ML19331E074
| ML19331E074 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/27/1980 |
| From: | Sholly S AFFILIATION NOT ASSIGNED |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-SP, NUDOCS 8009050427 | |
| Download: ML19331E074 (8) | |
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SHOLLY, 8/27/80 A I p c)
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UNITED STATES OF AMERICA f
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tiETROPOLITAN EDISON COMPANY, ET AL.
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Docket No. 50-289
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(RESTART)
(Three Mile Island Nuclear
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Station, Unit No. 1)
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INTERVENOR STEVEN C. SHOLLY REQUEST TO LICENSEE FOR SUPPLEMENTATION OF DISCOVERY REQUESTS AND DISCOVERY REQUESTS BASED ON NEW INFORMATION CONTAINED IN ARTICLE IN "TMI TODAY" RECEIVED 8/26/80 The Board, in the First Special Prehearing Conference Order, accepted for litigation Sholly Contention #15 which states as follows:
"It is contended that the design of the Unit 1 control room, instrumentation, and controls is such that operators cannot maintain system variables and systems within prescribed operating ranges during feedwater transients and LOCA's.
It is further contended that this violates the provisions of GDC 13 regarding instrumentation and controls.
It is contended that in view of the numerous operating difficulties encountered with Unit 2, and the similarities in design and construction between Units 1 and 2, a thorough human factors engineering review of Unit l's Control Room is called for in order to provide assurance that the operator-instrumentation interface is such that the operators can exercise adequate control over the reactor and prevent off-site consequences from anticipated operational occurrences and postulated accidents.
It is further contended that in order to assure naximum protection for the public health and safety, the human factors engineering review and any necessary changes recommended as a result of this review be completed prior to restart."
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SHOLLY,8/27/80 Sholly Contention was accepted by the Board without objection.
Intervenor Sholly has entered into substantial discovery with respect to Contention 15, submitting 76 interrogatories under general discovery and two additional " follow-on" discovery requests.
In addition, a portion of a day was spent in the TMI-1 Reactor Control Room taking photographs which will be introduced into evidence during the litigation of Contention 15.
Central to the pursuit of Contention 15 is the issue of the need for a human factors engineering review of the TMI-1 Control Room.
Several discovery requests on this matter were directed to the Licensee.
On August 26, 1980, Intervenor Sholly received a publication from the Licensee called "TMI Today". According to the publications information on page 2 of the August 1980 issue, the publication is published by "TMI Communications Services" ar.d its editor is Dave Klusick who is known by the Intervenor to be a member of Licensee's staff. Contained in the August 1980 edition of TMI Today is an article entitled, " Human Factors Analyzed." The article begins on page one and continues on to page eight.
(SEE attached copy of the article)
This article contains information which requires supplementation of certain prior discovery requests as per 10 CFR 2.740(e).
These discovery requests, in the form of interrogatories, are repeated below.
Further, the article cor.tains information which is "new information" and is therefore subject to discovery requests upon leave of the Board.
The discovery requests which require supplementation will be specified, l
followed by a motion for leave from the Board to submit specific discovery l
SHOLLY, 8/27/80
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requests based on new information contained in the August 1980 issue of "TMI Today", received by Intervenor Sholly on August 26, 1980.
The following interrogatories were posed to the Licensee, and which now require supplementation as a result of the "TMI Today" article:
15-001--Provide copies of all documents, including tapes, letters, memoranda, transcripts, and files relating to human factors review of the design of the Unit I reactor control room.
COMMENT: Licensee's response indicated that at least portion of its response to this interrogatory would be presented in direct testimony.
I indicated that this was unacceptable.
There now exists no reason why this material should not be made available to me prior to the date for submission of direct case.
The information is apparently now available as to the specifics of how the control room mockup in the Turbine Building was created, who performed the mockup, what procedures are being tested with the mockup, and what if any deficiencies have been discovered by the use of the mockup.
15-005--Has Licensee or its contractors ever asked TMI operators to evaluate the design adequacy of the control room?
COMMENT: Apparently, a significant componer.t of the recently revealed control room mockup is the evaluation of both control room design and procedures as they relate to the control room design.
New information developed thus far should be provided, with further supplementation as required while additional evaluations proceed.
The following interrogatories are based on new information contained in the "TMI Today" report on Licensee's human factors review of the TMI-1 Control Room.
I hereby request leave from the Board to pose
C SHOLLY,8/27/80 15-077--Identify by name and position all persons employed by Licensee or any of its contractors who have participated in and/or are participating in the human factors review of the TMI-1 Control Room by the development and use of the mockup in the Unit 1 Turbine Building as described in "TMI Today".
15-078--Do any of the individuals identified in response to Interrogatory 15-077 above possess any formal training in any specific area of human factors engineering? If so, identify each such nerson by name and provide a description of the training, including where the training was obtained and when it was obtained (during what year or years).
15-079--According to the article in "TMI Today", " key operational and emergency procedures are being ' walked through' to develop a clear understanding of how displays, controls and communications channels are used in the Control Room."
Identify by name and procedure number which procedures are being evaluated by this method.
Identify by name and position the persons who are performing the so-called " walk througn" and the persons wilo are evaluating the results of the walk through and recommending procedural changes.
15-080--The article in "TMI Today" contains a statement by Gary Broughton l
which states:
"we want to match the capabilities of the operators to absorb information with the capabilities of control displays to l
SHOLLY, 8/27/80 provide information." With regards to this statement, tientify specifically by what means Licensee has determined the " capabilities of the operators to absorb information".
Further, quantify the capabilities of the operators to absorb information, and how this data is being related to how much information is generated by the current Control Room design.
From the point of view of this Intervenor, because of the past history on the part of the Licensee in attempting to avoid reasonable interrogatories on this contention, the Board may, in the event that the Licensee objects to any of these new interrogatories, treat this as a motion to compel discovery on these interrogatories.
The reasons why Licensee should be required to respond to these interrogatories are as follows:
15-077--This interrogatory could not have been posed before I knew about the existence of the mockup in the Turbine Building,, knowledge of which would have been revealed had Licensee timely supplemented its responses to earlier interrogatories.
Such information is crucial to determine the credibility of the review being j
performed.
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1 15-078--Same as for 15-077.
The knowledge about each such person's formal training in human factors engineering is very important.to assessing the relevance of the mockup
SHOLLY,8/27/80 to the need for a thorough human factors review of the design of the TMI-1 Control Room which is the basis of Contention 15.
The degree to which this activity on the part of the Licensee may meet part of the concern embodied in Contention 15 can only be determined if this information is provided.
15-079--This information is needed to assess the bounds of procedures which are being tested on the walk through basis.
Key procedures have been identified by other reviewers, and I wish to determine if these procedures are being evaluated in this program.
15-080--This information is very central to the issues embodied in Contention 15.
One of the key questions which would be answered by a human factors review of the TMI-1 control room would be if there is too much information preser.ted for operators to handle, or do there exist mechanisms by which display of information to operators in a different format could improve the ability of the operator to absorb operational and control information, so as to reduce the chances of human error.
RESPECTFULLY SUBMITTED, DATED: 27 August 1980 Steven C. Sholly
SHOLLY, 8/27/80 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Docket No. 50-289(RESTART)
CERTIFICATE OF SERVICE I hereby certify that single copies of INTERVENOR STEVEN C. SHOLLY
.(EQUEST TO LICENSEE FOR SUPPLEMENTATION OF DISCOVERY REQUESTS AND DISCOVERY REQUESTS BASED ON NEW It: FORMATION CONTAINED IN ARTICLE IN "TMI TODAY" RECEIVED 8/26/80 were served on those persons below by deposit in the United States mail, first class, postage prepait', this 27th day of August 1980.
Steven C. Sholly Mr. George F. Trowbridge, Esq.
Mr. James Tourtellotte Esq.
Shaw Pittman Potts and Trowbridge Office of the Executive Legal Director 1800 M Street, NW U.S. Nuclear Regulatory Comission Washington, D.C.
20006 Washington, D.C. 20555 Mr. Ivan Smith, Esq.
Secretary of the Comission Chairman, Atomic Safety and U.S. Nuclear Regulatory Comission Licensing Board Panel Washington, D.C.
20555 U.S. Nuclear Regulatory Comission ATTN:
Docketing and Service Section Washington, D.C.
20555 Mr. Daniel Pell, Esq.
Dr. Linda Little Counsel for ANGRY 5000 Hermitage Drive 32 South Beaver Street Raleigh, NC 27612 York, PA 17401 Dr. Walter Jordan Ms. Ellyn Weiss Esq.
881 liest Outer Drive Counsel for UCS Oak Ridge, TN 37830 Harmon and Weiss 1725 I Street, NW Suite 506
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Washington, D.C.
20006
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t 3L.I,NO.2 PUllLISilED IlY TilitEE MILE ISLAND NUCLEAR STATION AUGUST,1980 an actors SHalyZed numan ractors Neve,theless. because of the criti.
cisms which have been made of hu-A full-scale Control lloom mockup llroughton explains that *,we want 1
man factors design aspects et floor to evaluate Unit 1 Control Room operators to absorb information with ' {H}QQf $ Q(]If
' has been in use in the Unit I turbine to match the capabilities of tho nuclear power control rooms gen-erally, a closer look at the Unit I con-
- design and analyze potential "hu-the capabilities of control displays to trol room design was undertaken,
- man factors" problems m the ar-provide mformation. This should Broughton adds.
.rangement and design of controls make it easier for Control Room c,,,,,,,g f,,,,,,,,
and displays in the main Control operators to assimilate data.
' lloom.
"In effect," he says, "we're jry.
the walk-through. The object of this According to Gary llroughton.
ing to acconunodate the workings of review is to ensure that items such GPU control and safety analysis a human being with the workings of as rendability are evaluated.
manager, the Control Hoom mockup instrumentation."
GPU plant analysis manager Pat is designed for several uses. "What The operating procedures which Walsh adds that a review of alarm we're trying to accomplish is the are being exercised on the mockup systems is also being performed to right display of information that re-include plant heatup and startup (in.
evaluate the usefulness of the in-duces the likelihood of operator er-cluding operations at power), shut.
formation presented to the operator ror."
down and cooldown and refueling.
in both normal and unusual situa.
The mockup consists of panel tions.
A variety of emergency pro-fronts reproduced by a comb, ation cedures are being exercised, in-Ilroughton and Walsh point out m
of photographic and photocopy en-cluding reactor trips from several that Unit I has had nn excellent causes, turbine trips, lesses of feed-availability record durmgs its five I"'"""*"'*'
On the model control panels, key water flow and several cases where years f c mm rcial operation. "It operational and emergency pro-reactor coolant would be lost.
had very few operatiom.1 problems I)isplays and controls on the prm.-
during this period and very few, if cedures are being " walked through" did b be milmad 4 to develop a clear understanding of capal panels and c nsoles are bemg any certainty to human factors prob-how displays, controls and commun-reviewed one by one, separato from ications channels are used in the lems in the arrangement and design Control Itoom. Studies of these pro-Ca'iaued 'a Pase 8 of the main control room," Walsh cedures'should indicate what if any notes.
changes would be desirable.
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