO accreditation of the TMI-l licensed operator training program would constitute a well-recognized imprimatur of a high quality program,
- e. Operator Attitudes Toward Program 212. It is unclear whether operator attitude towards training constitutes valid evidence of the quality of the pro-gram. As Dr. Regan-pointed out, students' views of their in-structors may-indicate the students' enjoyment of the. class, but:not necessarily their retention of necessary knowledge.
Tr. 33,773 (Regan). Nevertheless, the Appeal Board expressed a concern about operators' viewslof and, particularly, respect for1the program, see ALAB-772, supra, 19 N.R.C. at 1233, the parties focused on the issue and, we, in turn, summarize our-findings' based on'the evidence presented. 213.-Based on Mr. Ross's daily contacts with'the r licensed operators, it is his judgment that the current'TMI-1 licensed operators accept and have a positive attitude about'
-158- -
'?
% )h~-
I
_the licensed operator training program. He attributes this to the maturing of the program and the efforts that have been made by GPU Nuclear to provide operators with the opportunity for input into the program's development. Newton et al., ff. Tr. 32,409, at 60. 214. UCS faults Mr. Ross for not conducting specific formal interviews for the purpose of ascertaining operator at-titudes. See Tr. 32,562-63 (Jordan cross-examination of Ross). However, as Mr. Ross explained to UCS, such formality is not
'necessary in his case:
I talk to the operators often. I am not a guy they don't see. They see me every sin-gle day. I attend training myself. I sit in training class. I am in the tra[i]ning facility often. I am in the control room often. I ask them about their training. I look at their scores. So, I have a lot of interface in that area [ ], and what I get is real good from them. Tr. 32,562 (Ross).69/ 215. Perhaps the most conspicuous. evidence of opera-tors' acceptance of the training program and the demands it makes on them is their steady improvement on weekly. quizzes and
-on requalification examinations. Mr. Ross believes that this
'69/ Mr. Ross was the only licensed operator who testified be-fore-the Board. Although UCS originally subpoenaed four opera-tors to testify, it subsequently withdrew that request.
-159-
,. ,e
^ V, 5 I
l
^2--__,__-. - ._ ~ _ . _ . _ _ - .I
f 4 A improvement' reflects a more positive approach to participation in the program. He bases his view not only on his own observa-tions,'but also on the feedback Operations and Training man-
=agement have received. Newton et al., ff. Tr. 32,409, at 60-61'.20/
216. GPU Nuclear has instituted changes designed in part to_ improve operator attitude and to establish better com-munications between operators and their management. As previ-ously-discussed, the Vice President of TMI-1,.Mr Hukill, inter- 1 views all licensed-operator candidates prior to their license certification-(or recertification). At a minimum, each l-licensed' operator isiinterviewed by Mr. Hukill annually. See i h,- '1f67,< supra. Mr. Hukill encourages the operators to express.
.their-concerns, such as criticisms of the. training they.re-
, z ceive, and informs the operators that:such concerns will be-20/}~UCS contends that' grades may have~ improved,cbut attributes
.this to= improvements,in the training 1 program,:.not to' operator
' attitudes. See Tr; 32,559 (Jordan. cross-examination of Ross).
UCS 'then faults Licensee for 'noticonducting any: interviews .cnn ~ psychologicalLevaluations to; determine precisely 1what caused improved : grades. . See Tr. 32;560.(JordanLcross-examination of Ross). 'The' problem'the1 Board bas with this argumentLis that it ~ (flies tin' the : face .of L the rest of UCS'- position, ' namely that the
, : training program is. inadequate. =Mr. Ross' states.that his expe-
-rience has been~that the more interested one is in something,
- c- the'; harder one tries and~the-better'.the result. Tr. 32,559. *
-(Ross)'. -We agree. The better'results do tend to. confirm
~s 97 (MrL Ross'.. impressions;of~ positive operator ^ attitude-towards~
f^ - training.' - t
- v. -160-qY , ' ..
e
^
f.) H , ^i i - j w- H
, ; , s u
, u - - _ , , . . . . .4--._.- .,-._,._,-,..,-,2_ , ,, -,.;._~- . . . . . _ . . . . , , ..,;.4 i
s _ evaluated and, as appropriate, action taken to resolve them.
..(f3/ This process makes the Vice President accessible to operators, and ensures an open communications link between senior man-agement and the operators. The process tends to improve opera-tor morale and attitude about their work, generally, including training. Newton, et al., ff. Tr. 32,409, at 61.
217. Visibility of management in the training center is a positive ingredient in ensuring a good training program and helps to demonstrate to the operators the importance placed on training by their management. Various senior managers at-tend training, including periodic attendance by Mr. Hukill. Mr. Ross personally attends training in the status of a stu-dent. Mr. Ross schedules his training such.that he partici-pates in' training with different crews throughout.the training cycles. While,this expecure improves his knowledge as an oper-
. ator, . it also keeps him. abreast of the feelings of the opera-
~
- tors. Additionally, he is able to observe first-hand the con-duct of training and the reactions of Operations ~ personnel "tict the program. Id. at 61-62.
218. During simulator training, management's ; interest in-the quality of training and the' development'of proper con-trolcroom skills:is demonstrated'by the-attendance of all Emer-
.gency Directors'and various other GPU management level s
-161-
'us!
5 I_
f l I
' personnel. An operational examination is administered by one
/~X
(_) of the Emergency Directors to each requalification crew during simulator training periods. This process not only improves and
~
verifies operator skills but, in Mr. Ross's view, it also posi-tively affects operators' views about the importance of their training and management's interest in continually improvirg it. Similarly, management's participation in simulator classroor
. training allows early detection of training problems or opera-tors'fconcerns and ensures that the proper mate;ial is being taught and tested. Id. at 62.71/
219.'Mr. Ross himself states that it is both inevita-
.ble and appropriate that operators, Mr. Ross included, will have some negative comments about the training program.
1Mr. Ross, however, is of the view, which he believes the TMI-1 operators share, that the licensed operator training progr un is
-of high quality and is accepted by the licensed operators. He asserts that thb operators understand not only that training is
- a. job fu'nction, but that it is their responsibility to be com-mitted to participating in training in order to properl'y 71f Mr. Ross personally attendsLsimulator training and admin-isters. operating-examinations to new trainees and experienced requalification crews. In the past several years, he has:ob-served'.a' sincere desire on the part of the. operators to better their operating'. skills and a' highly professionalfand serious-approach to this type of' training. Newton et al., ff. Tr.
-32,409, at 63.
-162-j .. ,/~.
u
< l
.i -
u
, - - . ~ - , . - .
i 4 i discharge their licensed duties. He believes Operations is n (-) working jointly with the Training Department continually to im-prove the program and tc maintain the high standards now estab-lished in the licensed operator training program. Newton et al., ff. Tr. 32,409, at 65. 220. These conclusions by Mr. Ross are responsive to the RHR Report,72/ which UCS has introduced into the record in
.its entirety. The RHR Report summarizes the findings of psy-chologists hired by Licensee to survey operator attitudes in 1982, after the issuance of the Special Master's Report and the 1982. Licensing Board decision on cheating. See Tr. 32,038-40 (Gardner, Kelly). After the events which led to these deci-sions, Licensee legitimately was concerned about the morale and attitudes of its operators. See LBP-82-56, surpa, 16 N.R.C. at 301, 337,383 ( 1 2088, 2240, 2416-17). The RHR Report was de-signed to elicit operators' feelings about subjects of interest
, to them. See.Tr. 32,038-39, 33,293 (Gardner). Obviously, it was not designed to eliminate " invalid" feelings. See ALAB-738, 18 N.R.C. 177, 198 (1983) (RHR report is "one-sided").73/
72/ See UCS Tr. Exh. 6, "Prioritp Concerns of Licensed Nuclear Operators at.TMI and Oyster' Creek and Suggested Actions Steps," March:15, 1983, by Dr. Paul F. D'Arcy and Dr. John.R. Sauer, of
. .Rohrer, Hibler and' Replogle, Inc. ("RHR Report").
~
7_3_/ - UCS cross-examined'Mr. Ross at some length about his reac-
~ tion to the RHR Report and its raw data, UCS Tr.-Ex. 7. See (Continued Next Page) g v' ks_ / -- -163-n-
p l l.'!/~N 221. The RHR Report reflects both negative and posi-p . .'d ! tive feelings by operators towards their job, including L training.74/ From it, the Board cannot reach any clear E , .(Continued)' Tr. 32',563-89 (UCS cross-examination of Mr. Ross). UCS faults Mr. Ross for not following up on a number of apparently nega-tive statistics in the Report. See, e.g., Tr. 32,566-69 (Jordan ~ cross-examination of Ross); but see n.74. In response, Mr. Ross stated that he believed that he had a first-hand ap-preciation-of the operator attitudes reflected in the RHR Re-port, Land.he knew what the-problems were. Tr. 32,5661-72 (Ross). .Given the extensive company effort responsive to RHR, of which Mr. Ross obviously was aware, see Tr. 32,589 (Ross), we do'not fault Mr. Ross for not embarking on an independent formal' process to respond to the RHR Report's findings. 74/ For example, on the one hand, 36% of_the TMI candidate and s licensed' operators surveyed disagreed that top management is more-concerned about public safety than it is about generating ! electricity; 24% of the operators felt that there are so many cumbersome procedures that in practice the GPU Nuclear policy.
- on : compliance is disregarded; . 48% felt that the overall quality of theEtraining: staff.is: poor;;79% felt that the training de-partment is not oriented-to-the needs of the operators; 14%.did not feel.that trainingLhastbeen improving; and 73% did not_ feel
~that training prepares them.for what they.actually da as opera-
. tors ' . See UCS -Tr. Exh. 6 (RHR Report), questions 22, 23, 24,
- 29, 102, and 132; see also,JTr. 32,565-80 (Jordan,_Ross).
OnIthe other: hand,'all of the operators surveyed felt the flicensing process is necessary;;84% felt.that they learned _use-ful-material while preparing for theircrequalification exam; 79%' felt: that the content -of the last requalification- exam'was -
~ job relevant;178% felt that the training and. testing programs-havelhelped them be' a'more1 effective. operator;-91% thought:
Licenseethas a. major commitment to_ training;_ 86% felt training
~
-hasibeennimproving; 95% were or would be.proud to be licensed
; ope'rators;:86% felt"it was'worthithereffort and demands on:them
_ ~to be a' licensed operator;.86% thought'that their pr'esent mor-ale.wastgood;-all-ofithe surveyed operators-stated that.they' . (Continued;Next Page) I - - 164-
.;j L ):
A
; c.
s ', ET #1**9hpript
judgment about operator attitude towards training, even in the
-( / 1982 timeframe. Dr. Gardner, who is an educational psycholo-gist, emphasizes that RER is one data point in a continuum, be-ginning with the original OARP Report findings and culminating in the Committee's recent interviews of operators, described below. See Tr. 33,293-94 (Gardner); see also Tr. 32,745-46
, (Regan). Furthermore, the Staff testified that there were se-rious infirmities in the Report, e.g., the questionnaire used and the Report itself contain a number of ambiguities. Tr. 33,206, 33,216 (Morrisseau); see also ALAB-738, supra, 18 N.R.C. at 198. Finally, Licensee has responded very thoroughly to the action items contained in the RHR Report. Licensee Tr. Exh. 1; see also Tr. 32,313-17, 32,347-49 (Long). The Board is satisfied that even if RHR did provide evidence at one time of some poor attitudes toward training--which we do not find--there is no reason to believe those views still exist at
' TMI, nor-could we.ask Licensee to do more about the RHR Report (Continued) were committed to quality performance; 93% had~ confidence in
-the. plant management; 93% disagreed that safety got too high a
- priority at TMI-1; 98% felt that they understood their job-
. responsibilities and that these responsibilities had been made
. clear,to them; and 86% felt that they had management support in helping to do their job. See UCS Exh. 6 (RHR Report), qucs-tions 1,- 14,-17,-18, 19, 29, 50, 51, 55, 66, 115, 134, 135 and 138. .-It is not surprising that Mr. Ross felt that the Report.
- was "very good and very positive about TMI." Tr. 32,573 (Ross).
-165-
_ n l Ga a .- -
findings than it has already done.75/ 222. The OARP Review Committee has testified to the
. current attitudes of the operators. Members of the OARP Com-mittee observed TMI-l operators and candidates in the control room, in the classroom and at the B&W simulator. Committee
, members had the opportunity individually to discuss training with. operators (including the six shift supervisors) either in 1 the TMI training facility or in the plant. See 1 245, infra. I The Committee also was aware of the "arious processes and pro-cedures in place to ensure that operator views and criticisms of training are aired, responses provided, and appropriate ac-
'tions implemented. It was the Committee's impression, based on the observations and assessments it made, that the operators recognize the value and have respect for the licensed operator training program, recognize and accept their responsibility as licensed operators to participate in the program, and believe that7 it.is an effective program. Committee, ff. Tr. 31,749, at 13 1'. ~To the extent operator attitude is relevant at all, the-Board' believes the Committee's' findings, which are very recent, are the most pertinent. Notwithstanding the absence of.a
_15/ .Onel indication of good'overall_ morale-at TMI is the low operator attrition rate. According-to'Mr. Ross,.the Operations
~
. Department has not lost an operator in' years. Tr. 32,939 (Ross).
-166-e-
\_/-
, .- .. . .. . -. _ - - - - . - . - . = _ _ _ - . . -
r ^,? i
.s, formal questionnaire, as discussed below, the Committee's find-i _ bss .. l ings are well-supported by the experience of the interviewers
~
- the process used, and the number of operators interviewed. See 11 224-257, 286-290, infra.
- 5. Summary and Conclusions 223. In this section, the Board has considered in de-tail the TMI-l licensed operator training program and how it is implemented at:TMI. We have evaluated the management, staff and facilities available to support the program. We have con-sidered'inl great detail post-cheating modifications.to the pro-gram, and operators views of it. It is the Board's judgment
~
that licensed operator training program at TMI-1 is an effec-
~
tive performance-based training program. We.believe that GPU Nuclear /has developed sound procedures to implement the program-consistentlyLand reliably, and that' the IIIPO accreditation ef-
- fort:is' commendable.
.m ti
~
u .v d
' ~
--167-
- j 8}/: .
' ,'<-' . f l'
B. The Reconstituted OARP Review Committee's Assessment
-(~O of the'TMI-l Licensed Operator Training Program
- %]
- 1. The-Reconstituted OARP Review Committee 224. The Reconstituted OARP Review Committee testified-at great length about its review of the current TMI-l licensed operator training program. The members of the Commit-
- tee are quite familiar to us as are their distinguished creden-ftials. -See nn.2 and 9, supra.76/ In summary, Dr. Robert E.
Uhrig is Chairman of the Committee and Vice President, Advanced Systems & Technology for Florida Power & Light. Company, Miami, Florida, with 28 years of utility and engineering education ex-perience. Dr. Julien'M. Christensen is Chief Scientist, Human Factors and Logistics for Universal Energy Systems, Dayton, Ohio and a leading expert in human factors engineering. Dr. Eric F. Gardner is Professor Emeritus of Psychology and Educa-
-tion, Syracuse University, Syracuse, New York.and-a.well-known
. educational-psychologist. Dr. William R. Kimel is Dean of the College.of-Engineering at'the University of-Missouri, Columbia,
, Missouri.and,. inter alia, has served as President (1978-1979)
'of the American Nuclear Society. See-Committee, ff. Tr.
'31,749,; resumes. Dr. Kimel has been affiliated'with INPO 7 76/ z- Dr. Regan testified that he knew Dr. Christensen.p'rofes--
- sionally as a highlyfccmpetent psychologist and-he. knew Dr.
JGardner by' reputation. Tr.'32,695-96 (Regan).
-168- ,rm ;
n) ~ is ;
1 r virtuallyHsince its inception. He is currently serving as an 9 ) - alternate member of the INPO Accrediting Board. ir. 32,046
-(Kimel). ;
Mr. Frank Kelly is President of PQS Corporation and former' Chief of the Operator Licensing Branch of the AEC.77/
'See ALAB'772,-supra, 19 N.R.C. at.1210.
Each of the Committee
": members brought with him valuable expertise from various disci-
.plines which' greatly enhanced the Committee's ability to review ,
theLTMI'-1 training program effectively.
~
As the Appeal Board found in ALAB-772, "the OARP Review Committee (was] comprised of exceptionally well-qualified persons from a range of disci-t
. pl'inesx(nuclear enginer ' ".g , education, psychology, testing),
.most-suitable to their task." 19 N.R.C. at 1211; see also
-L'BP-82-56, supra,'16 N.R.C. at 378 (1 2397). The Reconstituted 7,
UARP,. Review. Committee is-equally well suited to review the cur- i
~
rent--TMI-1--licensed operator training program-and to address the remanded training' issues.
. 225. 'Our. satisfaction;withithe. qualifications of.'the Jmembers.of.she Reconstituted OARP" Review Committee notwith : ,
- st'and'ing,la discussion of the. methodology employed byuthe Com--
- mitteefin-reviewing;the TMI-lilicensed; operator training pro- -
~
(gram and the : remanded; trainin'g issues.'is' warrantedito address _ y" 'f-77/q As!previously discussed, Mr. Kelly; replaced Mr. Richar'd=J. -
- .Marzec,-Manageriof Technical-Training for-Duke (Power Company,
- due'to Mr. Marzec's' unavailability. > S e e i n . 9 , - s u p r a~.
~
s - r
-169-t .
5
. i 4 j w t A J 1
the numerous concerns raised by the NRC Staff and UCS. In Sec-rx (m) tion III.C of ALAB-772, the Appeal Board indicated that the Board should have sought further testimony from the Committee concerning its view of the training program in light of the cheating incidents and related program deficiencies. See ALAB-772, supra, 19 N.R.C. at 1233-36. The Committee interpreted the mandate of the Appeal Board as calling for it to conduct a review of the training program sufficient to allow it to knowl-edgeably address the remanded training issues. The Committee did not believe that, in seeking its opinion, the Appeal Board intended for the Committee to " validate" or perform a quality assurance check on the licensed operator training program. See
. Committee Rebuttal, ff. Tr. 33,320, at 9. Nonetheless, the
~
Committee's testimony indicates that it did perform a compre-hensive review of the. current training program that rivals the level of review an accreditation team would perform. Tr.
'32,109 (Kimel).
226. We agree with the Committee's assessment'of the Appeal ~ Board's intent. We-do not believe that the Appeal Board
. intended for the' Committee to undertake an accreditation-type review of'the training program in order to address the remanded issues.78/ See Tr. 33,249-51 (Staff view that Committee p
78/l~Our review of the-testimony revealed that the Staff.and UCS believe that the ~ mmittee should have performed an (Continued Next Page) ( -170- _s- - - , , , , - - , - - . - _
members'icredentials greatly exceed those of INPO staff workers [ who conduct accreditation-type review). Rather, we are confi-
~ '
~ dent that the. Appeal Board intended the Committee's review to
~
-have been fashioned such that the Committee could provide us with knowledgeable and competent testimony regarding its opin-ion of1the adequacy of the training program in light of the re-umanded issues. Hence, the threshold question is whether the
< Committee's method of review was sufficient to allow it to iknowl$dgeably address.the remanded issues. i r
#(Continued) ,
'accreditat' ion-type' review'of the training program.'lTheLStaff.
~
J arguedi that : the appropriate methodology should be- structured-
-likeithat
- performed by/ Data-Design': Laboratories in preparation' ,
sof s the :DDL; Report .(a multi-volume -accreditation of .the TMI-1 [ - training- programi exceeding 300 pages --in : length) . -Staff,.ffh _
~Tr.-33,148_at 36; Tr. 33_,246-48L(Persensky, Buzy). The UCS-
' methodology is also on par with.aniaccredit'ation-type review in
>- 4 terms.of-the depth and breadth of.the review;as~ evidenced by.
_ Dr. 'Re_gan's -: statement < that:.it;would; takej.a l team of five quali ~-
-fied' people'three months toccompleteihis: recommended 4 review. _
l
^
, -Regan, ff. : Tr. 33,532f at 22. (Hence, notwithstanding the:testi-
'monyfof'Mri:Persenskyfthat neitherlthe DDL approach'nor;the ,
Staff's methodology f are : technically-_ accreditation meth : odologies, our~ review of?the: methodologies: presented.by the 1 Staff'and UCS indicates that-they: clearly'suggest1 thatJthe Com-Emittee should-have. conducted an: accreditation-type review to-
; appropriately addressDthe' remanded: issues.' SeeLTr. 332249,7 '
33,273-74~(Persensky)'. - s 9 1 -171 . , 4 : _ m - l '.' h__ = .. }- ,
~
3
<' e ,
1 , V - O -
av l - '$ 2. The Committee's Methodology
?/~s.
U
- a. Committee's Initial Review (May-June 1984) 227. The Reconstituted OARP Review Committee met for two intensive.three-day sessions at the end of May and in early
, June of 1984, first at TMI and then in Parsippany, in order to review with knowledgeable GPU Nuclear personnel the current status of the TMI-1 licensed operator training program.79/
9 Committee, ff. Tr. 31,749, at 4. In addition to these ses-sions, the members of the Committee continued to review the
< training program during the days between and the weeks follow-
.ing these sessions. See Tr. 31,798-801 (Uhrig, Kelly, Gard-
-ner); Tr. 31,807-14 (Uhrig, Kimel, Christensen, Kelly, Gard-ner). The Committee's findings, based upon this initial review-
-of~the TMI-1 licensed operator training program, are summarized-in'their Special~ Report.
-228. *We received extensive-testimony from the.Com-mittee regarding their efforts in reviewing the TMI-1. licensed operator training program. The Commit' tee initially convened at
" ~
79/ ; Dr. Kime1 was unable' to be present during the initial -ses-sion; he-subsequently visited.TMI for an individual briefing. ( :Dr.'Uhrig'was unavailable for one day; however, he spent three additional days in Parsippany drafting the:first revision'of . u the Special Report and' subsequently' coordinated the: editing of ' the finalidraft;of the.Special Report. Committee,- ff. Tr. 31,749, . :ats .4.
-172-v s-!
, ,-- -- = . - ,
L TMI from May 30 to June 1, 1984 at the request of GPU Nuclear yy
- k. I to respond to the training issues raised by the Appeal Board.
-Committee, ff. Tr.~31,749-at 3; Tr. 31,789 (Uhrig). During [
- that period, the Committee was briefed extensively about the a
licensed operator training program by members of the Training and Education Department staff. Tr. 31,793 (Uhrig). These
~
briefings covered various topics ranging from the establishment , of procedures to keep the replica simulator up to date'with fu-ture'plantichanges, Tr. 33,277 (Christensen), and GPU Nuclear's efforts regarding INPO's accreditation of the TMI-1 training program including a discussion'of the TMI-1 Self-Evaluation Re-port-("SER"). submitted to INPO, Tr. 32,044-45 (Gardner), and
.;fhe development of TMI-specific job / task analyses based upon the INPO job / task analysis. Tr. 33,324-25 (Christensen). "Ap-proximately one-third to one-half of the Committee's time at TMI-was' spent in briefing sessions-with GPU Nuclear personnel.
r,. Tr. 31,794.(Uhrig). .The briefings were structured such that p. GPU Nuclear staff members were available to answer any ques-tions that the Committee had regarding the training program. This: allowed.the Committee'to assimilate. efficiently a-great deal of:information. :See Tr. 32,023-24 (Gardner).80/.
,80/3: In the' course of_its subsequent work, seeLdiscussion; .
infra,:the Committee determined that it had assimilated all of
- the'informationicontained in the Report quite accurately. See'
'(Continued Next Page)' '
~
-173-
_.g.p .
- . N
. - y _
229. The Committee also received and reviewed a s(~.)) great deal of documentary material, including ALAB-772, relating to the various aspects of the training program and the remanded. training issues. See Committee, ff. Tr. 31,749, Spe-cial Report, Table A-2. These documents provided the Committee with detailed descriptions of the various aspects of the training program, including procedures for exam construction and administration, instructor development, exam security, and operator training. Among these materials were various assess-
.ments.of the training program by the NRC and independent con-sultants.
230. The Committee further testified that their ini-tial? session included both guided and unescorted tours of the TMI' training facility, a tour of the TMI-1 plant, including the (Continued) Tr. 32,024 (Christensen);1see also Tr. 33,185.(Persensky). The Committee did discover, however, that the Report l failed.to
- state that Mr. Frederick, former Supervisor of Licensed Opera-tor Training, failed his SRO instructor certification.for.TMI-1 when;he took the exam in March, 1984. Tr. 31,750-51 (Uhrig).
None of the Committee members could recall. learning of this fact during their May-June briefings;;however, both Mr. Leonard and Dr. Coe recalled relating this fact to. Committee-members. See Tr. 31,958-60'(Uhrig,LGardner, Kelly, Kimel, Christensen);
' compare Tr. 32,354 (Coe); Tr. 32,465-68 (Leonard). -Apparently, this was the one fact-that was:not assimilated during the Com-
.mittee's intensive work. sessions at TMI.and Parsippany in -!
- May-June, 1984.
-174-m hY
L. i
control room, and independent discussions 81/ with a number of
,x
(_) individuals associated with the training program. Committee, ff. Tr. 31,749, at 4, and Special Report, Table A-1; Tr. 31,793 (Uhrig). The Committee testified that GPU Nuclear did not im-
. pose any limitations on its contacts with individuals or its pursuit of information. Committee, ff. Tr. 31,749, at 4-5.
231. During the first three days of review at TMI, the Committee was essentially involved in data-gathering, topi-cal discussions and the development of.an approach to address-ing the remanded training issues. See Tr. 31,797 (Christensen, Gardner). -The Committee members then disbanded, taking with them-much of the voluminous material which they had received to continue their review of the training program independently. Tr. 31,796 (Uhrig): Tr. 31,798-801 (Uhrig, Kelly, Gardner). 232. The members of the Committee tended to focus on those topic areas most closely associated with their respective areas of expertise and experience when they conducted their as-sessment.of the training program. Thus,.Dr. Christensen fo-cused.on the adequacy of the simulator programs, Dr. Gardner
< focused on the-educational quality of the operator training
~
81/-'For example during one such discussion, Mr. Kelly probed Mr. Boltz, an SRO and (then) Supervisor of Simulator Instruc - tion, about operator attitudes with respect to the-training program. Tr. -31,837-38, . 32,027 (Kelly) .
-175- ,m S /
programs, Mr. Kelly and Dr. Kimel concentrated on the substance
. (~~\ 'x/ of the program, and Dr. Kimel and Dr. Uhrig paid particular at-tention to the management issues of interest. The Committee members _ testified that they did not restrict their review to topics that were within their areas of expertise, but instead 4
reviewed as much information as personally feasible, particu-larly since'the topics were not mutually exclusive. See Com-mittee, ff. Tr. 31,749, at 25. 233. The Committee reconvened from June 6 through June'8 in Parsippany, New Jersey, site of GPU Nuclear headquar-ters.32/ The Committee members worked long hours during this session which was devoted to the drafting of the Special Re-port. The' Committee members drafted sections of the report'in-dependently and met as a group several times each day to dis-cuss those sections of the report that needed improvement. Tr. 31,804-05 (Uhrig). The Committee left Parsippany on Friday, June 8,. leaving Dr. Uhrig to complete the organization of the g2/ Dr.~Kimel spent part of the second day; June 7, at TMI-where he talked extensively with Mr. Newton, Manager-Plant-Training, Mr. Irizarry, (then) Simulator Development Manager, Mr. Boltz, (then) Supervisor-Simulator Instruction and Mr. Gifford, Vice President Communications. Tr. 31,803-04 (Kimel). The'BPTS was demonstrated for Dr. Kimel at-that time. Id. Dr. Kimel further testified that he had reviewed the cheating.inci-dents and Mr. Newton's responsibilities as Supervisor Licensed
-Cperator.. Training during that visit. Tr. 32,015.(Kimel). Dr.
Kimelfalso spent part of'his time at TMI reviewing-the Opera-tions-Plant Manual.. Tr. 31,825 (Kimel).
-176- ,3 Q) -
i
s ,
<first; draft of the Special Report on June 9. Tr. 31,805-06 1(~t
- ss/ -
(Uhrig)' . From that date until June 27, the Committee members
-cont.nued their review of the training program and~ called in Ithe'ir corrections to Dr. Uhrig, who had assumed primary respon-
- sibility for the final organization and editing of the Special Report ^. See Tr. 31,808-14 (Uhrig, Kimel, Christensen, Kelly, Gardner). Dr. Uhrig estimated that he devoted 3 days to this
- process;.Dr.-Kimel, 3 days; Dr. Christensen, 15 days; Mr.
Kelly,' 2 days; and Dr. Gardner, 10-15 days. Tr. 31,811-14
.(Uhrig, Kimel', Christensen, Kelly, Gardner). The various revi-sions of the-report that resulted from this process were for-warded to Dr.'Coe, who-assigned other GPU Nuclear personnel to correct factual errors. Tr. 31,829 (Uhrig). Dr. Uhrig
- testified that the:cu'mination'ofi this overall process came on
- June 28,-1984, when theiofficial copy of the Special Report,was
- transmitted to:Mr. Clark,/ President, GPU Nuclear. Tr. 31,811 I(Uhrig). ,
y,
'234. The. Committee's May-June rev'iew of the TMI-l licensed 1 operator training l program-tol address the remanded
[ . training issues'ent' ailed-a sweepingLreview of the licensed;op-eratorftraining-; program. Tnrough extensive:' document review,
'intensivebhiefingsby[Trainingand-Educationmanagementper-i isonnel'and a'l'imited degree of:first-hand review, thefCommittee-
~
~
,- ' investigated:the remanded issues.. During that; time;1the;
.-177-r< > -
s /> >.
~
.j \ g-'N 7
u
h
- 'following-subject areas of the TMI-1 licensed operator training i program were investigated by the Committee.
l 235. ' Cheating. The remar.d essentially was based on
-the Appeal Board's concern about the OARP Review Committee's
-opinion of the TMI-l licensed operator training program "in light of-the' cheating incidents" which occurred after the issu-ance of the 1980 OARP Report. ALAB-772, 19 N.R.C. at 1234-35; 1 4', supra. The Committee reviewed the training program with that in cind; however, as the Committee's testimony reflects,
. _ cheating is a very difficult issue to address, and the reasons t. for it are even more enigmatic. See Committee, ff. Tr. 31,749, at'5;;Tr. 32,032-34 (Christensen, Gardner). The Committee, therefore, concentrated its efforts on reviewing the responsive steps taken to prevent cheating in the future, rather than'en-gaging in'what they considered a valueless'and'perhaps._impossi-ble attempt to determine what each of.them would have thought. had they known that conditions existed that subsequently-per-
. mitted cheating to' occur on:NRC and'Licenseefexams.g3/:
; g3/- The Appeal Board directed the.following questionftojDr.
Gardner specifically:f"itLis essential ~to know if Dr. G&rdner's.
-favorable. opinion of'the Operator Accelerated Retraining. Pro-gram...would be altered by the subsequent knowledge of; cheating:
on licensee :and ?NRC examinations. " 19 N.R.C. at 1234. :In the N Special Report,;Dr. Gardner, stated that his opinion would not haverbeen altered. Committee,1ff. Tr._31,749,. Spec'ial Report <
.at'68-71. .Dr. - Gardner also' = addressed the Appeal Board's con-(Continued'Next Page)1 f.
, -178 -
'{
A s [ % < I" w
I> l I, Committee, ff. Tr. 31,749, at 6; Tr. 31,916 (Uhrig). Conse-
" L' quently, through discussions with training management personnel and documentary review, the Committee focused on GPU Nuclear's precautionary efforts to prevent cheating in the future. In particular, during the May-June review, the Committee evaluated exam security procedures and management communications with !
{ Operations and Training personnel. See Committee, ff. Tr. . t 31,749,-at 6,'22-24; id.,.Special Report at 26-27, 75-78; see also Long & Coe, ff. Tr. 32,202, at 5-12. 236. } Training Resources. The Committee' received and i reviewed information regarding: the GPU Nuclear Training and ,
. Education ("T&E") Department budget and staff; the qualifica-
.tions and performance of the management responsible for the T&E j
-Department; the TMI training facilities; the BPTS;Jrnd the num-ber'.and qualifications of the li' censed operate irutructors during-their'May-June re'iew. v Committee,-ff. c. 31,749,4 at. <
. j i 17-10. .
d.-? ,o o 5'
~y.
.( r m
' q, '
^'
j(Continued) 7
-cern regarding-the Committee's opinion of the involvement in ~
cheatihg of one or more of'the instructors evaluated-bystiiy
- original OARP Committee:and:found it of no present-conce .co '
y; him. :See ALAB-772, ,19 N.R.C. Tat 1235; and see. Committee,jff.;
.Tr. 31,749,..Special<Neport;at 71-72. e^ '
s l' _ , t' o.
,J <
s Cl
- h. -179- .
T l u1_ '
,1
-n1 .
a , c
.i i
- +,_ ,
// ., ,
'v ir 3 V
. , + .
. _ .' _ , , _ _ _ _ _ _ _ _ __ ____L__________________ . _ _ _ _ _ _ _ _ _1 _ _ _ _ _ _ _ _ _ _ _ _ ._ _ _ _ _
E i h 237. Program and Procedures. The Committee received and reviewed a wealth of information pertaining to the various TMI-1 licensed operator training programs and procedures during their May-June evaluation of the training program. The Commit-i tee reviewed the instructor development program, including in-structor job descriptions and specifications, the procedures [ for instructor evaluation, curriculum development, development r of behavioral learning objectives, preparation of lesson out- . lines and lesson plan formats, utilization of audj e.-visual aids, instruction techniques, examination preparation, evalua-tion techniques, and counseling techniques. See Committee, ff. ( Tr. 31,749, at 10-14; id., Special Report at 20-22. E 238. The Committee also reviewed information per-taining to the integration of simulator training into the licensed operator training program, particularly information ( pertaining to the utilization of the PSI (B&W) simulator pro-h grams (including ATOG training), the BPTS, the control room
, mockup board and the future implementation of the replica si- -
mulator for TMI-1. See Committee, ff. Tr. 31,749, at 13, g 15-18; id., Special Report at 60-63. 239. Examination construction procedures, including
'those procedures requiring instructors to code their exam ques-tions with respect to its content and the ment 1 process b
r
-180- :
, .e
.. 9
l required to respond thereto, were also evaluated by the Commit-p)' 6_ tee." See Committee, ff. Tr. 31,749, at 14, 19-21; id., Special Report at 23-24. Mr. Kelly also testified that he had evalu- - ated a sample of the 1982 (Cycle 9) and 1983 (Cycle 10) written RO and SRO requalification examinations, answer keys, and indi-vidual results on these written examinations. Committee, ff. Tr. 31,749, at 21; id., Special Report at 48. Mr. Kelly re-viewed these examinations to determine whether the scope and technical content of the questions were appropriate. Tr. 33,283-84 (Kelly). In connection with his review of these ex-Laminations, Mr. Kelly also reviewed licensed operator training program descriptions to ascertain the scope and content of the requalification program. Tr. 33,283.(Kelly). 240. Communications. The Committee's May-June re-view of the licensed operator training program and.the remanded trainingLissues included an evaluation of the lines of communi-cation,between Management, Training, and Operations personnel.
-The' Committee's evaluation of this issue consisted of discus-sions with'Dr. Long, Vice President,' Nuclear Assurance,-Dr.
Coe, Director,~ Training ~and Education,- Mr. Hukill,-Vice Presi-ident and Director,.TMI-1, Mr. Newton,- Managar, Plant' Training, , Land Mr.'Gifford, Vice-President,-Communications. Tr. 31,957 v.. (Kimel). -Dr. Christensen testified that during these meetings
.the Committee:was briefed on the procedures for receiving and
-181-
- p.
.N h-s a s t
+
~
, , , ~. , . - , w , , , - - - - , -, . .. - : :
~~'
F utilizing feedback from GPU Nuclear personnel relating to exam-p).
's ination and training procedures, among other things. Tr.
33,344-45 (Christensen). The Committee also conducted a cor-
- roborative documentary review through which they were apprised of a' number of communications channels (e.g., formal interviews with operators by the Vice President / Director of TMI-1; opera-tor certificati'no procedures; employee meetings on site held by the Vice President of Nuclear Assurance; and management off-shift tours). Committee, ff. Tr. 31,749 at 22-24; id., Special
' Report at 75-81.
241. The Committee's initial review of the TMI-1 licensed operator training program was an extremely demanding and painstaking process. The Committee devoted approximately 30-40 man-days to its initial review. Tr. 32,102 (Uhrig). 242. After issuance of the Special-Report, the Com-mittee dedicated approximately-160 to"200 additional man-days R to'a more exhaustive review of the training program. Tr. I
~32,102;(Uhrig); 32,109 (Kimel). 'This review involved extensive l - first-hand analysis of the relevant documentation and addition-al"first-hand observations of the training program and person-
- l. .
. nel. See Committee, ff.-Tr. 31,749, at-24-25. The Committee member's undertook this subsequent review to assure themselves
-that they retained confidence in andl soundly endersed the
-182-
,ey ,
y
- c. . i
conclusions reached in their Special Report. Committee, ff.
-(]
Tr. 31,749, at 25; Tr. 32,103-04 (Uhrig). In light of the sig-nificance of the Committee's current opinion of the training ! program to the remanded proceeding, the fact that the Commit-tee's opinion is based upon its overall assessment of the training program, and the concerns raised by the NRC Staff and UCS regarding the Committee's review, it is important to address the Committee's subsequent assessment of the TMI-1 licensed operator training program.
- b. Committee's Subsequent Assessment 243. The Comnittee raassembled at TMI on August 13-15) 1984. Tr. 31,972 (Uhrig). Lic'ensee invited the Commit-tee members to spend as much time as they had available to'ob-serve and review =the licensed operator training program first-
. hand. Tr. 31,972 (Uhrig). -The Committee testified that they accepted _ Licensee's invitation to undertake a more extensive investigation in order to confirm or refute the Committee's
. conclusions based upon its initial assessment, and to'better prepare the Committee members to apprise'us of the foundation for their conclusions during the course of the_ remanded hear-ings. Tr. 32,103-04 (Uhrig).
244. We received detailed testimony from the Commit-tee members'regarding.their' evaluation of training procedures-7"y -183-
- C/
i l and materials. Mr. Kelly reviewed emergency procedures, ! yS ! k/ including the ATOG training summary and the walk-through pro-gram and procedures. Dr. Kimel also reviewed the ATOG training summary and walk-through program. Dr. Kimel, Dr. Gardner and
-Mr.' Kelly reviewed the RO and SRO initial and requalification training program descriptions. Dr. Gardner and Mr. Kelly re-viewed the GPU Nuclear Instructor Development Program, the In-structor Indoctrination / Qualification Training Program, the In-structor Evaluation Procedure, the so-called Leonard Memo (Jan.
1984) on Exam Construction, the procedures on exam control and recent RO and SRO examinations. Dr. Uhrig was briefe,d on the procedures to ensure that the training program reflects the current design of the plant when he was briefed on the proce-dures for keeping the Operations Plant Manual up-to-date with plant modifications. The Committee familiarized itself with , the work of the T&E Advisory Council. The Committee also read the testimony of Licensee's witnesses, which describes the
' licensed operator training program and related issues, as well as the-depositions of Licensee's witneeses and Licensee's interrogatory responses on this issue. Committee Rebuttal, ff.
Tr. 33,320, at 3; Tr. 31,948 (Kelly); Tr. 33,276 (Uhrig). 245. The Committee conducted a number of interviews of GPU Nuclear management, and Training and Operations person-
.nel for the purpose of gaining first-hand impressions.of the
-184-7-)
v y e= m e, w - y ---
E ) quality of the personnel involved in the licensed operator
;O training program and to get their views about and attitude to-wards the training. See, e.g., Tr. 32,062-63 (Uhrig); Tr.
32,063 (Kimel)'; Tr. 32,067 (Christensen). Dr. Gardner, Mr. Kelly and Dr. Christensen interviewed 5 licensed operator or simulator instructors,84/ 4 replacement operators, and approxi-mately 27 licensed RO's and SRO's including all six shift
-supervisors who are the on-tha-job supervisors. Committee Re-buttal,-ff. Tr. 33,320, at 4. Dr. Uhrig testified that he asked operators about such things as their responsibilities, their present attitudes about the cheating and Licensee's re-sponse thereto, and their attitudes toward training. Tr.
- 32,062-63/(Uhrig)~ . Dr. Kimel added that.he asked operators
! - about-their feelings regarding the quality.of training-instruc-
-tors. Tr. 32,064-65 (Kimel). Dr.-Gardner testified thatlhe
~ and Dr. Christensen preferred to interview operators together
~
- r. E so that one.of them would be free to pick up on weak responses
'.' . thereby making it difficult for-an. interviewee to stand on an-
- : incomplete or evasive response. .Tr . 32,067, 32,155,.33,279
- (Gardner). Mr. Kelly testified.thatchis earlier interviews =of"
' licensed.op'erators had. addressed ~ operator. attitudes toward I"
i ~
~
;8_4],.Dr.' Christensen' testified that.he also engaged.in general discussions about.the1 program with two other licensed operator ~
instructors. .Tr. 32,155;(Christensen).
-185-I
'--f 6
w e -,e---r- 9 a , , ,,*-.-.----4 .- =w - - - - < > v + .r--. 6 , -
_ training and areas of improvement, and that his later inter-
~Al views also included questions related to the RHR Report. Tr.
t 31,843-44, 31,848, 31,855 (Kelly). Mr. Kelly further testified that he had interviewed operators with respect to their opin-
. ions of the quality of the training instructors and their opin-ions of the instructors' attitude-toward them. Tr. 32,068-69 (Kelly). The Committee's testimony indicated that it had con-ducted its interviews of operator instructors in similar fashion. Tr. 32,070-71~(Kelly, Gardner). Mr. Kelly testified that he had also conducted less formal discussions with several operators and instructors concerning debriefings undertaken to prevent negative transfer from the B&W simulator to the TMI-1 control room. Tr. 32,074.(Kelly). The Committee finally noted
, .that although the operators interviewed were usually designated j -aus available by the shift supervisor on duty, it had no reason
' ~
to believe_that any operators were either preselected or inten-tionally_ restrained from interviewing. Tr. 31,859-60 (Gardner, T Christensen); Tr. 33,278'(Gardner, Kelly, Christenson, Uhrig,
~Kimel).
246. .All five Committee-members have had significant
. interaction with the Vice' President of Nuclear Assurance,-Dr.
l~ Long, the Director of T&E,.Dr. Coe, the Manager of Plant
, Training, TMI, Mr. Newton and the_Gperator Training Manager,
! ')Mr.~ Leonard. Mr. Kelly..and Dr. Uhrig spent time-with the new
.- -186-
\ <
b
e s Supervisor, Licensed Operator Training, Mr. Maag, discussing (~ S training' issues with him. Committee Rebuttal, ff. Tr. 33,320, at 4. The Committee met as a group with Mr. Hukill. Id. Moreover, Dr. Uhrig-and Dr. Kimel met separately with Mr. Clark and with Mr. Hukill. Id. During his discussions with Dr. Kimel and Dr. Uhrig, Mr. Clark addressed the selection of training managers, the appointment of Dr. Long to Vice Presi-dent, Nuclear Assurance, GPU-Nuclear's disposition of Mr. H, and the priorities assigned to the training program as mani-fested by the resources devoted thereto. Tr. 31,928, 33,282-83, 31,941, 32,162-63 (Uhrig, Kimel). Mr. Kelly, Dr. Gardner, Dr. Christensen and Dr. Kimel reviewed simulator training with Mr. Irizarry, (then) Simulator Training Manager, and with Mr. Boltz, Supervisor of Simulator Training (who has now replaced Mr. Irizarry) at TMI. Committee Rebuttal, ff. Tr. 33,320, at 4. The Committee further testified that it met with Mr. Ross and Mr. Hukill. At these meetings, Messrs. Hukill and Ross explained the reasons for their satisfaction with the traininc program and the licensed.cperators ability to trans- , fer:the knowledge gained therefrom to job-performance in the plant. Tr. 32,138-39 (Uhrig). As part'of'this review,- Mr. Ross;gave all five Committee members a tour of the plant and explained-the impact of various aspects of the licensed opera-
~
' tors' training. Tr. 32,138-39 (Uhrig).
.a7-7-)
\>
,m 247. The Committee's classroom observations involved
- ~t he visitation of a cross-section of classes given to TMI-1 licensed operators or given by TMI-l licensed operator instruc-
-tors. Committee Rebuttal, ff. Tr. 33,320, at 4. Mr. Kelly ob-served 8 classes. Tr. 31,910 (Kelly). Dr. Gardner observed 7 classes. Tr. 31,894 (Gardner). As part of his review, Dr.
Gardner testified that he carefully reviewed the procedures concerning the development of lessen plans; and that he fre-quently spoke with instructors after observing their classes and reviewed the lesson plan for that particular class. Tr. 31,944 (Gardner). Moreover, Mr. Kelly reviewed the lesson plans' technical content and checked them to assure himself that they reflected the current plant design. Tr. 31,946 (Kelly). Both-Mr. Kelly and Dr. Gardner also visited a sample of non-licensed operator classes and two BPTS classes. Commit-tee Rebuttal, ff. Tr.133,320, at 4-5. Dr. Kimel observed 8 licensed operator training. classes. Tr. 31,906-09 (Kimel).
,,J' And Dr. Christensen' observed 4-6 classes. Tr. 31,898 (Chris-tensen). Dr. Gardner, Dr. Kimel'and Mr. Kelly observed the TMI-1 control board mockup while it was being used as a training device. Committee Rebuttal, ff. Tr. 33,320,.at 5.
Dr. Gardner also observed instructors using an overhead projec-tor and various hand-out materials. 'Tr. 32,158-59 (Gardner). 4 -188-- (j
248. With regard to the Committee's supplemental re-
- p/
N- view of simulator instruction, Dr. Christensen went to the B&W simulator in order to observe implementation of the TMI si-mulator program and, particularly, the quality of the instruc-tion given in the classroom and at the simulator to TMI-1 operators. Committee Rebuttal, ff. Tr. 33,320, at 5. Mr. Kelly also visited Lynchburg for this purpose. Id. While there on one occasion, Mr. Kelly observed B&W instructors per-form casualty drills for Crystal River operators as part of his assessment-of their qualifications. Tr. 33,280 (Kelly). This review was considered relevant because TMI operators undergo similar drills with the same instructors. Id. All five Com-1mittee members were briefed on and observed the use of the BPTS. Committee Rebuttal,'ff. Tr. 33,320, at 5. In addition, Mr. Kelly observed four hours of BPTS training and four hours of demonstration of specific B&W PWR operating characteristics. Id. During this visit, Mr. Kelly was able to review a demon-stration of how the BPTS-causes an operator-to use his problem'
' solving skills. Tr. 32,080 (Kelly). Dr. Christensen was briefed on GPU Nuclear's plans to keep the replica simulator-current with plant design modifications and their plans-to-avoid negative transfer. Committee Rebuttal, ff. Tr. 3' 3 ,320, at 5; Tr. 32,078-79, 32,124-25 (Christensen). Mr. Kelly also discussed with several; operators Licensee's measures to avoid
-189-O x
-negative transfer. Tr. 32,074 (Kelly). Through these discus-(3/
1^ 'sions he learned that: 1) trainees are briefed regarding the differences between the TMI-1 control room and the PSI (B&W) simulator; 2) instructors use TMI procedures; 3) instructors address differences between the TMI control room and the si-mulator during the training session; 4) trainees are. formally-debriefed after the simulator session; and 5) trainees infor-mally discuss the differences between the simulator training and the TMI control panel and procedures. Tr. 31,875-76 (Kelly); see also Tr. 32,068 (Kelly). 249. Mr. Kelly, Dr. Christensen, and Dr. Gardner ob-served the administration of several exams and verified compli-ance with the: control of examination procedures by following a GFU Nuclear check-off list of exam administration procedures. Committee Rebuttal, ff. Tr. 33,320, at 5; Tr. 32,081-82 (Gard-ner, Kelly, Christensen). Dr. Gardner discussed exam adminis-tration with several instructors. Tr. 32,083 ,(Gardner). In addition, the Committee further assured itself that exam secu-rity' procedures are effectively implemented through briefings and document review. Tr. 32,081 (Uhrig). 250. Dr.'Gardner and Mr. Kelly also conducted a sub-stantive review of Licensee's examination process. .Mr. Kelly and_Dr. Gardner' reviewed all of the BO and SRO 1982 (cycle 9)
-190 -
i-l
. , . =. ~ . -- -. . - -. . - .
+
b
~
-and 1983-(cycle-10) written requalification examinations. Tr.
131,882-84 (Kelly). Mr.- Kelly reviewed these examinations to assure himself that their scope and content addressed the mate-rial taught in the requalification program. Tr. 31,883 (Kelly). He also reviewed the answers to ascertain whether these- exams contained a proper balance of theoretical and pro-L l cedural questions. Id. Dr. Gardner and Mr. Kelly utilized the GPU Nuclear exam construction matrices, which are designed to r ensure that-all exams cover the proper subject material and I Itest appropriate mental processes, when they reviewed the , requalification exams to assess the level of memorization re-E : quired and the technical content of the exam questions. Tr. {, 133,280-81, 33,283'(Gardner, Kelly). Mr. Kelly's assessment - also; included a review of the process employed to update the
~
h~ questions in the exam bank. . See'Tr. 31,888-90 (Kelly). Mr . ; Kelly" reviewed the failure rate for cycles 9 and lb in order to assure-himself that those individuals who failed were properly ll, requalified'and ratested'.85/ Tr. 32,172 (Kelly). Mr. Kelly j; also. reviewed the results of Licensee's oral-and simulator P
; 185/ -Mr. Kelly testified that the-failure. rate'for the~1982 and-U > 1983 requalification exams was considerably' lower at'TMI than .
atisome otherJfacilities-because the!TMI training program is t very well1 established, and well implemented by-qualified T&E' ' management and staff. Tr. 32,173-74 (Kelly). He also stated. that the lower failure rate'wasiattributable to the operators' motivation to do'well on exa's. m Tr. 32,174 (Kelly).
-191-
- A 8 i' .
I exams. Tr. 31,864 (Kelly). In addition, Mr. Kelly reviewed s the licensed operators' NRC exam passage rate; however, the Committee did not rely on this information when it formed its opinion regarding the adequacy of the licensed operator training program. Tr 32,085-87 (Kelly); Tr. 31,967 (Kelly, Kimel', Gardner, Uhrig, Christensen). 251. The Committee's initial assessment of communi-cations mechanisms consisted of discussions with T&E management and the review of documents evidencing communications channels and management's encouragement thereof. The Committee testified that its subsequent assessment also included a review of_the numerous corporate memoranda encouraging the development of strong communications channels. More importantly, however, the Committee's subsequent assessment included interviews with licensed operators and instructors during which their attitude regarding the communications mechanisms in place were . addressed, in addition to corresponding discussions _with Messrs. Clark, Hukill, Long, Coe, Newton, Leonard and Ross. See. Committee Rebuttal, ff. Tr. 33,320, at 6. 252. Members of the Committee reviewed documents describing the instructor development program, Licensee training instructor criteria and procedures for instructor
' evaluation. Instructors were evaluated in particular by Dr.
-192-W
-(_)
w v , , - , ~ , . - - , ,
Gardner (education specialist) and Mr. Kelly (subject-matter expert). Dr. Gardner reviewed the performance evaluations for each of the TMI-1 licensed operator instructors for 1983 and 1984. Dr. Gardner and Mr. Kelly then compared their own as-sessments of the instructors wl'.h GPU Nuclear's to assure them-selves of the expected consistency between the two. Dr. Gard-ner and Mr. Kelly also attended portions of the most recent instructor development program and observed first-hand its structure, content and execution. During this time, Dr. Gard-ner and Mr. Kelly had the opportunity to obtain several in-structors' views of the instructor development program. Dr.
-Christensen, Dr. Kimel and Mr. Kelly also observed the~ training of two instructors on the use of the BPTS as an instructional device. Committee Rebuttal, ff. Tr. 33,320 at 6; Tr. 31,907-08 (Kimel).
253. Dr. Gardner and Mr. Kelly reviewed licensed op-erator instructor resumes, audited classes utilizing Licensse's s operator instructor evaluation sheet, reviewed instructor per-formance evaluations and interviewed them in order.to_ assess their qualifications, professionalism, pride, enthusiasm and
.the quality of their instruction. Tr. 31,911-14 (Kelly, Gard-ner); Tr. 32,069 (Kelly); Tr. 32,076-77, 32,084-85 (Gardner);
Committee Rebuttal, ff. Tr. 33,320, at 8. f3 -193-
.J t-
254. The Committee's subsequent assessment also in-c1 tied the review of certain documents that the NRC Staff's witnesses suggested were germane to an evaluation of the TMI-1 e licensed operator training program, especially with regard to operator attitude. Specifically, the Committee reviewed the RHR Reportg6/ and its supporting TMI raw data and NUREG-0680, Supp. 4.g7/ However, the Committee testified that it did not rely on these documents in formulating its views because it felt that its first-hand observations were more pertinent. The Committee further testified that Mr. Kelly and Dr. Gardner had reviewed the notes of Ms. Morisseau, which we understand form the basis for the conclusions about operator attitude in NUREG-
'0680, Supp. 4, and Ms. Morisseau's deposition, in which.these.
notes were discussed. The Committee also reviewed and placed reliance on-Licensee's memorandum responding to the RHR Report.
~
Committee Rebuttal, ff. Tr. 33,320 at 7; Tr. 31,851-(Gardner, Kelly): Tr. 31,855 (Kelly); Tr. 33,297-981(Gardner); Tr. 33,322-23 (Gardner, Kelly); see Tr.'33,226-(Morisseau). 86/ See 11 220-221,- supra; nn.72-74, supra. E7/ NUREG-0680, Supp'. 4, entitled: "TMI-1 Restart,.An Evalua-
;n tion 1of the RHR, BETA, and Draft INPO Reports as They Affect
. Restart Issues at.Three Mile Island Nuclear Station Unit'1' Docket:50-289"'(October, 1983),' documents-the Staff's review of.
. portions of the organization, management, training programs-and-
-operational. practices at-TMI-l'and-the related' findings of the RHR and BETA reports.
3c-g -194-U
^
__________-m._-____.mm_ _ _
y 255. The Committee members reviewed with Licensee its implementation of job / task analyses in the licensed opera-tor training program. See Committee Rebuttal, ff. Tr. 33,320 at~10. Dr. Christensen testified that he wra briefed on the
-job / task analysis-process by Licensee who at that time
. explained that GPU Nuclear was in the process of modifying the INPOLgeneric job / task analysis to make them TMI-specific.
- Tr.
33,324-25.(Christensen). Dr. Christensen was also briefed on the process of correlating job / task analysis with behavioral
-learning objectives in terms'of the development,-implerentation and practical applications of behavioral learning objectives.
See -Tr. 33,330-32 (Christensen) . Dr. Gardner evaluated the
? process-of correlating job / task analysis data with behavioral
] earning objectives by reviewing operator duties, behavioral-
. learning objectives.in the Operations Plant Manual and INPO's generic joo/ task analysis. Tr. 33,330-31 (Gardner). 'The Com-J.mittee was. apprised of;and reviewed the existence and:use-of performance based-behavioral 11 earning objectives,Ethe Opera-
~
-tions Plant Manual, the ' TMI Self-Evali" + 'n Report' submitted
.toLINPO,: table-top task analysis.(gene _ete rmination J of..
, , . tasks ~ required to perform.a job), plant walk-through[ on-the-- Ljob training and simulatoritraining, all of which'are= based
'upon or' relate'd;to job / task analysis.- Committee Rebuttal,-ff.
"Tr. 33,320Lat 10-11; Tr.-33,324-30 (Kimel,-Christensen).
-195-
Moreover, the Committee testified that it received and reviewed
- information on the correlation between job / task analysis data
~
'to behavioral learning objectives and exam questions. Tr.
133,330-33L(Gardner, Christensen). Dr. Kimel reviewed behav-
, ioral learning objectives, the Operations Plant Manual, plant specific task' lists and the generic INPO job / task analyses to.
. assure'himself that the licensed operator training program is performance based. Tr. 33,325-27 (Kimel). In addition, Dr.
Christensen received a briefing on table-top analysis from Dr. Knief and observed plant walk-throughs for the same purpose. Tr. 33,327-28 (Christensen)~. The Committee also evaluated the process for translating job / task analysis data into exam ques-tions. Dr. Christensen was briefed on the process whereby tasks. identified from the job / task analysis will be.evaluatsd-to assess the best method to teach the task (e.g., classroom, simulator, using a teaching-aide, etc.). Tr. 33,332 (Ch'ris-i b tensen). Moreover, Mr. -Kelly and Dr. : Gardner . reviewed the:
.requalification exams:to determine whether they corresponded-r j with'the behavioral. learning objectives. Tr. 33,333,(Gardner,
- _ -Kelly).
!. 256. With regard to the. committee's review of on-
- f. '
[ .the-job training, Mr. Kelly testified that he, discussed on-the-Job training,with.TMI-l training-management. personnel. .He also
~
- ' interviewed operators to' ascertain'how they received their g, 4
l on-the-job training. Mr. Kelly inquired into licensed operator
-(
performance during operations, such as heat-ups and cool-downs. He.also reviewed check lists and qualification cards used in conjunction with on-the-job training. Tr. 33,339-40 (Kelly). 257... Finally, the Committee received and familiar-
-ized itself with the Data-Design Laboratories (DDL) report,g8/
NUREG-0680, Supp. 5, the SALPg9/ report and NRC Inspection Re-port 84-05 (operator readiness evaluation). The Committee testified, however, that it did not rely on these independent assessments, nor did it attempt to emulate them; rather, it relied on the backgrounds and experiences of i'ts members to as-sess the TMI-1 licensed operator training program. Committee Rebuttal, ff. Tr. 33,320 at 10. Eg/ . Data-Design Laboratories was: commissioned by GPU Nuclear to' conduct aus independent assessment of selected TMI-1 training programs. Its findings are documented in a multi-volume report < entitled: " Assessment of Selected TMI-1 Training Programs" (September 10, 1982). The'DDL assessment was conducted by a team of ten individuals over a three month period. 8g U.S. Nuclear Regulatory Commission, Region'I: " Systematic Assessment of Licensee Performance, GPU Nuclear Corporation, Three Mile Island Nuclear Station, Unit 1" (April 2, 1984). (~T -197-LJ a
7 I cys c. NRC Staff Recommended Methodology b 258.. We received testimony from the NRC Staff which was limited to its assessment of the adequacy of the methodolo-gy employed by the Reconstituted OARP Review Committee during its' evaluation of the TMI-1 licensed operator training program with respect to the remanded training issues. Staff, ff. Tr. 33,148, at 2.90/ The Staff presented what it considers to be an appropriate methodological approach to assessing the licensed operator training program in light of the remanded training issues. The Staff presented its evaluation of the-JCommittee's methodology by comparing its recommended methodolo-
..gy to.that utilized.by the Committee. Staff, ff. Tr. 33,148, ,
. at 3.91/
1 90/- The three Staff witnesses were-Dr. Julius J. Persensky,
. Ms. Delores S. Morisseau and Mr. Joseph J. Buzy. Dr. Persensky 11s Section: Leader of The Personnel Qualifications Section, Licensee Qualifications Branch, in the NRC's Division of Human Factors Safety. He holds a B.A..in Psychology, a M.A. in Ex-
.perimental~ Psychology, and a Ph.D..in Applied Experimental-Psy-chology. Ms. Morisseau is a Training and Assessment Special-
-ist, Licensee Qualifications Branch,. Division of Human Factors iSafety. She holds a B.A. in PsychologyLand a M.A. in~Industri-al Psychology. Mr. Buzy, .the Staff's subject matter expert in; this case, is a Systems Engineer:(Training'& Assessment), Per-sonnel-Qualifications Branch, Division of Human Factors Safety.
Mr. Buzy holds a.B.S.-in Marine Engineering in' addition to his
-vast experience in the. nuclear power field overLthe past.20 years. Staff, ff. Tr. 33,148, attached qualification: state--
si- -- ments.
' 914 The Board 1 notes that neither the methodology 1to be.em-g ployed by the Committee, nor'the requirements for.any Committee.
(Continued Next Page). l D. t_/ -198-f C ,, ..-e.+ , , .
l ' L
)l 259. The Staff outlined approximately 110 steps that it felt could be taken or items that could be reviewed in an evaluation of the TMI-1 licensed operator training program in accordance with the Appeal Board's remand.92/
260. The Staff recommended that an appropriate review of the. training program should include the review of the fol-lowing documents: the 1980 OARP Committee Review Report, LBP-81-32, LBP-82-34B, LBP-82-56, ALAB-772, the DDL Report , (September 10, 1982), NUREG-0680 (June 1980) including Supple-ments 1 through 5, the RHR Report ,(March 15, 1983),-BETA Report (Continued) report are addressed anywhere within the Appeal. Board's' remand of the-training issues. While we agree that the bases for the,
' Committee's findings are significant and subject to_ challenge,
-we'are not certain that the method of gaining that.information
-is'significant absent any showing that-we should doubt the,ac-
--curacy of.the inforcation presented to us by the: Committee.
Nevertheless,~ a discussion of the Staff's concerns regarding. the methodo]ogy employed by the Committee'when it evaluated the training program would be of some value.- 192/ _In its-testimony, the Staff acknowledges that-it does~not conduct =its own reviewt.of licensee' programs using the method - ology it proposes. The Staff explains.this as reasonable be-cadse the Staff is constrained by law in:what it'can: review, and its-inspection program provides the Staff.with regular
.. input on'the status of training at licensee facilities.~: Staff, ff.;Tr.:33,148, at 33,175-76 (Persensky). The: Board need not address:the merits of the Staff rationale. The fact is that the1 staff. recommended'a methodology it felt the' Committee'could Lh ave used,-and evaluated the Committee's work against that-fmethodology.
-199 -
h w 1,. ..v,..., ,. , , . . . . .
- r. . .
_ _ . _ _ _ _ _ _ _-_______z_. n_
,_ (February 28, 1983)93/ and the INPO Annual Report (1983), in addition to the training pre;cuures and training materials (e.g., lesson plans, learning objectives, examinations) rele-vant to the remanded issues. Staff, ff. Tr. 33,148, at 8-9.
The Staff's methodology would also include interviews with training managers, licensed operator instructors, shift super-visors and operators, and observations of classrooms, instruc-tors, and examination administration (written, oral and si-mulator). Staff, ff. Tr. 33,148, at 9. The Staff would
. approach its assessment of the training program in accordance with the three topical categories that it derived from the re-manded training issues. These categories are: 1) management /
communications / attitudes; 2) training systems / programs; and 3) GPU Nuclear examinations. Id. at 10. 261. In the Staff's opinion, an appropriate assesn-ment-_of its'first category (management / communications /atti-tudes) would essentially consist of a series of interviews with training management, instructors and operators, as well as an extensive review of relevant documents (e.g., documents 93/ GPU Nuclear commissioned Basic Energy Technology Assoc 1-ates, Inc. (BETA) to-review GPU Nuclear, including the TMI-1 Training Department, from a cost efficiency standpoint in December, 1981. ' BETA's findings are documented in its report entitled: "A Review of Current and Projected Expenditures and Manpower Utilization for'GPU Nuclear' Corporation." (February 28, 1983). See ALAB-738, supra, 18 N.R.C. at'198-99.
. 't 'i (j -200-
concerning communications mechanisms, management resumes and O~# job descriptions, instructor resumes and performance evalua-tions, documents concerning the instructor development program, E- the RHR Report, NUREG-0680, Supp. 4, the DDL Report, and docu-ments concerning attrition rates and absenteeism). Id. at 11-19. Specifically, an evaluation utilizing the Staff's meth-odology would include interviews with: training managers regarding communications mechanisms and the effectiveness of , the-instructor development program; operators with respect to their opinion of the quality of the instructors, their percep-tion of communications, their attitudes toward the training program, and their level of " pride and enthusiasm";94/ and the training staff to ascertain their assessment of operator atti-tude and communications mechanisms. Staff, ff. Tr. 33,148, at 11-19. The Staff's methodology would also include classroom observations by a subject-matter expert to review the quality of instruction, instructor attitude, .cparator attitude and course content. Finally, the Staff recommends that an evaluating party review: organizational documents to determine the structure of the training program and its relationship to corporate and plant management structure; documents concerning 94/ The Staff's methodology suggests that interviews regarding operator pride and enthusiasm'should utilize questions that parallel the RER' survey questions. Staff, ff. Tr. 33,148, at 16. ('} -201 , _J - g .
.. . . - - . - - . ~ . ~
-- v 2 - ,
~
3- training department staff qualifications and job specifica-s O .tions, especially those of Messrs. Long, Coe, Newton and 1 Frederick, to ensure that they are qualified to serve in their positions; documents related to the cheating incidents to in-vestigate the involvement (if any) of these individuals; and documents describing the instructor development program, including instructor criteria and instructor evaluation proce-
-~'dures'and records of instructor attendance in addition to a re-view'of the aforementioned documents. Id.
262. The Staff's recommended approach :o the evalua--
, ? tion ^of'its second category (training. systems / programs) is=ded-
~
'icated in large part to-ensuring that the licensed operator
- training'. program is' performance-based. The Staff's methodology i'*J iinvolves.the review of the job / task analysis and the procedures for linking. job / task 1 analysis data to learning objectives. The St'aff'a methodology further recommends the' review of learning
' objectives 1to ensure that they are clearly stated'and that they properlygreflect theitask analyses for each job. The
- evaluating party. should' observe on-the-job training to ' ensure Ithat;it is' consistent with job / task analyses and actual plant
~
- operations._ It;should review or, t.observe classes,; lesson plans,
- dh'andout material and simulator. training to ensureethat these l items,are consistent with program descriptions. Also,,the re-Y . s.
viewing group should; review simulator training to determine 3 ' 1
} /~1 -
' -202-f; M s .
. e Q~'.,
W! a
,4 -- -
4
~
' whether it is centered on problem-solving and symptom-based analyses. "The Staff further believes that an appropriate re-
. view would include the evaluation of the performance evalua-tions of'the operators who have gone through_the training pro-gram.95/ Staff,. ff. Tr. 33,148, at 19-20.
263. As'a part of the inquiry into the program's ade-quacy, the Staff would consider the Appeal Board's question whether deficiencies in testing were symptomatic of more exten-
- sive failures. Here, the Staff would review the cheating deci-
- sions to ascertain what deficiencies existed before, and review
.theLrelevant areas of the training program, including lesson plans,Lto determine whether more extensive failures now exist in the. training program. Id.-at 21. As to whether the
. training program enhances. knowledge rather than' encouraging memorization, the-Staff recommends first determining the extent of memorization required to perform as an operator., The re-
~
viewing group should then inspect lesson plans and class in-structi:nel' plans for inappropriate repetition and to ensure
~
'that training concepts'are integrated with plant operation
~
95sf The Staff acknowledged that GPU Nuclear does~not. maintain specific control room operator performance evaluations;'how-
,, -ever, Mr. Persensky still believes'that some effort'should be
~
'made to evaluate the performance of graduates _of the training-
. program. Tr.~33,143 (Persensky). Dr.'Regan also supports the review:of job performance evaluations as a measure.of the ade-
.quacy of the' training. .
Tr. 32,784-86_(Regan).
-203-
{ .
+ $
N- -
..,,a
, . . _ _ _ _ . - . . _ . _ . _ . . ... ._ . - .._ _ _ _ _ _ - _- _ . ~ _.
J T i 1 requirements. Classes should be observed to determine if in-P. .O structors encourage memorization through repetition and to de- l l termine if there are opportunities for discussion and team work. If memorization is required the reasons for it should be 1 Quizzes and examinations
'w explained to the reviewing group.
should be. inspected to determine the types of questions asked, b "and-the balance'between the. mental processes required to re-spond to these questions. They also should be reviewed to en -
- sure.that the questions encourage discussion of the relation-ship between concepts and operational requirements. At the
. simulator,. lesson plans should be reviewed and exercises ob- ,
_ served to. ascertain whether a variety of situations are 1- , presented.- Id.' ;,at 22-23. 264. The Staff's recommended evaluation also would require the examining party.to: . visit the TMI training center to ' assess -its. adequacy and to ' observe the instructors' use'of training aids; evaluate training expendit'ures to' determine the-adequacy and' appropriateness of ,the training programs; observe and'avaluate.the training-instructors. qualifications against j .the documented instructor criteria, in addition to reviewing the new instructor evaluation forms; .f review the siraulator training lesson plans and learning objections for consistency-
;with; task analyses; have a subject-matter expert. observe si-
.mulator training.at~ PSI (B&W) and on the'BPTS; and review the
-204-
}-
9 h
a a. , _ GPU Nuclear performance evaluations of simulator instructors.
'D Staff, ~ ff. Tr. 33,148, at 23-26.
265. Finally, with respect to the Staff's recommended methodology for assessing its third category (GPU Nuclear exam-
~
inations), the Staff witnesses testified that exam development procedures, security procedures, content, format and adminis-tration should be reviewed by direct inspection of the exams
. and by observation of-the administration of exams. To this end, the Staff testified that a party conducting an evaluation of this. issue should review: documentation describing exam se-
'curity, construction and. administration procedures for written, oral and simulator exams; exam content to ensure that it is consistent with job / task analyses, behavioral learning objec-x .
' tives and current plant design; .1xam questions-to determine-balance between responses testing recall skills and those l testing an operator's ability to solve problems and address t
' plant systems. ~The evaluating group should also observe and-review the content of simulator-and' oral exams in addition to.
reviewing them to ensure that Licensee's written exams offer an effective means of measuring-an operator's' ability to run the plant. -The reviewing party should, finally, observe the: admin-
~
istration ofLexaminations, review exam answer keys for techni-cal' accuracy,'and interview' trainees to ascertain their opinion
. of the importance of exam. integrity. Staff, ff. Tr. 33,148, at-31..
- d -205-5 i
~ ' '
u _ _ . . _ _ _ _ _ _ . _ _ . _ _ _
1 l 266. We have carefully examined the testimony of both ~(' .the NRC Staff and the Reconstituted OARP Review Committee con-cerning the Staff's view of an appropriate methodological ap-proach to addressing the remanded issues.and the Conmittee's actual methodological approach to those issues. We are struck by the similarity between the Staff's approach and that taken by the Committee when it conducted its assessment of the TMI-1 licensed operator training program. In our estimation, the Committee reviewed or observed at least 85% of the items recom-mended by the Staff. The magnitude of the remaining differ-ences.between these two methodologies is not of such a nature that we fe=1 that our confidence in the substantive findings of the Committee has or should be in any way diminished. To'the contrary, given the extraordinary expectations of the Staff, the methedology utilized by the Committee is impressive. 267. An initial comparison of the Staff's methodology against the Committee's methodology shows that both meth-odologies are designed to gather information regarding those areas of the licensed operator training program which are germane to the remanded training issues. Hence, both meth-odologies focus on. examination construction, content, adminis-tration and security; instructor development and instructor qualifications; simulator. training (PSI /B&W and BPTS); th~e im-plementation i f job / task analyses; procedures to ensure that (f) f- -206-4 _-_a- - - . - _ . . _ _ . . _ _
=
the. training program reflects current plant design; communica-
'tions mechanisms; operator attitudes; training staff and facil-ities;-and T&E management qualifications. Both methodologies called for the reviewing body to evaluate these topice through documentary review, interviews and discussions with knowledge-able management, training staff, and operations personnel, and first-hand observation of the relevant aspects of the training program. The documents, personnel, procedures and programs re-viewed, interviewed or observed or recommended to be evaluated are almost identical,' which is not surprising when one consid-
-ers that both methodologies were designed to review the same training program in order to address the same remanded issues.-
14>on closer' inspection of the evidence presented by the Staff and:the Committee, we found that our initial impression was not-
. unfounded. Although we discovered certain differences in the
; reliance placed on certain-information sources,96/ and.in the method of' reviewing certain aspects of the1 training program,-we found that both. methodological approaches are.very similar.in-deed.
268.-The Committee l reviewed all of;the documents rec-
'ommended bylthe Staff,Jwith the exception of the first three revisions of-NUREG-0680.97/ .See i __, supra; Staff, ff;-Tr' .
W - (96/- See'11 275,l288.and n.112, infra. 97/ NUREG-0680 Land:its'~first three revisions are dated-June,'
- 1980,ENovember,-1980, March, 1981,<and' April, 19811 respective-4 ly. Staff, ff.'Tr.-33'148,:at
, 8.
-207 -
4 33,148, at 8-9. The Committee addressed all of the remanded D issues identified by the Staff, and several that the Staff did not address. See generally Committee, ff. Tr. 31,749, Special Report; Staff, ff. Tr. 33,148, at 3-6. The Staff recommended a review of the training procedures and materials that were rele-vant to the remanded issues, although it did not specify which of those documents were worthy of review. Id. at 9. The Com-mittee, similarly, reviewed all of the training documents and materials concerning training programs and procedures that it
' determined to be relevant to the remanded issues, including some of those recommended by the Staff.which the Committee found to be of limited value. See Committee, ff. TI. 31,749, Attachment 1,_ Table A-2, and Attachment 7; 11 229, 254, 257, supra; n.112 infra. The Staff recommended classroom visitation-to evaluate instructor quality, exam administration, instructor attitude, operator attitude, excessive use of repetition, and instructor use of training aids. See 11 261, 263, supra. The Committee visited approximately 25 licensed operator training classes. See 1 247, supra. During the course of its visits, the Committee evaluated instructor performance and matched-their findings against the instructors' GPU Nuclear performance-evaluations; observed the administration of several written exams while following along the GPU Nuclear exam administration check-off list; observed and evaluated the use of lesson plans
-208-(J"h
- and discussed their use with instructors; observed operator and N'J instructor attitudes; observed the use of various training aids; and. assured themselves that the classes did not inappro-priately rely on repetition. See 11 247, 249, 252-53, supra.
269. With regard to interviews and discussions with knowledgeable personnel, the Staff recommended interviews of operators, instructors, and T&E management to address: operator and instructor attitudes; communications mechanisms; training staff and operator morale; operators' perception of instruc-tors, the training program, the integrity of the exam process, the cheating incidents, and the Company response thereto. See 17 260, 261, 265, supra. The Committee interviewed 27 RO's and SRO's including 6 shift supervisors, 4 replacement operator candidates, 5 licensed operator or simulator instructors and, as well, met with a number of corporate, T&E and operations managers. See V 245, 251, supra. During these interviews, the Committee addressed all of the aforementioned issues. Id. 270. The Staff recommended that the qualifications of T&E management, especially those of Dr. Long,.Dr. Coe and Mr. Newton, should be reviewed in addition to those of the operator training instructors. See 1 261, supra. The Committee testified that it did review the qualifications of the T&E man-agement and of the instructors. See 11 236, 246, 252-53,
-209-
.O ()
t
-supra.. Their evaluation included the review of resumes and
-\ performance evaluations, discussions with management, including Jprivate discussions with the President of GPU Nuclear, Mr. Clark, classroom observation, and extensive interactions with
, all.threelif the individuals highlighted by the Staff. Id.
271. The Committee's assessment included the review of-job / task analyses and the procedures for translating them to-learning objectives and exam questions, as did the Staff's methodology. See 1 255, supra. The Committee's assessment of the integration of job / task analyses into the licensed operator training program involved briefings on and the review of the INPO generic job / task analysis, the TMI-1 Self Evaluation Re-port.which was submitted to INPO, plant specific task lists, the. table-top analysis, the use of behavioral learning objec-
.tives and~the Operations Plant Manual, plant. walk-through-training, on-the-job training, and written.requalification cxams and exam development matrices. .Alllif these mechanisms 4 are either related.to, reflect Lor are based upon job /taskf anal-yses. Id.
~272. Although an evaluation could not include'therex-?
aminationof CRO performance evaluationslas ncne exist,98/ the [18/c The union contract does not provide for GPU Nuclear to
- maintain control room operator-performance evaluations. Tr.
(Continued Next Page)
-210 -
O
't
fg Staff believes that an appropriate evaluation would include the O review of some indicia of the training graduates' performance. Tr. 33,143 (Persensky). The Committee's testimony, however, indicates that it held extensive discussions with Mr. Hukill and Mr. Ross to ascertain Operations' satisfaction with the training program as manifested by the performance of the opera-tors who have been through the program. See i 246, supra. 273. The Staff recommended that an appropriate review-of the training program should include an assessmen't of the procedures in place to ensure that the lessons and exams are
~kept up to date with plant modifications. The Committee's as-sessment addressed this issue through briefings on the proce-dures in place to keep training in line with plant modifica-tions, a review of the OPM, evaluation of examination questions and examination construction procedures to assure itself that i
they reflect'and will continue to reflect current plant design, and actual first-hand observations of updating of simulator training. See 11 228, 239, 244, 250, 255, supra; n.119, infra. L-I (Continued)
-33,143 (Persensky); Tr. 33,419-22 (Ross). Evaluations there-o fore could not be used to~ affect individuals' job status. Tr.
,- 33,420 (Ross).
~ ~
k_ ) i
274. The Staff testified during the hearing that the _O- Committee had indeed performed a number of the tasks that the 2 : Staff had' recommended. The Staff, therefore, testified that it was satisfied that the Committee's assessment properly includ-
.ed: 1) a quality assurance check on the T&E management presen-tation regarding communications mechanisms, including corrobo -
rative interviews with training and operations personnel and a documentary review of the communications mechanisms in place, Tr. 3.3,141-(Persensky); See Tr. 33,530-31 (Wagner); 11 240, 251, supra; 2) observation of PSI (B&W) simulator and BPTS
. training to determine whether problem-solving skills are inte-grated into.those programs, Tr. 33,142 (Persensky); 3) a review ofLthe-budget allocated to training and a corroborative tour of.
- the training' center to observe its utilization (e.g., proper Juse of training aids) to assure-itself of the adequacy of the -
' training-facilities, Tr. 33,144-45 (Persensky);-11 230,-236, 246-247, supra; and 4) the review of documents = describing the procedures for~ examination security._and control and observation-o'f the administration of(exams in conformance with these proce-fdures,.Tr- 33,146;(Persensky); 11.229, 235,l244,-249,. supra.
275. We also;are cognizant:offseveral areas where
, differences 1 exist between;the_ Staff's~ methodology.:and that of
~
'the Committee.; The emphasis on the' significance of the.RHR"Re-The' Staff-2 port #and NUREG-0680, Supp._4.is a prime example.
4 "? -212-iG 0+ -
.r- --
Y
argues that these documents are essential to reviewing the O issue of operator attitude. Hence, the Staff's methodology would include operator interviews involving questions that were structured parallel to those found in the RHR survey so that a comparison could be drawn between the present attitudes elicited during the operator interviews, the findings in Supp. 4 and those in the RHR Report. See Staff, ff. Tr. 33,148, at 15-16. The Committee reviewed the RHR Report, the raw data re-lated thereto, NUREG-0680, Supp. 4, and Ms. Morisseau's notes; however, the Committee did not rely on this information as a basis for its findings regarding the adequacy of the training program because it believes that the first-hand observations of its members are more pertinent.99/ See 1 254, supra. The Com-mittee, therefore, did not structure its interviews such that they would correspond directly with these two documents.100/ The Staff accordingly faulted the Committee because it did not1 99/ On cross-examination, Ms. Morisseau testified that the RHR survey of TMI-1 was conducted in mid-late 1982 during the months immediately following the Special Master's Report and our decision on the cheating incidents. Tr. 33,205 (Morisseau). She also testified that the Staff conducted-in-terviews in preparation of NUREG-0680, Supp. 4 in June, 1983. Tr. 33,206-07 (Morisseau). The Committee's operator interviews were conducted during its subsequent assessment, which began on August 13, 1984. Tr. 31,972_(Uhrig). 100/ Mr. Kelly testified that he did ask some operators about
'the RHR findings during the course of his operator interviews.
See 1 245, supra.
-213-p(_)
r .
. . compare its findings regarding operator attitude with the find- '(
3 Lings. reported in the RHR Report and NUREG-0680, Supp. 4; and because it did not structure its interviews in parallel with p the.RHR and NUREG-0680, Supp. 4 assessments. Staff, ff. Tr. 33,148, at 32-33; Tr. 33,140 (Persensky). 276. The Staff also faulted the Committee's methodol-ogy because it did not review documents evidencing the instruc-tors' class attendance or performances in the instructor devel-1 opment program. Staff, ff. Tr. 33,148, at 33. In addition, zthe Staff felt that the Committee's method of evaluating in-structors did not fully utilize GPU Nuclear's criteria for as-4
- sessing the instructors' qualifications.101/ See Tr. 33,140-41 L(Persensky).
277. The Staff's testimony also noted the following areas where the Committee's methodology did not compare with
.'its1 recommended methodology. . The' Staff' felt that the Committee did not review'the job / task analyses f1 or TMI-1 licensed opera-tors.102/ Staff, ff. Tr. 33,148 at 34. The Staff also stated
]~ 101/ The. Committee did familiarize itself with Licensee's in- ' structor. evaluation criteria and utilized these criteria in evaluating' instructors, although theLinstructor form was-not filled out. Tr. 31,913 (Kelly). Thus, while the GPU Nuclear-criteria were not formally used-or formally compared to the
' Committee members' own critera,-they nevertheless were.used and
~
evaluated for-adequacy by the Committee. See Tr. 31,913 (Gardner).
~
102/ But see~11 228, 255, supra and 11 301, 308,-311, infra.
- In particular, Dr. Kimel testified that he had reviewed the
. - ). f
~
(Continued Next Page) 2 '
-214-
- j t e- " - - -- ~
v -~*w -ev v - ww ev~---v--,-,,w- www.e,-.te--,,--e~+--v
- 7g that the Committee did not observe on-the-job training.103/
V The Committee did not review all training materials to deter-mine the degree of memorization required (with the exception of requalification exam questions), nor did it review or observe simulator or oral examinations regarding this issue. Id. In addition, the Committee did not use job / task analysis data to evaluate oral and simulator examinations. Id.
- d. UCS (Dr. Regan) Recommended Methodology 278. Dr. James Regan, an industrial psychologist with approximately 31 years of experience as a researcher in Navy training and other elements of a personnel system,104/
(Continued) OPM, behavioral learning objectives, plant-specific task lists and generic INPO task lists. Tr. 31,825, 33,325-27 (Kimel). 103/ Dr. Gardner and Mr. Kelly testified that the Committee did review on-the-job training, however. Tr. 33,138-40 (Gardner and Kelly). 104/ Dr. James J. Regan is currently a self-employed consul-tant, lecturer at the University of San Diego and visiting sci-entist with the Battelle Human - Affairs Research Cer.ter. He holds a Ph.B., M.A.'and Ph.D. in Psychology. Dr. Regan also has extensive research experience with the Navy Research and Development Center'in San Diego, California. See Regan, ff. Tr. 33,532, Resume. He does not, however, have much personal experience with the conduct of training. Tr. 32,703 (Regan). Dr. Regan describes himself as having no training in technical engineering, no-teaching experience.(aside from a-course and lectures on personnel management), and no significant personal experience with training program curricula development. Tr. 32,774-75 (Regan). rN -215-U J 9 m._._
- . . .. .~
r'- ':, . t. testified on behalf of UCS. -Dr. Regan provided us with his model for evaluating the TMI-1 licensed operator training pro-
~
gram. Dr. Regan's approach is unique to the extent that it is ,
?the only methodology presented that would employ the develop- !
i
~
ment;of an assessment model that is tailored to the program to be. evaluated. See'Regan Surrebuttal, ff. Tr. 32,693, at 7.105/ Dr. Regan explained that.the development of a model for review [ should-precede the commencement of that review in order to pre-vent the program from. directing the review.106/ Regan Surre-buttal,off. Tr. 32,693, a't 7. For purposes of comparison and. ' completeness, we have included a summary of Dr. Regan's recom-mended' methodology to which we now turn.107/ , r: 279. Dr. Regan testified that in order to undertake-an-evaluation of the TMI-1 training program that would allow 105/ L In evaluating Dr. Regan's model, we are mindful-of. ^ Dr.'Regan's' admitted complete lack of familiarity with TMI and training of licensed operators, generally. See Tr. 32,733,. 32,735-38 (Regan);;see n.28,' supra. 106/ Both the Staff and Committee methodologies: advocate.the review-of ALAB-772 and the preceding cheating decisions, as well..as the review of several' independent assessments and pro . -
-gram descriptions as the initial step in reviewing the training
. program'and the remanded issues.. Dr. Regan had proposed a'sim-ilar~ approach'in'his-initial testimony. See Regan, ff. Tr.
33,532, at 18.
-107/LWe note'that we hold the'same reservations concerning.the
-probative value of this discussion absent anyl evidence of any~
. substantive, errors in the' findings.of the Committee 1that would' ,
indicate that'our reliance thereupon would be misplaced. E q -216- . 9
E f'
'; him to' answer the questions raised by the Appeal Board, he
^
would perform a detailed three month study utilizing a team of personnel with both training and nuclear expertise. Regan, ff. Tr. 33,532, at 18, 22. The first aspect of any such effort
. would be to gather basic information and develop a plan of ac-tion.108/ The initial information would come from the com-
- pany's managerial personnel through briefings and docu-ments.109/ Beyond that initial information, he would review primary materials such as examinations and program documents, and conduct' interviews with appropriate personnel. Id. He also~would review a sample of task analyses and learning obje"c-tives.to determine whether they are technically accurate. He would also endeavor to determine whether the job descriptions and other information on which the task analyses were based were, in fact, consistent with the current plant design. Id. ,
,at 18-19. Dr. Regan's testimony further indicated that he would' review the' training materials and instruction to deter--
mine whether they were technically correct and whether they 108/ But see n.106, supra. 1
- 109/ Dr. Regan participated in several Battelle-affiliated com-
- mittees that gave' advice to the NRC on licensed. operator quali -
-fications and on simulators . Tr.-32,'725-32 (Regan). In both
, cases, the group was made up of a number of expertsTwho pooled.
their talent and, based-on briefings, gave their opinions on the question.at issue. Tr. 32,'727-28, 32,731-32 (Regan). This process was strikingly _similar to-the approach initially used by the.OARP Review Committee here.
- -217-C1 C
,_ were correctly administered. This would include a detailed re-view of instructors' training and education, as well as a re-view of the evaluations of instructors and "the evaluations of simulator performance done by instructors." Id. at 19.110/
280. Dr. Regan would review simulator instruction through observation of the instruction itself. He would also analyze the degree to which any simulators replicate the plant. To the extent that there are any differences, and particularly to the extent that the differences are minor or subtle, he would undertake two separate efforts. First, he would review what the Licensee had done to assure that the differences would not interfere with the operator's ability to operate TMI-1. Second, he would conduct tests appropriate =to reveal whether the operators' use of the simulators had created any such in-terference. Id. at 19. 281. Dr. Regan went on to state that he would be concerned about learning interference problems where, as at TMI, job incumbents and trainees are subject to frequent changes in procedures and requirements.111/ A review of this 110/ It is unclear whether Dr. Regan is referring here to si-mulator instructor evaluations, or to evaluations of instruc . tors while they are in training at the simulator. 111/ We did not receive any evidence of the existence of any
" learning interference problems," nor do we perceive that to be (Continued Next Page)
(O
,/ -218-
Lissue Yould be essentially the same as the review of the prob-
-6. ~
.lem of a' simulator that does.not replicate the actual reactor.
Id. at 20. 282. Dr Regan would review examinations and other asses: ment devices for several purposes: (1) to assess whether
~ exams rely upon objective and standardized measures of perfor-mance; (2) to determine whether exam questions are properly constructed, particularly with respect to.the behavior that they test and the mental processes that are required to answer them;~and (3) to the extent that oral assessments are used, Dr.
- Regan wotid inquire whether they are controlled.by the use of standardized procedures and whether complete notes of the an-swers are kept to ensure that they can be reviewed impartially.
Id . - 283. Dr. Regan's review would focus particularly.on the. issue of the correlation between exam performance and. job t-L p (Continued)' , among-the issues remanded _to us by the Appeal Board. .'Neverthe-- l 11ess, Dr. Regan suggested that this problem arises when an individual originally trained on one procedure operates under that procedure for a period of time ~and is.then faced with the l1 implementation of a new procedure. , Depending upon-the type and extent of the change, the prior learning'and experience can - - significantly inhibit both initial learning'and retention of.. , the new material. .The. problem can become particularly. acute in 5 emergency situations, When an operator may tend to revert to previous procedures.. Regan, ff. Tr. 33,532,.at 20.
-219-V i
i e L
performance. In order to address this issue, Dr. Regan would
/^T
\~/ review the types of job performance evaluations that are done by Licensee, the' extent to which the evaluations use objective
. measures, and the extent to which the objective measures are consistent with exam performance. Id at 21.
T 284. The Regan methodology would include an assess-ment of how Licensee feeds the results of its training (presum-ably exam scores) and the results of job performance evalua-
~
f- tions back into the training program. Id.
,, 285. Finally, Dr. Regan would systematically examine the attitudes of the trainees toward the training and toward the jobs themselves. This would be done through an anonymous random sampling technique, with a standardized set of questions
. carefully developed by survey research experts to reveal actual
. attitudes. Dr. Regan testified that this survey would be use-
_ ful in conjunction with the other assessments (presumably the RER Report and NUREG-0680, Supp. 4). Id. , e. Compt.rison of Methodologies 4 286. We have carefully reviewed the testimony and documents presented concerning the methodology used by the Com-mittee and the recommended methodologies. presented by the Staff and UCS. We find, upon comparing the three methodo'logies, that
-220-(~
e
+
v) . 4
J each of them follow a virtually identical progression toward O' the evaluation of the. training program. Although the UCS meth-odology incorporates the development of a review model as its initial step, the first step incorporated by the other meth-odologies is the review of the remanded issues. Given our understanding that the primary reason that the Committee re-1 cently reviewed the training program was to address the Appeal Board's remanded issues, we firmly believe that any review de-signed to address those issues should certainly begin with a review of ALAB-772. All three methodologies provide for the review of relevant documents (e.g., program descriptions, 4 cheating decisions, training procedures and independent assess-m,ents of the training programs) in the preliminary stages of review. -See 11 229, 260, 279, supra. Management briefings are considered valuable initial sources of information for all three methodologies. See TV 228, 260, 279, supra. Moreover, all three methodologies employ a series of interviews of GPU Nuclear personnel and first-hand observations of various as-pects of the training program to corroborate the information reviewed during their respective initial stages of review. See 11 230, 245-248, 260-61, 279-80, supra. If anything, the Com-mittee's interview process (number and depth) was more thor-ough, if less formal, than the processes recommended by the Staff and Dr. Regan.
-221-
287. We further discovered that all three meth-
.E
'odologies focus on the following aspects of the training pro-gram: 1) examination construction, content, administration and security; 2) instructor development and instructor qualifica-tions; 3) simulator training; 4) the implementation of job / task analyses; 5) procedures to ensure that the training program stays up-to-date; and 6) operator attitudes. In contrast to Dr. Regan's approach, the Committee and Staff methodologies also focus on communications mechanisms, T&E management quali-fications, and the adequacy of the training facilities. .See 11 228, 236-240, 244-246, 248-253, 255, 260-262, 264-265, 273, 279-280, 282, 285, supra.
288. . Recognizing the many similarities which exist among these three methodologies, it is clear that the Commit-tee's approach did not fully conform to either the. Staff or UCS methodologies. Each methodology employs different methods for ascertaining the same information. The appropriate method of evaluating. operator attitudes elicited the greatest disparity among the three models. The Staff testified that the issue of operator attitudes should'be evaluated with reference to the findings in the RHR Report and NUREG-0680, Supp. 4. See Staff, ff. Tr. 33,148, at 14-15. The Committee, on the other hand, relies upon its independent assessment of operator attitudes which it considers to be more pertinent than the out-of-date c -222-( -)
XJ
-) findings of the RHR Report and the similarly dated findings of NUREG-0680, Supp. 4.112/ See 1 254, supra. UCS' methodology distinguished itself as the only one of the three that would incorporate the use of an anonymous survey to assess operator attitude. See 1 285, supra. The Staff's methodology, however, distinguishes itself as the only one that would utilize absen-teeism records to evaluate employee satisfaction, notwithstand-ing the Committee's comparable evaluation of attrition rates.
See 1 261, supra; Committee, ff. Tr. 31,749, Special Report at
- 46. Although we are not certain which method of evaluating current operator attitudes is best, we are confident that the Committee's direct operator interviews and conversations with training and operations management is a reliable method of ascertaining that information.
112/ We agree that the findings of the RHR Report are of little probative value in assessing the current attitude of operators of TMI-1. See 1 254, supra. Ms. Morisseau's testimony on cross-examination indicated that the RHR survey data was col-lected in the wake of the Special Master's report and our 1982 ' cheating decision. See n.99, supra. Operator morale at that time was understandably low. Moreover, Dr. Gardner and Mr. Kelly testified that the RHR findings were both situationally remote and irrelevant to the current operator attitudes which were the subject of their review. See Tr. 32,039-40 (Gardner, Kelly). Dr. Gardner also testified that attitudes are tran-- sient, hence the probative value of the findings of NUREG-0680, Supp. 4 (the data for which was gathered 1 1/2 years ago, see ir. 33,206-07 (Morisseau)), like those of the RHR Report, is minimal with respect to an assessment of current operator atti-tudes. See Tr. 33,297-98 (Gardner). The Staff included in NUREG-0680, Supp. 4, that the RHR Report represents nothing more than a behavioral sample of attitudes at that time due to the numerous ~ changes that have occurred since the RHR survey was completed. Tr. 33,205 (Morisseau). O N.)
-223-
+f*-
-g 289. The following list is representative of the disparity between the Committee's methodology and those of the-LStaff and UCS. The Committee did not perform the following tasks recommended by the Staff: 1) review instructor develop-ment class attendance figures; 2) review training materials to see how much memorization-they require; 3) observe on-the-job
- training to ensure consistency with job / task analyses; 4) ob-serve simulator exams; and.5) observe oral-exams. Nor did the.
, - Committee perform the following tasks recommended by-UCS: 1)-
i review instructor performance <nt the simulator;113/ 2) techni-cally verify the accuracy of task analyses, learning objectives and training materials; 3) develop:a formal model for review before embarking on the program evaluation;114/ and 4) test op-
- erators for signs of negative transfer from the B&W simulator to the-TMI J1 control room. We do not,believe, nor.was it F shown,'that the absence of those tasks'from the Committee's k methodology materially.affects either the overall adequacy of'
-113/:The Committee did review PSI simulator' instructor perfor-mance. See Tr. 32,078-79-(Christensen); Tr. 33,280~(Kelly).'
The Committee also reviewed. licensed operator-training at-the PSI simulator 1and the BPTS, which is the same training that is ! ' received by licensed instructors. ] . 114/ The Committee.did, however, proceed by~ dividing.up issues l into the members' respective areas of expertise. Committee, 1 ff.~Tr. 31,749,Lat 25 1 Also, Drs. Christensen and-Gardner developed.a "model" for their joint operator interviews.- Tr.) 32,067, 32,155, 33,279-(Gardner).
-224-
!L L e
-1 ,, , .s,,,m -~,.~%,,y, ,,<,-,,,.,www-rw., ,,,wr.,-._w,.mg.,g. .,..,._9c,. 4 w,,_y,-m-.wwy,-mw,y_.p..w ,w ,7w cm-r-pymw.
c -th'at methodology or the accuracy of the Committee's substantive
+ O: . ' '
findings. Moreover,.the substantive value that would have been derived from performing.most of these tasks was determined by other means=as discussed earlier.115/ 290. In'short, we are confident that_the Committee's
. methodology is adequate to allow it to address knowledgeably the remanded training issues. Notwithstanding UCS' conviction
,that theJ OARP Review Committee's approach was materially lacking,-we are further assured by the overall similarity which exists _among the three methodologies. Although we would antic-
-ipate that there would be significant differences in the recom-
~
mended approaches evaluating the. training program,'there was no evidence:that the Committee' failed to review, in the generally approved or a like manner, any aspect of the training program. 115/ Dr. Gardner. was confident that the' Committee's assessment did not suffer 1because-it did not incorporate every step sug-gested by the Staff and UCS methodologies. He cautioned
- against the use.of " textbook" models'for review over a consid-ered modeiof review independently tailored in accordance with the ' issues ' concerned and the resources > available to ~ the re .
viewing group. He further expressed his confidence in the.
-methodology used by.the Comnittee~which included management Lbriefings, first-hand observations, interviews with relevant GPU Nuclear personnel,<and the review of relevant documents, especially the TMI-1 Self Evaluation Report ("SER").which was H , ' submitted to INPO. Dr. Gardner expressed particular~ confidence' ,
L
~
.in the data contained in the SER'because it was submitted as
.part of the TMI-1 INPO accreditation process and was'therefore.
. subjected to'a very detailed quality assurance or confirmatory; e
assessment by the INPO site-visitation team. Tr.'33,350-53 (Gardner). !t -225-
\,
F
- 3. The Committee's Findings
()
- a. Cheating 291. The Committee reviewed the cheating issues in response to the Appeal Board's remand of that issue. See 1 235, supra. During the course of this review, the Committee determined that cheating is an issue of personal morality, and is not an easy issue for educators or professionals to grapple with. It is complex in its derivation, highly situational and individual.116/- Management must take the utmost precautions to prevent it. The Committee recognized that the , cheating inci-
' dents which occurred in April, 1981, as well as the other inci-dents of. cheating discussed by the Licensing Board in its July, 1982, decision were extremely serious and reflected unfavorably on the' organizations as well as the individuals involved. The ,
116/ There is no evidence that links cheating with deficiencies in the= substantive quality of training. To the contrary, the experience of all of the witnesses who testified on this sub-ject, other than Dr. Regan, was that cheating is so highly sit-uational and individual that it cannot be generalized to one cause, nor can one assume that only poor students' cheat. See Tr. 32,029-31, 32,032-34 (Gardner, Uhrig, .Christensen); Tr. 31,924-25 (Uhrig); Tr. 32,140-45 (Christensen); Tr. 32,148-49 (Gardner); see also Tr. 33,402-15 (Leonard); compare Tr. 32,771-73 (Regan).. Indeed, Dr. Uhrig testified that he does not believe that course content had anything to do with the cheating. Tr. 31,924-25 (Uhrig). .On'the other hand, one can-not preclude-the possibility that one contributing cause of cheating may be weaknesses in a training program. See Tr. 32,145-47 (Gardner).
-226-O
'V
b Committee concluded, however, that such behavior on the part of O": a very few individuals did not negate the " Herculean" efforts s , of so:many -- trainers and trainees -- during the past five years. Committee, ff. Tr. 31,749, at 5. 292. The Committee testified that after the discov-ery of cheating, GPU Nuclear took the necessary precautions to prevent future cheating incidents. The Committee has never seen such stringent examination security procedures.117/ The
- Committee found the current training program to have excellent training' procedures in place to provide the necessary guidance
..to training personnel on construction, administration (including proctoring), evaluation and interpretation of exami--
nations. These measures facilitate the proper administration. b of examinations and thereby reduce ~the opportunity, the feasi-bility and the temptation to cheat. The Licensee went~further, [ however, and considered other-ways to ensure itself that its-
' training program was.satiufactory. For example, numerous com-munication lines have~been established between the. Operations.
!: and Training Departments in response to cheating. 'See !~ '11,65-75, supra. Individuals ~ responsible for the TMI-1 L L li~ censed operator training program at-the time'of the cheating !L 117/ GPU Nuclear's response to cheating is.more fully. discussed . - in 11 64-96, supra.
-227-I i
feel a keen sense of responsibility for the cheating that oc- %' curred, and the training organization is firmly dedicated to ensuring that it does not happen again. See 11 46-63, supra. The Committee therefore testified that in its opinion GPU Nu-clear has properly responded to the problems in its training program identified internally and/or by the NRC decisions in this case. Committee, ff. Tr. 31,749, at 29. 293. The Committee determined that it would not be feasible or useful to attempt to determine what each member would have thought had they known that conditions existed that subsequently permitted cheating to occur on NRC and Licensee exams. Therefore, in the Special Report the Committee focused instead on the current TMI-1 licensed operator training pro-gram. In its view, this was the most effective approach, given
~
the passage of four years and the fact that the OARP, for which its original Report was prepared,.was a one-time program that has~been succeeded by subsequent developments. Id. at.6. 294. The Committee testified at length-about the status of.the current licensed operator training program with respect to the remanded issues. The Appeal Board has asked whether the deficiencies.in operator testing, as manifested by the cheating episodes, may be symptomatic of more extensive failures in the licensee's overall training program, and
-228-
gy whether those deficiencies have been remedied. ALAB-772, .v supra, 19 N.R.C. at 1233. The Committee answered these ques-tions by evaluating, to the extent possible, the steps that have been taken by, and the performance of, the GPU Nuclear op-erator training program during the four years since its initial Report was issued. The answers to such questions do not depend upon a single activity, a single event, a single success, or a single failure. Rather, as the Committee testified, the an-swers depend upon the existence at TMI of a systematic pre-paredness to address problems and events that occur. Commit-tee, ff. Tr. 31,749, at 7. Based on its findings, summarized below, the Committee found such a systematic preparedness to exist at TMI.
- b. Training Resources 295. The T&E Department services TMI, Oyster Creek and corporate headquarters in Parsippany, with 108 staff mem-bers plus six contractors and its impressive 1984 budget of
$7.3 million, which is about an order of magnitude increase in both staff and budget since the TMI-2 accident. The Committee was impressed with the large resources assigned to training of nuclear plant and support personnel, which it considers-to re-flect the commitment of GPU Nuclear top management to excel-lence in training. Committee, ff. Tr. 31,749, at 7.
{~'y -229-v s
E #- 3 296. The Committee felt that the primary basis upon AI .which it could assess whether Licensee's assignments of training managers-is. appropriate was to assess the quality and performance-of the program. In its Special Report, the Commit-
~
-tee stated that it did not consider it appropriate to second-guess GPU Nuclear's management decisions, after the cheating incidents were uncovered, on the assignment of individuals to
~
~
- positions in the company.
The Committee subsequently did, how-ever, review the qualifications of T&E management in addition to the discussions it held with Mr. Clark on the propriety of.- th'e. current management assignments. 11 236, 246, supra. The-
-Committee also testified that its view, implicit in the Special Report,-is that the cheating that occurred was not a reflection on the, moral character of any of the individuals in charge of a
the~ operator training program at the time of the cheating inci-
-dent, although they of course shared in the responsibility for-
;the occurrence of cheating on company exams. The Committee p.
T found that training management accepted this responsibility,_ d
?andLwas firmly'edicated to ensuring'that cheating does not I recur.- In general,-it was the Committee's view'that, as re-
'grettable'as the cheating' incidents were,Ethey must not over-
,i< shado'w;the extraordinary progress made by the T&E Department ,I
'since'the TMI-21 accident under the leadership of Dr. Long, Dr.
Knief,'Mr. Newton and,~'more recently, Dr..coe and Mr. Leonard.
.Commititee ,. ff'. Tr. 31,749, at 8. ' g; R -230-F y
297. The Committee also believes that in an organi-
'/ cation that is responsible for effective training on a broad scale (with operator, technician, engineer, management, and general employee training being administered), a special mix of management, education, and experience is most beneficial to the conduct of training operations. The Committee is of the view that the T&E management in place is performing very well and has been innovative and effective in development of the GPU Nu-clear training programs. The individuals cited by the Appeal Board -- in particular, Dr. Long, and Mr. Newton and addition-ally Dr. Coe and Mr. Leonard (who were not cited) -- have the variety of backgrounds recommended in the 1980 OARP Committee Report. They possess the complementary skills and knowledge that, in'the Committee's view, are essential to the smooth functioning and effectiveness of the GPU Nuclear training pro-gram. Id. at 9;118/ see 1 32, supra.
118/ The OARP Review Committee notes in its Special Report that the number of instructors assigned to operator training at TMI is nearly double the average number of similarly assigned in-structors at other nuclear power plants in the United States. l Committee, ff. Tr. 31,749, Special Report at 44. Moreover, the Committee states, "the fact that most of the TMI operator training instructors have or will hold either RO or SRO licenses or certificates provides invaluable knowledge and ex-perience input to the training programs ~and establishes an all-important instructor credibility with the operators in training." Id. rs -231-() .
, ~ :egr.
]- 4 ..
- 300.- Overall, the Committee endorsed the management
- t. :
~ N- responsible for the TMI licensed operator training program and
.the facilities available for use by.cperators in the program.
Committee, ff. Tr. 31,749, at 8-10, 30; id., Special Report at 16-19, 82; Tr. 33,329-30, 32,079-80 (Kimel); 32,084 (Gardner); 32,080-81 (Christensen).
- c. Programs and Procedures I
_301. In the Special Report, the Committee considered D the' issue of the adequacy of the current TMI licensed operator i training program from several different vantage points. The 4
- Committee-reviewed GPU Nuclear's responsiveness to the exten-l
sive recommendations in the areas identified by the OARP Review Committee in.1980. In this way, the Committee'was able-to-
- evaluate substantive aspectsoof the current program and,'as well, assess the commitment.of the Company to the improvements l- 'the. Committee endorsed four years ago'. Tr. 31',943 (Uhrig).
2 Chapter-III.of the Special Report' summarizes'each 1980 OARP'Re--
- ' view Committee recommendation and GPU. Nuclear response.= . In i .
short, all of the Committee'.s recommendations.have been seri-ously studied, and all but one; recommendation, which'the Com-l pany reviewedibut did not implement, have been adopted and have - been or are being' implemented. The Committee testified that-the following' improvements are particularly pertinent to the 4 O S b
, ,_,m r t - r i 2 issue of adequacy of the TMI-l licensed operator training pro-O'- gram: l (3) Curricula incorporating (a) heat transfer, ,
- fluid. flow, and thermodynamics, (b) small break LOCA, (c) tran-sient-training,: including abnormal transient operating guide-ilines (ATOG) and (d) simulator training, incorporating depres-surization and natural circulation have been developed and are included in the licensed operator training and retraining
_(requalification) program. [ (2) Continuous, internal self-examination and pe- l q
-riodic external reviews have been conducted at TMI. Currently,.
GPU is seeking.INPO's accreditation of the TMI operator pro . > L . grams, including the TMI-l licensed operator training program. (3) LGPU Nuclear has taken steps to ensure that the content'.and conduct of'B&W's simulator programs-are exactly
'what GPU. Nuclear-considers necessary_and appropriate, are com -
^
4 plementary to other operator training and, where feasible, are responsive to_ changes that occur-in the TMI-l control systems, o ^ [ plant" design and procedures.119/ 119/ Dr._Christensen testified that during one-of his visits to the B&W simulator he observed the rapid alteration of the si- ! _ mulator instruction to. reflect a plant design change which had i; .? been made only~twoJor three days beforehand. Tr. 33,288-89 o (Christensen). Bhe. Kelly further _ testified that the PSI (B&W)
' instructors are;always very careful.to use-TMI procedures. Tr . -
L32,068.(Kelly).
-234-t e a a
(4) GPU Nuclear has secured and placed into opera-
-(,_).
'_ tion a Basic Principles Training Simulator (BPTS) bailt to its own specifications and based on its own studies. GPU N.> clear has also ordered a replica simulator for TMI-1 which will be delivered in late 1985. Additionally, an actual size TMI-1 contrcl board mockup, has been installed in the TMI training build ng.
(5) As previously discussed, a program for in-structor development has been implemented since the fall of 1980. The program includes such topics as curriculum develop-ment, development of behavioral learning objectives, prepara-
. tion of lesson outlines and lesson plan formats, utilization of audio-visual aids, instructing / teaching techniques, preparation of examinations, evaluation techniques, and counseling tech-niques.
(6) Decision analysis training is included as part of senior reactor operator training. The original program offered in 1980 by Management Analysis Corporation has been modified and has become an integral part of the initial SRO training program. (7) GPU Nuclear has developed guidance for the preparation of examinations. This guidance includes a matrix of content (knowledge) and type of response (skill or ability) required to answer the written examination questions.
/ i
-235-L.
_ . - _ . . . - - - - .. . - . - . .- ..- . . = l l
,s (8) GPU Nuclear has worked with INPO in the prepa-k) . ration of a generic task analysis list for utilities that have operating nuclear plants. T&E used the INPO task analysis in the development of the BPTS program. The applicable INPO/B&W task analyses also were used to upgrade the specifications for
- the classroom and on-the-job training (OJT) portions of the op-erator training programs.
(9) GPU Nuclear management philosophy with respect to nuclear power plant operation and responsibilities to the public has been well developed and has been disseminated to GPU , Nuclear personnel through a variety of memoranda and corporatts publications. Id. at 12-14. 302. In' summary, it is the Committee's view that GPU Nuclear's commitment of additional resources and the dedi- , cation to building a quality licensed operator training progarm forithe TMI-1 operators since'the issuance of the 1980 OARP Re-
-view Report (or for that matter since the Licensing Board's 1981 and 1982 management decisions) has been impressive. Id.
'at 14-15.
303. -The' Committee also testified that it reviewed information-on the current status of licensed operator
-itraining, independent of its' prior recommendations. In the last1several years, the.TMI-1 licensed operator training
. program has been enhanced in a number of ways. Id. at 15.
.' J
- 236--
g ,
*-t+T -- gy .g W g- - +p y-gya wy+-e y.g - p- y e eg g. f- m a &
- Aky---y v 6
& y t y
rw 304. The Committee believes that the BPTS is the U most advanced basic principles trainer for licensed operators in the' United States. Furthermore, GPU Nuclear is one of only three U.S. utilities of which the Committee is aware that gives its operators training on both a BPTS and a full-scale (B&W)
. simulator. Id. at 15; see 11 44-49, supra.
305. In addition to the BPTS program, GPU Nuclear has an extensive simulator and plant evaluation drill program. Special B&W simulator training programs have been developed to provide operators experience with the use of major TMI proce-dural changes, (e.g., ATOG), steam generator tube rupture emer-gency procedures, and other Licensee Event Report (LER) lessons learned. The B&W simulator is used for initial training, main-tenance of skills and special training requirements. Quality control is exercised by the Training Department over the con-tent of the program. It is also used, contemporaneously, by-senior members of TMI Operations staff to assess operatorsca-
.pabilities. Moreover,'as part of hot functional testing, oper-ators have been provided with experience in the operation of certain' systems. Ccmmittee, ff. Tr. 31,749, at 16.
I i 306. The mock-up TMI-1 control. board. procedures-trainer has been installed at the Training Center. Among other purposes, see 1 51,1 supra, it is used to further enhance the
-237-1 o
p' . . _ - , . . _- _m. - ,.
7- effectiveness of ATOG procedural training. Licensed operators (^ review the ATOG procedures with instructors and perform a step-by-step walk-through of each procedure and reference the actual controls displayed on the mock-up panels. Committee, ff. Tr. 31,749, at 17. 307. The Training Department utilizes instructor lesson plans to conduct all of its training sessions. These plans require management approval before being used. As a means of maintaining Operations Department feedback to the
, training process, weekly meetings with shift operators and the Training Department are held to review all program revisions and schedules and to resolve any special problems that may arise. Id. at 17-18.
308. GPU Nuclear has produced and published the Operations Plant Manual ("OPM"), a multi-volume technical ref-erence document intended to cover all systems and major compo-nents in TMI-1, as well as fundamentals and theory necessary to-understand the operation of power plant systems and equipment. Id. at 18; see 11 74, 113,'176, supra. The Committee testified that.it is used by operators and instructors as a valuable ref-erence document. Each .section contains behavioral learning ob-tjectives for auxiliary operators, RO's'and SRO's,-and is writ-ten from an operator's viewpoint. Much of the detailed
-238-c.
s engineering information typically found in system descriptions, but unn'ecessary for operator training, has been omitted. To date,~over 100 of the 121 OPM sections have been issued, with the remainder in various stages of preparation, review and printing. Every section has been reviewed by the appropriate technical organization for completeness, accuracy, and for ap-propriateness of the learning objectives. Id. at 18. 309. Mr. Kelly and Dr. Gardner reviewed all of the Cycle 9 (1982) and Cycle 10 (1983) requalification exams (key
.with. questions and answers-to results), as well as all of the exam construction and implementation procedures. Committee Re-buttal,-ff. Tr. 33,320, at 3, 13; Tr. 31,882-84 (Kelly); See 1-250, supra. Pooling'their educational and nuclear technolog-ical: expertise, they conclude that the scope and cor. tent of these written examinations, along with-oral exams, simulator exercises, and on-the-job evaluations, were adequate to judge the effectiveness of the training program and that the opera-
. tors have maintained high-levels of qualification. Committee, ff.'Tr. 31,749, at 21; Tr. 31,863 (Kelly). Each annual
' requalification training program reinforces and builds upon the
~
previous knowledge of the operators;.the requalification exami-.
-nations, which are designed to test lthis, knowledge, cover per-tinent subject 1 matter and are structured to measure retained Lknowledge of-technical. subject matter. Id.
r" -239--
;O):
m
r
-310. The Committee further testified that reexamina-O' . tions on much of the same subject-matter, which is required by the requalification process, is inevitably going to result in the experienced examinee's familiarity with key issues on which he should and will be examined. In addition to written exami-nations,.an oral examination is used to assure that operators have a thorough understanding of the subject-matter. GPU Nu-clear has included in its training program for instructors a seminar on test construction. Seminar participants developed a taxonomy of learning objectives and use it to evaluate examina-E tions in terms of a two-dimensional blueprint that includes both-content and the variety of types of mental processes needed by the examinee. More recently, sessions on this matter--
have been incorporated into the. Fundamentals of Instruction , _ course. Following such a blueprint will ensure that test ques-tions-will sample more broadly the kinds of mental' operations Lthat:are1 required for a demanding. job such as that of the con-' trol room operator, and will not simply encourage memorization for test-taking purposes. .Id.nat 19.
~
311. Following the TMI-2 accident,'Lthe NRC,..INPO,.and the' industry committed resources to'an analysis of what an op-erator needs to know to. operate nuclear power plants-safely and effectively. INPO's tashfanalyses, initiallyL-issued in 1981~. { "and updated ~ periodically, were used by GPU Nuclear in the
- a -240-
\_f
'j
e . development of TMI-1 job analyses. These analyses for the job h' - of control room operator are now complete. Tr. 33,330 (Kimel); Tr. 32,455 (Newton). The use of task analyses in the develop-ment of the training curriculum will further enhance the licensed operator training program. Committee, ff. Tr. 31,749, at 18-19. 312. The format and content of the examinations are designed to test the specific skills and knowledges established as behavioral learning objectives in the performance-based training-program. Both informal job and task analyses done by the GPU Nuclear staff and a set of task analyses constructed by INPO'have been used. The written, oral and B&W simulator exam-inations are part of GPU Nuclear's overall appraisal of a potential operator's competence to function safely in the TMI-1 control room. The entire evaluation process involves: (1).
. classroom activities with' lectures, quizzes, and examinations, (2). simulator exercises involving the solution of problems.re-
[ lated to the. transient behavior of the system, and (3) on-the-l -_ -job performance and evaluation. These three components are'in-E tegrated so that thefrequired skills and. knowledge can be Etested appropriately,-and the. extent of each examinee'.s under-standing can be ascertained reliably. Iji . at 20. s o I . ~ ^
- -241 .
~
- +
s s I
-' I
r. a 313. All TMI training programs, including, of Os course, the' licensed operator training program, are subject to auditing by GPU Nuclear management. For example, the licensed operator shifts undergoing requalification training on the B&W simulator are observed at least once during each cycle by one of the Emergency Directors (Messrs. Hukill, Toole,.Ross and Colitz) and by the Vice President of Nuclear Assurance, or the Director of T&E. In addition to providing management with r information, and a-different perspective, on the effectiveness of'the training program, the audits provide the operators with the confidence that management is truly concerned that the training activities are carried out' effectively. Id. at 2i; gf. Committee, ff. Tr. 31,749, Special Report at 76. 314. An extensive program for the training and-fur-ther' development of instructors has been undertaken by GPU Nu-clear. The Committee testified that this program is being con-ducted in accordance with a strategy develop,sd by the Director of-Training and-Education, Dr. Coe. A standardized method for instructor development and'the conduct of effective i performance-based training-is in.use, with a number of-guidance
~ documents developed to aid in the systematic pursuit of-performance-based instruction. Thus, for example,-a detailed rating sheet permits the1 evaluation of-an' instructor on a num-bar:of the important factors related to teaching, such as
-242-
&ge,
F
. familiarity with technical information, adequate preparation Land presentation of materials, establishment of sound learning
. objectives,. selection of appropriate instructional methods,
- proper: use of instructional aids, proper treatment of explana-tions and' questions, classroom management, and instructor char-
~
acteristics'such as voice, diction, enthusiasm, and appearance. There is also a rating sheet for the evaluation of examination administration.120/ Committee, ff. Tr. 31,749, at 10-11. 315. In addition, the Committee described a number of specific steps that have been taken to further ensure that t qualified instructors are selected and that their skills im-prove on-the-job. These steps include (i) adoption of a formal
, Instructor Mode of Progression that clearly outlines the criteria-for instructor job descriptions and specifications; (ii); instructor development: modules offered as on-going pro-grams administered uniformly by the Manager offEducational1De-velopment; (iii) required regular instructor evaluationsfby
' training management; (iv) unannounced documented classrco'm 120/ Mr.tKelly testified that the operators that he interviewed
+ are'very pleased with the quality of-the.GPU. Nuclear and' PSI:
~
(B&W)1 instructors; Land that they.are also quite' satisfied with the instructors' attitude ~toward them. Tr. 32,068-69 (Kelly). Moreover, Dr. Kimel and Mr.: Kelly;were. impressed by the high Jgualitylof' instruction-they observed during'their classroom ob-
'servations. Tr.l31,909 (Kimel); see.also'Tr. 32,084-85-(Gard ~
ner).;
-243 -
n
.V.
5
T. . 1- . visits by.the Vice President / Director of Nuclear Assurance and O the Director of-Training and Education; (v) a plan for the con-solidation of? appropriate GPU Nuclear training programs; (vi) licensed instructors making required and routine visits to the plant; (vii) off-site programs for educational and career de-velopment; (viii) regular staff meetings to discuss current company and educational issues; and (ix) formation of a GPU Nu-clear Training Advisory Council that meets regularly to advise the Director of T&E on broad educational and personnel issues. t Id. at 11-12. i '. , 316. Committee members, particularly Dr. Gardner and Mr.-Kelly, reviewed the licensed operator, instructors' resumes l and performance evaluations, attended some classes and talked to several operators about the quality of the licensed operator. i j . instruction at TMI-1. .The Committee is satisfied that the edu-cational, technical and.more subtle attitudinal quality of in-- 3 struction is very-good. It also is confident that GPUINuclear . is striving continually to maintain and; improve its instructor. !~
. ' capabilities through its educational development programs.
f Committee, ff. Tr. 31,749, at 30; 11:252-253', supra.
-317.
L _- 'In' summary, the Committee found that during the i- ' period of time that has_ elapsed since the 1980 OARP Review-Com-
., mittee Report and testimony presented by;other licensee L -244-1 -
I: s
~
pmm.m ,-,w
F-consultants, the TMI-1 licensed operator training and requalification programs have been significantly improved. Ad-ditionally, there continues to be a strong GPU Nuclear man-agement commitment to training. Since the OARP Review Report was issued in 1980, most of the Committee's recommendations have been carried out, and the strongest aspects of the OARP have been developed further and incorporated in the current training program. The present program is superior to the OARP training program. Management has actually devoted considerable additional resources to training, as well as to systematically developing procedures that promote an effective program, The Committee, moreover, believes that the training programs cur-rently conducted at TMI enhance the Licensee's' ability to main-tain licensed operator competence. In short, the Committee be-lieves the present training program strongly supports thel restart of TMI-1. Id. at 18, 22.
- d. Communications 318. Based on-discussions with a variety of GPU Nu-clear personnel and a corroborative review of documents, the Committee found extensive evidence of effective communications between company management and the persons involved in the licensed operator training program -- both operators and
' training staff. There are a number'of ways in which these open
-245-('N v
L
1 channels of communication are fostered. The Special Report
-O -notes the'following lines of communication: (1) formal inter-views with~ operators by the Vice President / Director of TMI-1, Mr. Hukill, see 1 67, supra; (2) operator certification proce-dures requiring Operations and Training Department performance and attitude evaluations; (3) Mr. Hukill's attendance of
-training classes at least four-hours per month; (4) bi-weekly management reports from each division to senior GPU Muclear management; (5) periodic meetings by Mr. Hukill with operators and by the Vice President of Nuclear Assurance, Dr. Long, with' training personnel; (6) management and supervisory development programs; (7) weekly off-shift tours by management; (8) atten-dance by senior managers from Nuclear Assurance, Operations and LTraining at the B&W simulator; (9) approval of operator training programs, including schedules and content, by Opera-
~
tions management prior to their implementation and regular
. meetings between Operations and Training to discuss common issues _of_ interest; (10) meetings between shift management from week to week during requalification training in order to im-prove the program as it.is retaught; and (11) attendance by the Manager of Plant Training, Mr.' Newton, at Mr. Hukill's man-agers' meetings. Id. at 22-23.
319. .The Committee also found that GPU Nuclear's top management has emphasized the-need for and encouraged the
.. -246-L..
development of strong communication channels within the Com-
~
pany. A number of corporate memoranda and staff meetings bear out this finding. The necessity for GPU Nuclear employees to act honestly, responsibly and cooperatively also has been stressed by the company. Id. at 23, 320. After examination of the evidence, the Commit-tee has confidence in GPU Nuclear management's current aware-ness of the real and perceived problems of its employees. It has in place wor' king and demonstrably effective communication
. practices between top managment and the operating crews.121/
Id. at 24. 321. With respect to operator attitudes, the Commit-tee testified that it observed operators and candidates in the control room and at the B&W simulator. As our earlier discus-sion on methodology demonstrated,122/ the Committee has taken advantage of a number of opportunities to individually discuss training with numerous licensed operators, including all six shift supervisors. The Committee is also aware of the various 121/ Dr. Kimel testified that the barrier between manaqsment and _ the operators no longer exists due to the open line s of communication which allow operators to address their ccacerns regarding the training program or job performance with man-agement. Tr. 31,975-77 (Kimel). 122/ See TV 227-257, supra.
-247-n
(_)
processes and procedures in place to ensure that operator views O and criticisms of training are aired, responses provided, and appropriate actions implemented.123/ It is the Committee's im-pression, based on the observations and assessments it has made, that the operators recognize the value of and have re-spect for'the licensed operator training program, recognize and accept their responsibility as licensed operators to partici-pate in the program, and believe that it is an effective pro-gram. Committee, ff. Tr. 31,749, at'31. 322. After a thorough consideration of the issue, the Committee concluded that the licensed operator training program at TMI-1 is an effective program and will continue to _ qualify individuals to ' safely operate TMI-1. The Committee thus reaffirmed the conclusions reached in its Special Report and, in particular, the findings from that Report that the Com-mittee highlighted in its testimony. Id. at 31.
'123/ Mr. Kelly testified that operator attitude toward requalification training and annual requalification examina-tions is much more positive at TMI than the general resentment of the requalification process that pervades the industry. Tr.
32,170-71 (Kelly). He attributes the better disposition of the TMI operators to the open communications channels between Training and Operations which allow operators to-request and receive improvements in training. Id.
-248-
a
- 4. Summary and Conclusions
, 323. An extensive record has been developed concern-ing.the adequacy of the TMI-1 licensed operator training pro- !
~
gram and the Reconstituted OARP Committee's review thereof. Both the Staff and UCS presented testimony outlining their pro-posed methodologies for reviewing the training program. Nei-ther proposed methodology was shown to be superior to the meth- , odology used by the Committee when'it reviewed the licensed 1. operator 2 training program. We have carefully reviewed the-dif-ferences that exist between the three methodologies and find nothinglthat would indicate'that the Committee's review of the ~ tra'ining program was in any way inadequate to allow it to '
' address knowledgeably the remanded issues before us. We are 7 mindful that the Committee ~did not attempt to conduct, nor ;
l . - should it have conducted, an accreditation of'the. training pro-' I t t f~ i ~ gram; instead it embarked on an extensive review of the
.' - training. program to allow it to address the Appeal Board's re- --
~ - '
manded issues.. -This review was.a; follow-up to'the' baseline We are-con-1980 assessment;done by the OARP Review Committee. !~ fident that'the Committee'screview' met and exceeded'that i ithreshold-level of' review. We, therefore, find that!the Com- ; mitted's methodology'.used-to' assess the TMI-1 licensed operator
. training program isLadequate to support its findings concerning
- that program.- Moreover,-the Committee's' findings, which are. -
i f <
.-249-
/C L . 1 t 4 , < re -- . - = , ,-w %ch c- ,rm-w'ew-e,-~.-.,, -,M - w es*r ee e---,..e, r- - , - + -see r y, m,+w.u--.-,e--+.,-w-w--- ,v = w y e .w-,,,--. w. -m-e -mg-
very favorable, are fully consistent with the evidence
~- _ presented in this proceeding on licensed operator training at TMI-1.
III. CONCLUSIONS OF LAW 324. In accordance with the Appeal Board's decision in ALAB-772 remanding the issue of licensed operator training for further hearings, and based on the extensive evidence presented during the remanded proceeding, including the specif-
.ic expert views of the OARP Review Committee members, the Board concludes that licensed operator training at TMI-1, including the management, staff, facilities, programs and procedures, is adequate to train operators to operate TMI-1 safely. The Board further concludes that the issues in the remanded proceeding on training have been resolved in favor of restarting TMI-1.
Respectfully submitted, 0, 0AM% Ernest L._Blake, Jr., P.C. Deborah B. Bauser Wilbert Washington, II John N. Nassikas, III SHAW,'PITTMAN, POTTS & TROWBRIDGE 1800 M Street, N.W. Washington, D.C. 20036 (202) 822-1000 Counsel for Licensee Dated: February 13, 1985 /~ (3
'j
-250-}}