ML19296C967

Contentions Re NUREG/CR-1270 on Human Factors Evaluation. Alleges Failure of Control Room Design to Incorporate Adequate Technology & Failure of Util to Provide Adequate Training to Operators.Certificate of Svc Encl

ML19296C967
Person / Time
Site:	Three Mile Island
Issue date:	02/13/1980
From:	Pollard R CHESAPEAKE ENERGY ALLIANCE
To:	Atomic Safety and Licensing Board Panel
References
RTR-NUREG-CR-1270 NUDOCS 8002290146
Download: ML19296C967 (3)

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UNJTI:D STATES vi' f aERIca g ) NUCLEAlt IWGUI.ATORY COMMISSION CHA:CCN-80.02.13 2 DEFOlm Tl!E ATOMIC SAFETV AND 'ICENSING BOARD l

In the Matter of )

IM:TFGPOi,lTad hhIEuu Cut:t N.y Do 0- M (Three Mi.le  ;) :' nd , Unit l' )

CEA CCNTENTICNS (DRAFP) PURSUANT TO RSVIEW CF NUREG/CR-1270 Intervener, Chesapeake Energy Alliance (CEA), hereby submits the follcwing draft contentions pursuant to its review of NUREG/CR-1270, Humn hetors Evaluation of Control Rom Design and Cperator Performance,at TE-2:

(D)-14 CM contends that the Ccutr71 Rooln Design (CRD) of TE-1 substantialb fails to incorporate adequate, up-to-date, and available information technology and resources, and throagh this failure the CRD contributes significantly to undermining the reasonable assurance that in the event of an unanticipated sequence of abnormal transients, control room cporaters weald be denied adequate, readily accessible, and accurate infermation concerning relevant indicators cf plant status. CEA centends that until the inadequacies in the CRD are corrected. TMI-l shsuld not be allcwed to re-start.

There is a clear nexus between this contentien and the 79.03 28 accident at TMI-2 in light of the evidence presented in NUEG/CR-1270 on the assessment of the role of the TMI-2 CRD in that accident.' The review and description of the CED give evidence of numerous inadequacies and incensistencies in the CRD, from poor labelling and layout, inconsistent meanings of colors, etc. as well as great inccnveniences in access to and visibility of key elements of the Centrol panels and instruments.

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2 What is also clear 1;y evident fro NUREG/Cb1270 is there is clear failure to incorporate =odern information and control technology in the CRD (e.g. utilizatice of cceputers in presenting and displaying information on plant status onto video display units that could also be accessible to cthers, whether on or off-site, for review and censultation both rcutinely and in an emergency). With recent dev-elopments in infor=aticn technology, there is the opportunity for vastly more intelligent and efficient presentation (and potential analysis) of plant status indications, with concomitant inprovements in operator response and control in unanticapated event sequences. GA contends that a co=parative evaluation cf CRD with instrumentation display and control standards in aviation and space programs,'where there is a similar order of magnitude of instrumentation, controls, and accident consequences,would be mors than fruitful in this regard.

(D)-15 2A ccntends that the training provided to TMI operators, both overall and especially in regard to emergency procedures, is inadequate to provide reasonable assurance for the protection of the health and safety of the public, and that a full and thorough upgrading and overhaul of the Operator Training (Or) and Emergency Procedures (EP) is required prior to re-start of TMI-1.

As with draft centention (D)-14, the nexus with the 79:03:28 accident is clear from the NURE0/Cb1270 review of the role of CI and EP in the accident. Failure to remedy the deficiencies in CT and EP would clearly contribute to the probability of an accident at TMI-l with consequences equal to or greater than that of 79:03:28.

Respe supaitted

,.,.,I a

l Robert Q. Pollard, for DATED: February 13, 1980 CHESAPEAXE ENEMI mnum

UNITED STATES OF AMERICA GA: CCN-80.02.13 NUCLEAR REGULATORY CO:0!ISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

METROPOLITAN EDISON COMPANY ) Docket No. 50-289

) (Restart)

(Three Mile Island Nuclear )

Station, Unit No. 1)

CERTIFICATE OF SERVICE I do hereby certify that I served a true and correct copy of the foregoing document on the below listed parties by f'rst-class malling; c# b g/d. t Ivan W. Smith, Esquire Atomic Safety & Licensing Board Panel U.S. Nuclear Regulatory Cemmissirn Washington, DC 20555 Dr. Walter II. Jordan 881 West Outer Drive Oak Ridge, TN 37830 cs to ,

Dr. Linda W. Little / 4 5000 IIermitage Drive Raleigh, NC .27612 J/ $

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George F. Trowbridge, Esquire Shaw, Pittman, Potts & Trowbridge { i

.'6 1800 M Street, N.W. y g

Washington, DC 20006 Docl:eting and Service Section U .S. Nuclear Regulatory Commission Wanhington, DC 20555 E::ecutive Legal Director U .S . Nuclear Regulator; Commission Washington, DC 20555 Respcct'ully cubmit ed, f

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Dated: ' g(r2[ g-l / I / 'l'o b <' " S 0 . I'on cd, f e r' T c ;- ~ n ' ,, n i.,v ' G1 ' 1,L r,^ EC . .

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