ML19347C659
| ML19347C659 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 12/22/1980 |
| From: | Prince H, Ramirez R Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19347C658 | List: |
| References | |
| NUDOCS 8101050042 | |
| Download: ML19347C659 (12) | |
Text
,_ o UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFE' _ ;D LICENSING BOARD In the Matter of METROPOLITAN EDISON COMPANY
)
Docket No. 50-289
)
(Three Mile Island Nuclear
)
(Restart)
Station, Unit No. 1)
)
TESTIMONY OF RAYMOND G. RAMIREZ AND HAROLD E. PRICE RELATING TO CONTENTIONS Sholly 15 & ANGRY Issue Sc O.1 Please state your name and your position with the NRC.
A.
My name is Raymond G. Ramirez.
I am a senior Human Factors Engineer with the U. S. Nuclear Regulatory Comission assigned to the Office of Nuclear Peactor Regulation, Division of Human Factors Safety, Human Factors Engineering Branch. From June 1979 until April 1980, I was assigned to the Instrumentation and Control System Branch.
Q.2 Have you prepared a statement of professional qualifications?
A.
Yes. A copy of this staternent is attached to this testimony.
0.3 Please state the nature of the responsibilities that you have had with rescect to TMI Unit 1 Nuclear Generating Station.
edtaakp5 N.t meme gas
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A.
I am the team leader who was responsible for reviewing the TMI-l Control Room from a human factors engineering standpoint prior to restart.
9.4 What is the purpose of your testimony?
A.
The purpose of my testimony is to respond to Sholly Contention 15
& AMGRY Issue Sc.
Q.5 fir. Price, please state your name and position with the NRC.
A.
My name is Harold E. Price.
I am a Human Factor Censultant to the Human Factors Engineering Branch of the Division of Human Factors Safety in the Office of Nuclear Reactor Regulation of the Nuclear Regulatory Commission.
0.6 Have you prepared a copy of your professional qualifications?
A.
Yes.
It is attached to this testimony.
0.7 ffr. Price, please describe your connection with the Three Mile Island Station.
A.
I participated as a human factors consultant with the NRC audit team performing the TMI-l Control Room review.
0.8 What is the purpose of your testimony?
A.
The purpose of my testimony is to respond to Sholly Contention 15 &
Angry Issue Sc.
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- 8 Sbolly Contention als States
"It is contended that the design of the Unit I control rooru, instrumentation, and controls is such that operators cannot maintain system variables and systen 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 similarties in design and construction between Units 1 and 2, a thorough human factors engineerina review of Unit l's Control Room is called for in order to pro-vide assurance that the operator-instrumentation interface is such that the coerators 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 maximum protec-tion for the oublic health and safety, the human factors engineering review and any necessary changes reconmended as a result of this review must be comoleted prior to restart."
Ancry Issue 35c States:
"The NRC Order fails to recuire as conditions for r astart the following modifications in the design of the THI-l reactor without which there can be no reasonable assurance that TMI-l can be operated without endangering the oublic health and safety."
(c)
Parformance of an a.1alysis of and implementation of modifications in the design and layout of the TMI-l control room as recommended in P!UREG-0560.
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i 0.9 Has NRC conducted a human factors engineering review of Unit i 1
control room?
A.
Yes. A review team consisting of members of the Human Factors Engineering Branch and a Human Factors Engineering consultant con-ducted an on-site visit review of the TMI-l control room from July 21 to July 25, 1980. The review team emphasized tne following aspects of the control room:
(1)
The adequacy of information including alarm system information presented to the operator to reflect plant status for normal operation, anticipated operational occurrences, and accident conditions; (2)
Improvements in the safety monitoring and human factors enhancement of controls and control displays; (3)
The operability of the plant from the control room with f
multiole failures of nonsafety-grade and nonseismic systems.
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The review was performed by means of inspections of control room layout, environment, and consoles / panels; interviews with operators; and observa--
tion and videotaoing of operators as they walked through selected emergercy procedures and an escorted walkthrough of the Unit-2 control room.
0.10
'4 hat was the purpose of this review?
A.
The human factors engineering control room design review was l
conducted at the recuest of the Division of Licensing (DOL) and in l
conjunction with the TMI-l restart order.
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i The purcose was to identify human fact]rs deficiencies and j
require, crior to restart, the correction of those de#iciencies,
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which hav'e an increased cotential for causing operator ery )r.
We believe that the correction of these deficiencies will si;nificantly imorove the operator's ability to safely control plant et tration during normal and abnormal operating conditions. These imorovements will make the TMI-l control room comoarable with the control rooms of newly licensed Diants.
In addition to the NRC review, the licensee, like all other operating reactor licensees, is recuired to perform a Detailed Control Room Design Review (DCRDR) which is excected to take aoproximately one year to complete after the NRC guidelines are issued'l This may identify other human factors
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improvements in addition to those that may be recuired orior to i
restart.
The design review team made a tour of the Unit 2 control roon sufficient to determine that the Units 1 and 2 control room designs were significantly different. The review then concentrated Unit 1 control room to determine deficiencies in the
'm on assest design of the coerator-instrumentation interface which could lead to potential ooerator error.
' 11 What did you leara from this review:
A.
Using the draft report NUREG/CR-1580, " Human Engineering Guide To Control Room Evaluation" and other human factors guidelines as a basis for comoarison, we found that there were certain design i
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deficiencies. These design deficiencies have been documentad in a staff recort and in NUREG-0752, " Control Room Design Review Recort. The licensee has emoloyed the services of a h,uman factors engineering consultant to orovide recomrendations for imoroving their control room design and for correcting human factors defici-encies.
Q.12 How serious are these deficiencies?
A.
Some of the deficiencies are considereo significant.
The deficiencies were evaluated on the basis that they could crecipitate ce contribute to unnecessary coerator error during both normal and emergency coerations, and cotentially imoact safety, The licensee was informed as to what these deficiencies are and has met with the NRC staff to discuss what actions will be taken to correct them. We will reouire the licensee to imolement actions to correct the more significant deficiencies identified in NCREG-0752, 0.13 Do they constitute a violation of GDC-13? Why or why not?
i A.
No. They do not constitute a violation of GDC-13 because adequate instrumentation necessary to monitor an accident has been provided as i
recuired by the criterion. The review was concerned with the appli-l cation of human factors engineering standards and principles to I
control room design which are not addressed in GDC-13.
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1 0.14 Is it necessary that these deficiencies be corrected pricr to restart? Why or why not?
A.
Yes, we are requiring that the significant deficiencies be corrected orior to restart.
-cwever we believe that the correction of a number of minor deficiencies can be deferred until after restart.
It is the staff's opinion that all modification necessary to bring TMI-l on a comparable basis with the other cperating plants should be incorporated prior to rettart.
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4 RAYMOND G. RAlilREZ PROFESSIONAL OUALIFICATIONS HUMAN FACTOPS ENGINEERING BRANCH OIVISION OF HUMAN FACTORS SAFETY Since Acril 1980, I have been assigned to the Hunan Factors Engineecing Branch, Division of Human Factors Safety, Office of Nuclear Reactor
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Degulation. I began devoting full time to human factors engineering in
'lovember 1979.
Initially, I was resconsible for helping to implement the reccamendations of Section 7, Appendix A to NUREG-0585, "TMI-2 Lessons Learned Task Force Final Report". These included assisting in; dev aloping human factors control room design review guidelines for use by licensees to 1
conduct year long reviews of their control rooms and surveying selected control rooms to provide a data base for the guidelines. Since February 1980, I have been working closely with human factors excert consultants as the NRC's team leader, in conducting onsite control room design reviews anc in evaluating the results thereof.
I have participated in the review and evaluation of 14 control rooms thus far.
1 I graduated from Ohio University in 1958 with a Bachelor of Science Degree in Electrical Engineering, and in 1971 I graduated from the University of Baltimore with a Juris Doctors Degree in Law.
From 1958 to 1960 I cerformed as a design engineer at the Radio Corporation of America's " Missile and Surface Radar Division", which among other things involved the instrumentation and control of large radar systems.
From 196n to 1962 I oIrformed as a design engineer with the Martin-Marietta Corotration wnich included design resconsibility in several missle systems and their control and instrumentation.
From 1963 to 1972 I cerformed as a senior engineer, project engineer and sucervisor with the Sendix Corporation involving various military and non-nilitary systems.
From 1972 to 1979 ! vas emoloyed by the AEC/NRC as a safeguards engineer.
Desconsibilities included develocing Regulatory Guides, NUREG Reports and the writing of regulations.
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I' HAROLD E. PRICE HUMAN FACTOR CONSULTAtli PP0FESSIONAL QUALIFICATIONS In November, 1979 I became a consultant in human factors to the NRC. My efforts have included:
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- Since May 1980, participating in the human factor audits of 9 nuclear power olane control rocms, including TMI-l
- "anaging a study to review and interpret research and aoplications literature relevant to staffing requirements for nuclear power plant control rcoms (NUREG/CR 0764)
- Directing an effort by Biotechnology to redo the NRC human facto s engineering design review guidlines and to develop evaluation criteria for nuclear pcwer plant control rooms
- Acting as the Liason Technical Officer for the Human Factors Society
- n a contract with the NRC to recocrend a long tem human factors l
l plan.
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The MDC has orovided me and my staff special indoctrination training in the oceration of nuclear cower plants.
In addition an ex-Navy nuclear reactor coerator on my staff has provided in-house training and technical l
consultation to me.
I have been active in human factors research and manned systems applications since 1953, and have directed or participated in more than 70 human factors i.
crojects.
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I am a Fellow of the Puman Factors Society, member of the Executive Council, e
I received my training in and Past President of the Potomac Chapter.
4 electrical engineering at the University of Marylanc and Experimental Psychology at the American University.
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since 1970 I have been Executive Vice President of Biotechnology, Inc.
started the Transpo tation and Traffic Safety Program at Biotechnology in This urogram has incluced significant projects in motorist informa-1971.
tion research, pedestrian safety, and operatic nal or safety studies concerning motorcycles, trucks, trains, school buses, and passenger vehicles.
4 In 1974, I started and still direct toa Personnel Performance Architecture This program is concerned with obtaining pro-Procram at Biotechnology.
ductive, safe, and satisfying performance from people in systems and society.
Project emohasis has been in job performance aids R&D, training requirements analysis, job design, human engineering methods and applications, and total cersonnel systems architecture.
Prior to joining Biotechnology, Inc., I was Senior Vice President and Genera From Manager of Serendipity, Inc.; and also one of the founders in 1962.
1953 to 1962, I was with The Matrix Corporation, advancing to a Senior Research Analyst.
Key technical At Serendipity, I had both a technical and management role.
pilot acceptance factors in the development of all-efforts included:
weather landing systems, potential roles of supersonic transport crews, crew recuirenents on a long-duration space mission, and development of a descriptive nodel for determining man's role and the allocation functions Also at Serendipity, I was involved in the initial planning in a system.
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for Project P!MO and contributed as a staff consultant to the solution of nany oroject technical issues. While dire ^'or of the Eastern Operations, I had management responsibility for pr0jects to determine recreation require-ments for astronauts, driver information requirements for route guidance, a ship manning simulation model, and several efforts to support development of a business information system program for Bell Laboratories.
During my ten years with The Matrix Corporation, I directed or participaced in orojects concerned with operation and maintenance problems of airborne j
intercent radar, human engineering recommendations for the F4H-1 and A3J-l weacon system trainers, and human engineering recommendations for test sets of the MK 52 mine for the Bureau of Ordnance.
I was also involved in seversi orojects supporting operational and maintenance personnel system design for ballistic missile systems development, and the crew role in a manned orbiting bomber.
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