|
---|
Category:EXHIBITS (DOCKETING AND SERVICES BRANCH INFORMATION
MONTHYEARIR 05000244/19860161986-11-12012 November 1986 Board Exhibit B-26,consisting of 861023 Insp Rept 50-244/86-16 & 861103 Forwarding Ltr ML20237H5151986-11-12012 November 1986 Board Exhibit B-25,consisting of Stating That 18% of MPR Total Billable Hours Spent on Nuclear Plants for Gpu & Subsidiaries from 1979-1985,10% in 1984,7% in 1985 & 7-10% Estimated for 1986,per Board Request ML20237H4421986-10-30030 October 1986 Board Exhibit B-22,consisting of Amended Spec Sections 9.3.4.2, Chemical Addition Sys & 5.2.6, Pump Flywheels ML20237H4631986-10-30030 October 1986 Board Exhibit B-23,consisting of Amended Specs,Including 5.2.3.2, Compatibility W/Reactor Coolant & 5.2.3.3, Compatibility W/External Insulation & Environ Atmosphere ML20237H4091986-10-29029 October 1986 Board Exhibit B-20,consisting of Forwarding Testimony of Dr Haverkamp W/Attachments,Including Insp Repts,Notices of Violation & Forwarding Ltrs ML20237H4191986-10-29029 October 1986 Board Exhibit B-21,consisting of Lh Bettenhausen 851007 Affidavit ML20237H4041986-10-10010 October 1986 Board Exhibit B-19,consisting of TMI-2 Control Room Layout Diagram ML20237H3921986-10-10010 October 1986 Board Exhibit B-18,consisting of 790215 Results of Reactor Coolant Leakage Test Sp 2301-3D1 ML20237H3901986-09-30030 September 1986 Board Exhibit B-17,consisting of Record of Dates,Reasons & Authorizations for Application of out-of-service Stickers to Devices ML20237H3531986-09-24024 September 1986 Board Exhibit B-16,consisting of 761008 Memo Re Category IV Control Room Operator (Cro) Training.Category IV Cro Study Assignment Sheet,Practical Evolutions Sheet & 90-day Cro Probationary Period Recommendation Sheet Encl ML20237H3241986-09-19019 September 1986 Applicant Exhibit A-15B,consisting of Resume of Dh Harrison ML20237H3121986-09-19019 September 1986 Applicant Exhibit A-15A,consisting of Resume of Nm Cole ML20237H4821986-09-18018 September 1986 Board Exhibit B-24,consisting of Forwarding Stated Items of Evidence,Per Request & Indicating That MPR Assoc,Inc Estimate of Percentage of Hours Spent Performing Svcs for Gpu During Past 10 Yr Not Yet Received ML20237H1781986-09-11011 September 1986 Board Exhibit B-11B,consisting of Graph Titled TMI-2 RCS Leakage Rate ML20237H1651986-09-11011 September 1986 Board Exhibit B-11A,consisting of Graph Titled TMI-2 Final Average Temp ML20237H1401986-09-11011 September 1986 Board Exhibit B-10A,consisting of Amended Senior Operator License SOP-2485-2 for Wh Zowe ML20237H1501986-09-11011 September 1986 Board Exhibit B-10B,consisting of Operator License OP-4602 for CC Faust ML20237H3031986-09-0808 September 1986 Applicant Exhibit A-12B,consisting of Rev 1 to Station Administrative Procedure 1036, Instrument Out-Of-Service Control ML20237G6711986-09-0808 September 1986 Applicant Exhibit A-1A,consisting of 850905 Vol Iv(C) to TMI-2 Reactor Coolant Inventory Balance Testing. Vol Consists of Section Ix,App K,Tests 1-25 to MPR-875, Technical Review of RCS Leakage at TMI-2, Dtd June 1985 ML20237G6781986-09-0808 September 1986 Applicant Exhibit A-1A,consisting of 850905 Vol Iv(D) to TMI-2 Reactor Coolant Inventory Balance Testing. Vol Consists of Section Ix,App K,Tests 26-50 to MPR-875, Technical Review of RCS Leakage at TMI-2, Dtd June 1985 ML20237G8711986-09-0808 September 1986 Applicant Exhibit A-1A,consisting of 850905 Vol Vi(K) to TMI-2 Reactor Coolant Inventory Balance Testing. Vol Consists of Witness Statements from J Stair,J Stupak, G Troffer,R Warren,D Weaver,D Wilson,R Zechman & W Zewe ML20237G9461986-09-0808 September 1986 Applicant Exhibit A-1A,consisting of 850905 Vol Vi(C) to TMI-2 Reactor Coolant Inventory Balance Testing. Vol Consists of Witness Statements in Alpha Order from R Dubiel to J Floyd ML20237G7031986-09-0808 September 1986 Applicant Exhibit A-1A,consisting of 850905 Vol Iv(G) to TMI-2 Reactor Coolant Inventory Balance Testing. Vol Consists of Section Ix,App K,Tests 101-125 to MPR-875, Technical Review of RCS Leakage at TMI-2, Dtd June 1985 ML20237G8971986-09-0808 September 1986 Applicant Exhibit A-1A,consisting of 850905 Vol Vi(J) to TMI-2 Reactor Coolant.... Vol Consists of Witness Statements from T Mulleavy,D Olson,I Porter,W Potts,M Ross, F Scheimann,J Seelinger,M Shafer,R Sieglitz & B Smith ML20237G9311986-09-0808 September 1986 Applicant Exhibit A-1A,consisting of 850905 Vol Vi(E) to TMI-2 Reactor Coolant Inventory Balance Testing. Vol Consists of Witness Statements in Alpha Order from L Harding to H Hartman ML20237H2961986-09-0808 September 1986 Applicant Exhibit A-12A,consisting of Rev 0 to Station Administrative Procedure 1036, Instrument Out-Of-Service Control ML20237G8531986-09-0808 September 1986 Board Exhibit B-4,consisting of 781027 Heat Balance Calculation for Group 32 ML20237H1071986-09-0808 September 1986 Applicant Exhibit A-9C,consisting of Control Room Photo ML20237G7391986-09-0808 September 1986 Applicant Exhibit A-1C,consisting of Advising That Author Conclusions in 860828 Rept on Facility Leak Rate Testing Remain Unchanged After Reviewing Missing Pages from Nrr/Ofc of Investigations Rept on Jr Congdon ML20237G8651986-09-0808 September 1986 Applicant Exhibit A-1A,consisting of Vol VI (a) to TMI-2 Reactor Coolant Inventory Balance Testing. Vol Discusses Witness Statements of C Adams,R Beeman,N Bennett,R Bensel, M Bezilla,J Blessing & R Booher ML20237G8871986-09-0808 September 1986 Applicant Exhibit A-1A,consisting of Vol VI (B) to TMI-2 Reactor Coolant Inventory.... Vol Discusses Witness Statements of J Boyd,K Bryan,D Buchter,J Brummer,J Chwastyk, M Coleman,W Conaway,J Congdon,M Cooper,E Curry & G Cvigic ML20237G6881986-09-0808 September 1986 Applicant Exhibit A-1A,consisting of 850905 Vol Iv(E) to TMI-2 Reactor Coolant Inventory Balance Testing. Vol Consists of Section Ix,App K,Tests 51-75 to MPR-875, Technical Review of RCS Leakage at TMI-2, Dtd June 1985 NUREG-0680, Applicant Exhibit A-7,consisting of NUREG-0680,Section 4.0, TMI-1 Leak Rate Falsification1986-09-0808 September 1986 Applicant Exhibit A-7,consisting of NUREG-0680,Section 4.0, TMI-1 Leak Rate Falsification ML20237G8221986-09-0808 September 1986 Applicant Exhibit A-1A,consisting of Vol V (D) to TMI-2 Reactor Coolant Inventory Balance Testing. Vol Discusses Tabs 38-53 ML20237G9241986-09-0808 September 1986 Applicant Exhibit A-1A,consisting of 850905 Vol Vi(F) to TMI-2 Reactor Coolant Inventory Balance Testing. Vol Consists of Witness Statements in Alpha Order from H Hartman to K Hoyt ML20237G9421986-09-0808 September 1986 Applicant Exhibit A-1A,consisting of 850905 Vol Vi(D) to TMI-2 Reactor Coolant Inventory Balance Testing. Vol Consists of Witness Statements in Alpha Order from E Frederick to C Guthrie ML20237H1241986-09-0808 September 1986 Applicant Exhibit A-9F,consisting of Control Room Photo ML20237G7051986-09-0808 September 1986 Applicant Exhibit A-1A,consisting of 850905 Vol Iv(H) to TMI-2 Reactor Coolant Inventory Balance Testing. Vol Consists of Section Ix,App K,Tests 126-150 to MPR-875, Technical Review of RCS Leakage at TMI-2, Dtd June 1985 ML20237G7841986-09-0808 September 1986 Applicant Exhibit A-1A,consisting of 850905 Vol V (C) to TMI-2 Reactor Coolant Inventory Balance Testing. Vol Discusses Tabs 15-37 ML20237G9131986-09-0808 September 1986 Applicant Exhibit A-5A,consisting of Undated Results of NRR Investigation & Evaluation of Ten Licensed Operators Involved in TMI-2 Preaccident Leak Rate Testing Irregularities ML20237H1261986-09-0808 September 1986 Applicant Exhibit A-9G,consisting of Control Room Photo ML20237G9181986-09-0808 September 1986 Applicant Exhibit A-1A,consisting of 850905 Vol Vi(G) to TMI-2 Reactor Coolant.... Vol Consists of Witness Statements from K Hoyt,T Illjes,D Jenkins,R Kleinfelter, H Kohl,G Kunder,L Lawyer,Jk Lionaroni,J Logan & J Manoskey ML20237G9071986-09-0808 September 1986 Applicant Exhibit A-1A,consisting of 850905 Vol Vi(H) to TMI-2 Reactor Coolant Inventory.... Vol Consists of Witness Statements from W Marshall,J Mcgarry,H Mcgovern & B Mehler ML20237G9031986-09-0808 September 1986 Applicant Exhibit A-1A,consisting of 850905 Vol Vi(I) to TMI-2 Reactor Coolant Inventory Balance Testing. Vol Consists of Witness Statements from B Mehler,A Miller & G Miller ML20237G7411986-09-0808 September 1986 Applicant Exhibit A-1A,consisting of Vol V (a) to TMI Reactor Coolant Inventory Balance Testing, Dtd 850905.Vol Discusses Tabs 1-9 ML20237H1141986-09-0808 September 1986 Applicant Exhibit A-9D,consisting of Control Room Photo ML20237G7581986-09-0808 September 1986 Applicant Exhibit A-1A,consisting of Vol V (B) to TMI-2 Reactor Coolant Inventory Balance Testing, Dtd 850905.Vol Discusses Tabs 10-14 ML20237G6931986-09-0808 September 1986 Applicant Exhibit A-1A,consisting of 850905 Vol Iv(F) to TMI-2 Reactor Coolant Inventory Balance Testing. Vol Consists of Section Ix,App K,Tests 76-100 to MPR-875, Technical Review of RCS Leakage at TMI-2, Dtd June 1985 ML20237H4741986-09-0808 September 1986 Applicant Exhibit A-5B,consisting of 850920 Memo Comparing NRR & Stier TMI-2 Leak Rate Test Evaluations.Technical Differences of Repts Not Significant to Overall Conclusion. Leak Rate Tests 1-156 for 781031-790331 Encl ML20237H0911986-09-0808 September 1986 Applicant Exhibit A-9A,consisting of Photo of Control Room 1986-09-08
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20210B8491999-07-21021 July 1999 Exemption from Certain Requirements of 10CFR50.54(w),for Three Mile Island Nuclear Station Unit 2 to Reduce Amount of Insurance for Unit to $50 Million for Onsite Property Damage Coverage ML20206D4141999-04-20020 April 1999 Exemption from Requirements of 10CFR50,App R,Section III.G.2 Re Enclosure of Cable & Equipment & Associated non-safety Related Circuits of One Redundant Train in Fire Barrier Having 1-hour Rating ML20206T7211999-02-11011 February 1999 Memorandum & Order (CLI-99-02).* Denies C George Request for Intervention & Dismisses Subpart M License Transfer Proceeding.With Certificate of Svc.Served on 990211 ML20198A5111998-12-11011 December 1998 Comment Opposing Proposed Rule 10CFR50.65 Re Requirements for Monitoring Effectiveness of Maintenance at Nuclear Power Plants.Proposed Rulemaking Details Collaborative Efforts in That Rule Interjects Change ML20154G2941998-09-17017 September 1998 Transcript of 980917 Public Meeting in Rockville,Md Re License Transfer of TMI-1 from Gpu Nuclear,Inc to Amergen. Pp 1-41 ML20199J0121997-11-20020 November 1997 Comment on Pr 10CFR50 Re Financial Assurance Requirements for Decommisioning Nuclear Power Reactors.Three Mile Island Alert Invokes Comments of P Bradford,Former NRC Member ML20148R7581997-06-30030 June 1997 Comment on NRC Proposed Bulletin 96-001,suppl 1, Control Rod Insertion Problems. Licensee References Proposed Generic Communication, Control Rod Insertion, & Ltrs & 961022 from B&W Owners Group ML20078H0431995-02-0101 February 1995 Comment Opposing Proposed Rule 10CFR50 Re Shutdown & Lowpower Operations for Nuclear Reactors ML20077E8231994-12-0808 December 1994 Comment Supporting Proposed Rules 10CFR2,51 & 54 Re Rev to NRC NPP License Renewal Rule ML20149E2021994-04-20020 April 1994 R Gary Statement Re 10 Mile Rule Under Director'S Decision DD-94-03,dtd 940331 for Tmi.Urges Commissioners to Engage in Reconsideration of Author Petition ML20065Q0671994-04-0707 April 1994 Principal Deficiencies in Director'S Decision 94-03 Re Pica Request Under 10CFR2.206 ML20058A5491993-11-17017 November 1993 Exemption from Requirements in 10CFR50.120 to Establish, Implement & Maintain Training Programs,Using Sys Approach to Training,For Catorgories of Personnel Listed in 10CFR50.120 ML20059J5171993-09-30030 September 1993 Transcript of 930923 Meeting of Advisory Panel for Decontamination of TMI-2 in Harrisburg,Pa.Pp 1-130.Related Documentation Encl ML20065J3461992-12-30030 December 1992 Responds to Petition of R Gary Alleging Discrepancies in RERP for Dauphin County,Pa ML20065J3731992-12-18018 December 1992 Affidavit of Gj Giangi Responding to of R Gary Requesting Action by NRC Per 10CFR2.206 ML20198E5581992-12-0101 December 1992 Transcript of Briefing by TMI-2 Advisory Panel on 921201 in Rockville,Md ML20210D7291992-06-15015 June 1992 Exemption from Requirements of 10CFR70.24 Re Criticality Accident Requirements for SNM Storage Areas at Facility Containing U Enriched to Less than 3% in U-235 Isotope ML20079E2181991-09-30030 September 1991 Submits Comments on NRC Proposed Resolution of Generic Issue 23, Reactor Coolant Pump Seal Failure. Informs That Util Endorses Comments Submitted by NUMARC ML20066J3031991-01-28028 January 1991 Comment Supporting SECY-90-347, Regulatory Impact Survey Rept ML20059P0531990-10-15015 October 1990 Comment Opposing Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal ML20059N5941990-10-0404 October 1990 Transcript of 900928 Public Meeting in Rockville,Md Re Studies of Cancer in Populations Near Nuclear Facilities, Including TMI ML20055F4411990-06-28028 June 1990 Comment Supporting Petition for Rulemaking PRM-50-55 Re Revs to FSAR ML20248J1891989-10-0606 October 1989 Order.* Grants Intervenors 891004 Motion for Permission for Opportunity to Respond to Staff Correspondence.Response Requested No Later That 891020.W/Certificate of Svc.Served on 891006 ML20248J1881989-10-0303 October 1989 Motion for Permission for Opportunity to Respond to Staff Correspondence in Response to Board Order of 890913.* Svc List Encl ML20248J0301989-09-29029 September 1989 NRC Staff Response to Appeal Board Order.* Matters Evaluated in Environ Assessment Involved Subjs Known by Parties During Proceeding & Appear in Hearing Record & Reflect Board Final Initial Decision LBP-89-7.W/Certificate of Svc ML20247E9181989-09-13013 September 1989 Order.* Requests NRC to Explain Purpose of 890911 Fr Notice on Proposed Amend to Applicant License,Revising Tech Specs Re Disposal of Accident Generated Water & Effects on ASLB Findings,By 890929.W/Certificate of Svc.Served on 890913 ML20247G0361989-07-26026 July 1989 Transcript of Oral Argument on 890726 in Bethesda,Md Re Disposal of accident-generated Water.Pp 1-65.Supporting Info Encl ML20247B7781989-07-18018 July 1989 Certificate of Svc.* Certifies Svc of Encl Gpu 890607 & 0628 Ltrs to NRC & Commonwealth of Pa,Respectively.W/Svc List ML20245D3651989-06-20020 June 1989 Notice of Oral Argument.* Oral Argument on Appeal of Susquehanna Valley Alliance & TMI Alert from ASLB 890202 Initial Decision Authorizing OL Amend,Will Be Heard on 890726 in Bethesda,Md.W/Certificate of Svc.Served on 890620 ML20245A5621989-06-14014 June 1989 Order.* Advises That Oral Argument on Appeal of Susquehanna Valley Alliance & TMI Alert from Board 890202 Initial Decision LBP-89-07 Authorizing OL Amend Will Be Heard on 890726 in Bethesda,Md.W/Certificate of Svc.Served on 890614 ML20247F3151989-05-22022 May 1989 NRC Staff Response to Appeal by Joint Intervenors Susquehanna Valley Alliance/Tmi Alert.* Appeal Should Be Denied Based on Failure to Identify Errors in Fact & Law Subj to Appeal.W/Certificate of Svc ML20246Q2971989-05-15015 May 1989 Comment Opposing Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants ML20246J6081989-05-12012 May 1989 Licensee Brief in Reply to Joint Intervenors Appeal from Final Initial Decision.* ASLB 890203 Final Initial Decision LBP-89-07 Re Deleting Prohibition on Disposal of accident- Generated Water Should Be Affirmed.W/Certificate of Svc ML20247D2761989-04-20020 April 1989 Transcript of 890420 Briefing in Rockville,Md on Status of TMI-2 Cleanup Activities.Pp 1-51.Related Info Encl ML20244C0361989-04-13013 April 1989 Order.* Commission Finds That ASLB Decision Resolving All Relevant Matters in Favor of Licensee & Granting Application for OL Amend,Should Become Effective Immediately.Certificate of Svc Encl.Served on 890413 ML20245A8381989-04-13013 April 1989 Transcript of Advisory Panel for Decontamination of TMI-2 890413 Meeting in Harrisburg,Pa.Pp 1-79.Supporting Info Encl ML20245A2961989-04-13013 April 1989 Transcript of 890413 Meeting in Rockville,Md Re Affirmation/Discussion & Vote ML20248H1811989-04-0606 April 1989 Valley Alliance/Tmi Alert Motion for Leave to File Appeal Brief out-of-time.* W/Certificate of Svc.Served on 890411.Granted for Aslab on 890410 ML20248G0151989-04-0606 April 1989 Valley Alliance/Tmi Alert Motion for Leave to File Appeal Brief out-of-time.* Requests to File Appeal Brief 1 Day Late Due to Person Typing Document Having Schedule Problems ML20248G0261989-04-0606 April 1989 Susguehanna Valley Alliance/Tmi Alert Brief in Support of Notification to File Appeal & Request for Oral Argument Re Appeal.* Certificate of Svc Encl ML20248D7211989-04-0404 April 1989 Memorandum & Order.* Intervenors Application for Stay Denied Due to Failure to Lack of Demonstrated Irreparable Injury & Any Showing of Certainty That Intervenors Will Prevail on Merits of Appeal.W/Certificate of Svc.Served on 890404 ML20247A4671989-03-23023 March 1989 Correction Notice.* Advises That Date of 891203 Appearing in Text of Commission 890322 Order Incorrect.Date Should Be 871203.Certificate of Svc Encl.Served on 890323 ML20246M2611989-03-22022 March 1989 Order.* Advises That Commission Currently Considering Question of Effectiveness,Pending Appellate Review of Final Initial Decision in Case Issued by ASLB in LBP-89-07. Certificate of Svc Encl.Served on 890322 ML20236D3821989-03-16016 March 1989 Valley Alliance & TMI Alert Motion for Extension of Time to File Brief in Support of Request for Appeal in Matter of 2.3 Million Gallons Of....* Certificate of Svc Encl.Served on 890316.Granted for Aslab on 890316 ML20236D3121989-03-15015 March 1989 Licensee Answer to Joint Intervenors Motion for Extension of Time to File Brief on Appeal.* Motion Opposed Based on Failure to Demonstrate Good Cause.W/Certificate of Svc ML20236D2901989-03-11011 March 1989 Valley Alliance/Tmi Alert Motion for Extension of Time to File Brief in Support of Request for Appeal in Matter of Disposal of 2.3 Million Gallons of Radioactive Water at Tmi,Unit 2.* Svc List Encl ML20236A3761989-03-0808 March 1989 Licensee Answer Opposing Joint Intervenors Motion for Stay.* Stay of Licensing Board Decision Pending Appeal Unwarranted Under NRC Stds.Stay Could Delay Safe,Expeditious Cleanup of Facility.Certificate of Svc Encl ML20236C2441989-03-0808 March 1989 NRC Staff Response in Opposition to Application for Stay Filed by Joint Intervenors.* Application for Stay of Effectiveness of Final Initial Decision LBP-89-07,dtd 890202 Should Be Denied.W/Certificate of Svc ML20235V2641989-03-0202 March 1989 Notice of Aslab Reconstitution.* TS Moore,Chairman,Cn Kohl & Ha Wilber,Members.Served on 890303.W/Certificate of Svc ML20235V2161989-02-25025 February 1989 Changes & Corrections to Susquehanna Valley Alliance/Three Mile Island Alert Documents Submitted on 890221.* Certificate of Svc Encl 1999-07-21
[Table view] |
Text
W h{(& & -
~
hrtP.fY l k CORPORATE CONFIDENTIAL 1 Date August 30, 1982
"^ * -
U v.w MUC Ger Suelect Lessons Learned from ASLB PID of July 27, 1982 To A d A M 4 President '85 FtosliioUMdquarters
~ .-
GFiL - N- ,
GCCe'ilhG A SEPT '
I. INTRODUCTION 6RAhCH The response of the Training & Education Department to thu cheating in-cident began ismediately in July and August, 1981 when the extent of the problem was revealed. Much of the initial response was focused upon the the " mechanics" of Training & Education Department examination and testing processes, since these were clearly found to be too loose and casual.
Formalization of these processes and development of administrative pro-cedures to handle employee misconduct were the primary issues addressed in my testimony before the ASLB Special Master. In this memorandum I will discuss broader issues which come from both a review of the AS!Js PID of July 27, 1982 and my ongoi'ng experience within GPU Nuclear during the past year.
II. ISSUES A. Training and Corporate Credibility Much of the discussion in both the report of the Special Master and the ASLB Partial Initial Decision reveals that employees lack confi-dence in the training process as well as in the various levels of GPUN management. I believe that this concern goes well beyond simply training issues. Employees may also lack confidence in plant procedures, administrative guidelines, corporatu policius, and management direction.
When this lack of confidence exists we can expect to see many types of misconduct, including such things as failure to follow procedures, de-liberato ignoring of administrativu practicus and guidelinus, casual implementation of management directives, and the willingness to take shortcuts wherever they seem to be convenient.
It also appears that employees are not certain that GPUN management is truly concerned and supportive of them in their efforts to comply with the training and operational / administrative requirements imposed upon them. Thus, it is not surprising that employces may be unwilling to admit to their supervisors that they need help in preparing for a particular examination or that they have not been able to satisfactorily complete a particular surveillance procedure or plant evolution. They may feel it is easier to seek unauthorized assistance, or , shortcut the surveillance procedure while indicating on the records that it has been satisfactorily completed, or move right on through a plant evolution even though certain requirements have not been met exactly as specified.
Clearly we will be shortsighted if we- do not look carefully at our entiro corporate conduct of business and particularly the conduct of opurations in the power plants.
8508200245 850102 .
PDR ADOCK 05000289
- O PDR
.N l: 2 c2
$ ^
.t eg D* c x' 7o egg _5 d' 9,sg
% U$
' '?
+%
~
afk4
% '%+
,I
4 E
! R. C. Arnold ,
August 30, 1982 Page two l B. Protection of the Integrity of Trainees and the Trainers Upon reflection it appears that one contributing factor to the multi-faceted problems revealed may be the confusion introduced in the training of operators by the fact that the licensed instructors perform in multiple roles. First of all they are trainees who had to receive the training and take the same mock exams and licensing exams administered by the NRC during the extensive retraining puriod following the TMI-2 accident. Second, they also were expected to perform as instructors for the larger number of operations personnel undergoing this retraining examination process; and third, they were expected to proctor and evaluate the progress of the trainees (basically including their own). We did not provide them any special guidance or insight into how to perform in this multiple role environ-Was there a ment nor how to determine which role was more important.
1 need to think through and verbalize the differences in performance depending on what role one was in? For example, when proctoring an
' exam did the instructor think like a student or like a proctor? The
' proctor had certain responsibilities to assure that students perform i
on their own and that the evaluation process demonstrate their true capabilities. However, since the proctor was himself a student, l might not both he and the students feel that they were in "the same
! boat" and that they should help each other get through this one more hurdle imposed upon them?
At the time that the NRC requalification examinations were given in April and October of 1981, there was a feeling on the part of both the trainers and the trainees that the written examination administered by the NRC was not a good measure of their ability to operate the plant.
i Thus the instructors were again placed in the difficult role of teaching material which they (as operators) were not necessarily convinced was really relevant to being an effective operator. This set of circum-stances was perhaps in a way unique to the TMI-1 situation, which was requiring all licensed personnel to be-relicensed. However, even in our ongoing programs the licensed instructors must perform on shift
! periodically, they must participate in an annual requalification program, and they must satisfactorily complete an annual requalification process.
j Although perhaps not with the same intensity as during the 1981 NRC re-certification exam process, this multiple role nature of our licensed operator instructors exists on an ongoing basis.
t i
i
! e
F R. C. Arnold -
August 30, 1982 Page three C. Empicyee Attitudes Although the new training facilities, increased instructional staff, an increased br eadth of training activities have sub-stantially improved our ability to deliver training, I believe we still have a long way to go in effecting employee attitudes towards.the entire nuclear power endeavor. This was certainly confirmed by the recent feedback we received from Drs. D' Arcy and Sauer of RHR, Inc. Employees may feel we have lost sight of our basic responsibility to produce electricity in a reliable and economic manner. The perceived new emphasis on procedures control, quality assurance, highly regimented and documented training, and frequent evaluations of all aspects of plant activities by outside age'ncies may indicate to them a concern with form rather than substance. There is clearly a need to find ways to effectively persuado our employees that our ru.-
sponsibility to the public and the industry demands an exceedingly
. high standard of conduct and an attitude towards performance of our work which is beyond reproach.
III. RESPONSE TO ISSUES ,
A. Restoring and Maintaining Credibility-i .There have been and are a number of activities underway directed towards this restoration and. maintenance of credibility for GPUN in the eyes of our employees. While I do not have any new ideas to suggest in this area, I believe that it is essential for all of us at all levels of management to continually demonstrate our commitment to creating a work environment in which issues are properly identified, addressed, and resolved.
B. Integrity of the Training Process The effort underway to review and revise the examination procedure, and to extend it:to use in a broader range of training activities (in-cluding some outside of the TEE Department) is part of the ongoing activity to assure the integrity of the training program. In addition, we will develop a better understanding of the multiple roles that are required of our licensed operator instructors. We will also look at l
. l
{7 ~
R. C. Arnold August 30, 1982 Page four this role issue in terms of our instructors in other areas. Specific guidance will be developed for the licensed operator instructors to help recognize and accept their responsibilities in the several roles.
They will also be helped to find ways to clarify these roles to their trainees. Thus, the trainees will understand that the instructor /
proctor relationship with them may require distinctly different be-havior from those which the licensed instructors exhibit when they are performing as licensed operators on shift, or as students in thei r ru-qualification training programs.
We need to continue to develop our capability to produce reliable, valid test instruments. Dr. Eric Gardner, Professor Emeritus of Educational '
Psychology, Syracuse University, has suggested the use of a table of specifications for each examination. The table would basically be a matrix which has a list of the topics to be covered on the examination, compared with identification of the types of behavior required to ef-factively demonstrate mastering of those topic areas. Specific test items or questions are placed in the appropriate position in the matrix.
Completion of such a table allows you to make a deliberate decision as to the percentage or fraction of exam which requires memorization, the fraction which requires analytical capability, the fraction which requires synthesis of ideas, and so on. Along with the ongoing activities of the T&E Department to explore test development techniques, this approach by Dr. Gardner will be considered.
The recent modifications to the content and administration of NRC
, licensing exams has resulted in better acceptance of the usefulness
- of the licensing exam to evaluate opera' tor capabilities. We will continue to work with both instructors and trainees to make certain they understand and accept the vital importance of the steps in the i
licensing process. We will also continue to provide inputs to NRC and INPO to help further improve the licensing examination process.
- Both in response to circumstances surrounding the PID, and the recent -
l- comparison by DDL of our instructor certification process with draf t l recommendations _being considered by INPO, we will take stups to tighten i . our process for certification of instructors in the T&E Department. As ismediate steps, we will require a practice lecture evaluated by the Training Department staff prior to placing any instructor into the classroom environment. We also will require the Manaque of Plant Training (or Corporatu Training) to. conduct an extensive inturview with each instructor prior to teaching of their first class. This ,
interview will be along the lines of the interviews of candidates for licensed operator positions which are conducted by the operating unit directors. The interview will explore instructor attitudes towards the instructional process, familiarity with the history and concerns I
1
( .. _ _ . - . . _ __ .. .. -- ._ .
! o il R. C. Arnold August 30, 1982
. Page five l
l raised by the PID, and their commitment to delivery of quality training. ,
The Director of Training & Education will conduct a follow-up interview
, during the first several months following the start of the instructor performance in the classroom.
These steps will begin immediately under a memorandum directive and will
! be formalized in the " criteria for qualifications of training instructors".
The criteria themselves will be developed by the end of 1982 through (a)
- review of the draft "INPO Guidelines for Technical Instructor Qualifica-
, tion", (b) review of the DDL report recommendations, (c) review of our Instructor Training Program, and (d) consultation with our instructors and outsiders, as appropriate. .
4 In addition to the above, it should be noted that the Quality Assurance i
Department has been involved with many of the efforts directed to assuming the integrity of the training process. The T&E and QA Departments will continue this cooperative effort and will formalize practices where re-quired.
C. Training's Responsibility for Attitudes I have recognized from the beginning of my assignment as Director of Trainini; & Education the significant responsibility that T&E Department instructors have towards influencing attitudes of our employees. This has been a subject of discussion among the T&E staff from the earliest ,
formation of this group. We will initiate additional activities to clarify for all of our instructional staff their understanding and acceptance of their responsibility for significantly influencing our employees' attitudes. Our training centers should be models for quality performance. This includes such things as physical appearances classroom environments starting classes on time; and providing full measure of per-i formance in the classroom both in terms of time devoted to subject matter
! and the quality of delivery of that matter. We will develop ways to clearly define and establish the value of the licensed operator requali-fication process, as well as the cyclic training for all of our technical positions. The importance of the NRC operator examination as a step in the certification process for an individual to operate the power plant will be emphasized. The basic principles trainers for TMI and Oyster Creek will enhance our ability to develop an alert attitude on the part of employees with regards to readinuss to handle unusual circumstancus.
We will assure that these devices aru fully utilized and that the company's commitment to obtaining them is fully recognized by both trainees and trainers.
1 4
4
.---_.m_ ,v_-_- , . _ . . _ , _.,_,~..m-_,.m. . , . , - , , _ . . . . , , , ,
p .
s R. C. Arnold August 30, 1982 Page six IV. CONCLUSION Specific concerns and criticisms in the ASLB PID of July 27, 1982 have been identified and addressed as part of the T&E Nuclear Assurance Division, and GPUN Corporate response effort. In this memorandum, I have developed and identified responses to several broad issues, in-cluding GPUN training and corporate credibility, protection of the integrity of the trainees and the trainers, and employee attitudes.
It is clear that an ongoing, objective examination of the GPUN training and education activities is required to assure the development and maturing'of GPU Nuclear.
( '\,
- Robert L. Iong Vice President Nuclear Assurance RLL:kg cc: P. R. Clark i