ML19344D591
| ML19344D591 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/20/1980 |
| From: | Aamodt M AFFILIATION NOT ASSIGNED |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML19344D583 | List: |
| References | |
| NUDOCS 8004250075 | |
| Download: ML19344D591 (5) | |
Text
&?AKETED
.usNr.c March 2C, 1980
/AR 311980 >
United states of America 6-Office of the Secretary 4
Dodeting & Serd e Nuclear Regulatory Commission Branch M
6 Before the Atomic Safety and Licensing Board N
c)
In the Matter of Metropolitan Edison Company, Three Mile Island Unit 1 Docket 50-289 (Restart) f AAMODT RESFnNSE TO LICENSEE'S OBJECTIONS TO CONTENTION 2 INTERROGATORIES Intervenor enters the following responses to Licensee's objections:
i a.
Interrogatory 4 - We are not able to understand how the reason given by Licensee for refusal to disclose tests would not be operative at a later date (April or May,1980), at which time Licensee is agree-able to disclosure.
Licensee also equates disclosure to Service. List with public disclosures it seems far-fetched to presume that personnel would obtain tests in this way.
Are personnel barred from use of the Discovery Reading room? Have personnel attempted or actually gained access to tests used in the past?
Additionally, if pre-knowledge of a f
test would preclude its usefulness, the testing process is in jeopardy j
consideration of i
because/the variety of human attributes that might predispose some and j
not others to " cheating" has been eliminated from the scrutiny of this hearing.
(Aamodt Contention 1) b.
Interrogatory 16 - The ability of operators to perfom under conditions of stress has been recognized in all studies
- as a necessary condition for adequate operation of a nu: lear power plant.
Clearly the l
operators were under considerable stress during the TMI-2 accidents the
]
lights, the buzzers, unexpected occurrences were some of the stresses.
If training breaks down under stress, is training then adequate.
" Con-fusion" is a descriptive term used to explain inappropriate action during the TMI-2 accident.
This interrogatory is referring to external stress (noise, lights, interruptions, number of hours on job, etc.) which can offect the adequacy of training under emergency conditions.
Licensee feels that this interrogatory is an attempt to drag in V 0042 5G (),g
'2 l
Aamodt Contention 1 which has been rejected.
Contention 1 dealt with i
individual variables: Contention 2 deals with variables in the training and operation processes.
(Since Licensee evidently did not understand what we meant by Contention 1, and since the human aspect cf safe operation of TMI-l is a central concern of the hearing, the contention is being reentered with intent to clarify.)
Contention 2, as accepted, requires demonstration of test perfonn-ance under " critical situations as well as routine situations."
Stress
[
i would be present during actual critical situations, hence a fair testing j
of performace for prediction of performance during an emergency should f
include as many conditions af strem as can be anticipated.
Interrogatory 17 - Objection accepted, however it would seem
]l c.
counter-productive to train individuals without screening their ability to function in " critical situations".
d.
Interrogatory 21 - Contention 2 deals with " performance of licensee technicians and management.. certified by an independent eng-ineering firm."
This is essentially a man-machine interface evaluation.
We just wanted to know whether you will train, test to cope with inter-ference of repair tags or if you plan to eliminate them, and therefore,
~
ther e is no need to deal with them in a training and testing progran.
This was thought to be a serious problem **, possibly attributing to human error and confusion during the TMI-2 accident.
If the same kind of maintainance tagging system is planned to be used in operation, it should be s'imulated in training and testing.
This is in the category of stress, and its potential effect on performance can be enormous, Interrogatory 22 - Licensee calls this request extraneous, e.
which except for the seriousness of our common concern, is ludicrous..
l The history of common experience is sufficient to cite proof positive i
that fatigue effects performance, both in training, testing and on the
job.
Common experience is backed by numerous measurements of experimental psychologists.
This interrogatory is not dealing with individual dif-ferences.ri.:.e.4 Jhow individuals differ from one another in performance as a function of fatigues that was the thrust of Contention _.1.
It is esking what is the optimal fit of length of shift and reliable perform-ance (as trained and tested),
L..
l f.
Interrogatory 23 - Same as for (e) g.
Interrogatories 24, 25 and 26 - We were attenpting to do some of the man-machine interface work that licensee should have done in attempt to understand all areas where hmuan error could be reduced.
If I.icensee has made such a study, the results would suffice.
h.
Interrogatory 36 -
Licensee objects to our request to depose employees for reasons that could easily have been settled amicably by tolerhone. communication.
We, therefore, request that a more specific request be granted.
We would like to select 10 employees from each job category from a complete list of employees submitted by job category,-
location (TMI 1 or 2).
he would like to question the employees selected by use of a questionnaire (written).
Questions will be in relation to performance and trainidg..
Copies of all questionnaires will be made immediately available to Licensee.
We request to use the Discovery Reading Room.
We would provide a notary for swearing-in.
We invite Licensee's suggestions relative _ toc. times.~e,tc., _We.woQld_be able to depose as soon as arrangements can be made with Licensee and request that this be'before April 5 i
Respectfully submitted,
- r
~
'b(&
LA.fldau.E Marj(or)ie M. Aamodt
March 21, 1980 United States of America Nuclear Regulatory Commission Before the Atomic Safety and Licensing Board In the Matter of Metropolitan Edison Company Three Mile Island Unit 1 Docket 50-289 (restart) 6 Certificate of Service I hereby certify that copies of the following:
AAMODT RESFONUE TO LICENSEE'S OBJECTION TO THE THIRD (SIC SIXTH) SET OF INTERROGATORIES DATED February 25, 1980 AAMODTREb1ONSETOLICENSEE'SOBJECTIONSTOIHESECONDLETOFINTERROGATORIEd AAMODT RESFONSE TO LICEN5EE'S OBJECTIOIN TO CONTENTION 2 INTE.RROGATORI were served on those persons on the attached service list by deposit in the United States mail, postage prepaid, this 22nd day of February, 1980.
/
!lA M,. h h f M Marjor M. Aamodt Dated:
March 21, 1980 s:t
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UNITED STATES OF AMERICA WUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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METROPOLITAN EDISON COMPANY
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Docket No. 50-289
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(Restart)
(Three Mile Island Nuclear
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i Station, Unit No. 1)
SERVICE LIST George F. Trowbr.i.dge, Esquire Shaw, Pittman, Potts & Trowbridge f
1800 M Street, N.W.
- Vashington, D.C.
20036' ~ _ _ ___
Tvan.W. Smith, Esquire i
Chairman Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory l
Commission Washington, D.C.
20555 Dr. Walter H. Jordan Atomic Safecy and Licensing i
?
Board Panel 881 West Outer Drive Oak Ridge, Tennessee 37830 i
Dr. Linda W. Little Atomic Safety and Licensing l
Board Panel.
5000 Hermitage Drive Raleigh, North Carolina 27612 i
James A. Tourtellotte, Esquire Office of the Executive Legal i
Director i
U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C.
20555
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