ML19340D616

Requests That Date for Submittal of Testimony on Training & Testing Issue Be Extended Until 810202.NRC Approval of New Met Ed Training & Testing Procedures Lacks Scientific Basis.Related Correspondence

ML19340D616
Person / Time
Site:	Crane
Issue date:	12/15/1980
From:	Aamodt M AFFILIATION NOT ASSIGNED
To:	Jordan W, Little L, Smith I Atomic Safety and Licensing Board Panel
References
NUDOCS 8012310405
Download: ML19340D616 (7)

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Coatesville, Jennsylvania 19320 Dece:ber 15, 1980 Ivan 'a'. Smith, Zsquire Chairman Atenic Safety and Licensing Board Fanel g

N U. S. Huclear Regulatory Conmission O

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Atomic Safety and Licensing Board Fanel g

" l 881 Wes', Outer Lrive Cak Ridge, Tennessee 37830 4i Cr. Linda W.

Little Atomic Safety and Licensing 3 card Fanel

-5000 Hermitage Irive Eali'sh, North Caroll-na 27612 Lear 30ard i%cbers:

Cn 'dednesday, Iecember 10 further discovery on my contention 2 was pursuec by way of a conference call initiated by Daniel Swanson, Counsel for NRC Staff.

Several others of thT Strff participated a.s,.,

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well as Er. 31ake representing the Licensee. -

I was asked to indicate the specific ar"eas within contention 2 s

which I intended to pursue in the hearing.

.~I indicated that'they were adequacy of testing of control root operators as a predictor of per-formance of these operators under various conditions of stress, fati6ue and attitude, and the validity of change'si,in training, proposed

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2 The licensee, according to F.r. Elake, is requesting submittal of written testimony by Lecember 22 and readiness for trial by January These dates, if granted, would prohibit my participation in the hearing relative to training and testing.

Although considerable ti=e has elapsed since the acceptance of

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contention 2 by the Board, ' discovery' has been ongoing.

I was hopeful until the recently published evaluation of the Staff that the areas of my concern regarding training and testing would be addressed by the Staff, thereby taking any further effort on =y part unnecessary.

That has not happened.

The Staff indicated in their supplement to their response to restart that they were satisfied with the licensee's pro-posed training and testing program,as they had indicated earlier in their evaluation.

However, their evaluation appears to be based on.

opinion rather than precise standards.

This was pointed out in my response (10/15/50) to Staff interrogatories inquiring why I considered that. the ~1censee still had not met the stipulations of contention 2 Eeither the licensee in their program or the Staff in their original evaluation of-in their supplement. provide any evidence that the changes in the training and testing will indeed result in improved performance by control room operators.

kr. 31ake indicated that ' assurance' will be provided by an independent engineering firm in written testimony 1

It would be too late at that time for me to cbtain witnesses if the testimony of the engineering firm appears to be in errcr.

It would seem that the licensee should have been willing to provide this infor ation subsequent to our discovery of Oecember 10.

If this was the intention

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of the 3 card, I motion that the licensee be co=pelled to provide -this information prior to submittal of testi=ony.

Iuring discovery on Dece=ber 10,.I requested and Jir. Swanson

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3 agreed to supply a number of documents that would be helpful to he in preparing to represent contention 2.

None of those documents have.

arrived.

I a= therfore requesting that.the date for submittal of testimony on training and testing issue be extended until February.2 at the earljest.

This is assuming that the documents to be provided by the Staff will arrive by January 5, thereby allowing three weeks for study and preparation and a week for mailing.

At one point in the preheari.7g conferences, training and testing b

weryotincludedwithmanagementissues.

While training and, testing 9

fall' under the purviewpf manageient,.the. design of a. trainingnand must testing program should be the. responsibility of technically trained

" human engineers'.

This is the thrust of contention 2, and it was accepted, so stated, as relevant and litigable in this hearing.

To hear contention 2 in the light in which it was framed, apart from canagement issues, would appear proper and would not detain the hearing of those issues.

I would also like to bring again to the 3 card's attention my opinion that contention 2 deserves core adequate representation than I will be able to make.

Although if given tite, I will make every effort within my means to defend the areas contended, my means are licited. Continuing in the hearing has been a considerable burden since intervenor funding and legal assistance have been denied.

4 Eisk analysts have targeted " human error" as4 highly probably cause of a future major accident.

Training is acknowledged to have an effect on reducing human errors.

The changes in training proposed by the Licensee are being put forth as meaningful in the sense of reducing future hu an errors.

The Staff is evidently willing to accept changes as improvements without scientific evaluation or

4 at least not articulating that evaluation.

The Licensee has bired an.' evaluator', whether in response to contention 2 or because.of their own cognizance is not known.

The question is whether the testimony of the Licensee's evaluator will have to stand against nere than my cross-qv.estioning)or others with even less knowledge and uperience in numan engineering)or whether the Board will provide experts in the field of human engineering --highly qualified and in-dependent of the Licensee -- to assure tha the licensee'.s program is can be,to protect the health and safety of the public.

the best it I, therefore, motion that the Board provide assistance as described above so that I; and the public, can be assured that the training and testing program at TMI Unit 1 has been adequately and independently evaluated.

spectfully submitted, m

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!.arjo[J Aamodt b

lecember. 18, 1980 -

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CR 2 9 G80 > E E. L. 5, Box 42a e

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y ag e Iecember 16, 1930 EE:

Training and Testing Contention In the Matter of I.etropolitan Zdison Company, et al.

(Three Mile Island Nuclear Station, Unit 1)

Docket No. 50-289 -(Restart) lacies and Gentlemen:

The attached letter was served on the 3 card Ianel, the Locketing

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anc Service Section of the U. S. Nuclear Regulatory Commission, hr. Tourte110ttee of the U. S. Nuclear Regulatory Commission and Er. George F. Crowbridge of Shaw Fittman, lotts & Trowbridge anc counsel for Eetropolitan Zdison Company or their representatives in Harrisburg on December 19, 1980.

ncerely, klA

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LL4A; I.arjo-ie Aamodt Inter'_nor, Three kile Island Restart Hearing Service by mail, uecember M, 1960 to parties on attached Service list instead of as above, cue to change in time of meeting and c:nflict with prior appointment.

The express delivery service was unable to find our home anc delivery of.,Uhr,G-0746 was mace y LC i 'y;af ternoon late.9 D

+m I intent to speak with Joseph Gray, Counsel for HEC, about subsequent ciscovery on this document as a quick perusal leaves many unanswered questions.

Not allowing the change in time, I would have been unable to prepare for the Iecember 19 meeting due to. the late arrival of

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the evaluation.

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CONSIGNEE COPYG?

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Ivan W. Smith, Esquire Chaircan Atr.mic Safety and Licensing Board Fanel' U.S. Nuc3 car Regulatory Cctrission Washin'gton, D.C.

20555 j

Dr. Walter H. Jordan Atemic Safety and Licensing Soard Tanel S81 West Outer Drive Oak Ridge, Ter.nessee 37830 Dr. Linda W. Little Atomic Safety and Licensing Board Panel 5000 Hermitage Drive Raleigh, North Carolina 27612 James A. Tourte11otte, Esquire Office of the Executive Legal Director U.S. Nuclear Regulatory Ceraitsion Washington, D.C.

20555 Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Cc:missien Washington, D.C.

20555 George F. Trowbridge, Esquire Shaw, Pittean, Potts & Trewbridge 1800 M Street, N.W.

Washington, D.C.

20036 I

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