D.C. School Superintendent Floretta D. McKenzie says she expects about half the city's estimated 44,000 elementary school pupils to fail to meet midyear promotion standards in January under the school system's new and tougher promotion program.

The failure rate will be about the same as last year when half of the city's 21,000 first-to-third graders failed to meet the required standards, she said. Under those standards, students must master a certain number of reading and mathematics skills before they are promoted in January and June.

Last year, a crash tutoring program, dubbed Operation Rescue, was initiated to bring the failing students up to grade level. By the end of the academic year last June, all but about 3,857 had been promoted.

This year, however, the new promotion plan has been extended to all six elementary grades, affecting about 44,000 students, and school officials expect it will be even harder to bring the failing students up to the standards by the end of the year.

McKenzie, in a luncheon interview at The Washington Post Friday, said some teachers are posing a serious threat to the program by refusing to fill out a checklist that shows what specific reading and math skills each student has mastered or failed to master before the semester ends. The checklist is the major document verifying that a student is ready for promotion.

Teachers have complained that the checklist forms are too long and too complicated to fill out and that there is not enough time to teach all of the skills required for each semester.

In the sixth grade, for example, where there are usually 28 to 30 students a class, teachers are responsible for teaching 92 reading and math skills in the first semester. They must then check off on the forms what skills the students mastered and the date of mastery.

The Washington Teachers Union has filed a grievance against the school system on the matter, claiming that teachers have to fill out neither the checklists nor a new two-page report card, since this responsibility is not covered in their current contract. The matter will go to arbitration, McKenzie said.

Neither McKenzie nor the union could say how many teachers have refused to complete the checklists and report cards, but McKenzie said she intends to "check and see how widespread the disobedience is." She said teachers who refuse to follow her directives will receive formal reprimands.

"I have indicated that the promotions program is to be implemented in spite of the teachers' union instructions to the teachers not to complete the forms," McKenzie said.

"Some teachers say they thought they were being coerced into filling out the forms because their principals threatened reprimands if they did not fill them out," she said. "I didn't find that coercive. I found that the truth . . . . The teachers will do what they are told until such time as we get an impartial arbitrator."

McKenzie said she feels there are "pockets" of teachers who disapprove of the promotion plan in general but that opposition is not widespread. She acknowledged that the school system may be trying to teach students too many skills in too short a time and that she has asked the National Institute of Education, in conjunction with the University of the District of Columbia, to evaluate the program.

McKenzie has said in the past that it may be too "ambitious" to promote students twice a year. She has said she is considering a plan whereby students would still be held to specific promotion standards but would be promoted only at key grades, like three, six and nine.

Right now, the main help for failing students is the Operation Rescue volunteer tutoring program and extra instruction they receive from federally funded reading and math specialists.

In addition, McKenzie said, the system is already planning ahead for a summer school program for the failing students. She is also considering extending the school day, she said.

The sixth grade at Langdon Elementary School, 20th and Evarts streets NE, for example, is already coming in at 8 a.m. -- an hour early -- to keep up with the required work. Sixth grade teacher Margaret Washington said she had to teach most of her students math and reading skills that they should have learned in fourth and fifth grades before she could start them on sixth-grade work.

Linwood F. Williamson, a teachers union field representative, said he felt many teachers "do not believe" in the new promotions plan but are complying with it "because the superintendent wants it." He noted that teachers are the sole judges of whether a child has mastered a specific skill and that it is sometimes difficult for teachers to vouch for what each of 30 children knows.

Some school systems use standardized tests to determine a child's level of achievement, but the D.C. schools depend mainly on teacher judgment.